1

 

                DEPARTMENT OF HEALTH AND HUMAN SERVICES

 

                      FOOD AND DRUG ADMINISTRATION

 

                CENTER FOR DRUG EVALUATION AND RESEARCH

 

 

 

 

 

 

 

 

 

 

 

 

 

                NONPRESCRIPTION DRUGS ADVISORY COMMITTEE

 

                IN JOINT SESSION WITH THE  DERMATOLOGIC

 

                 AND OPHTHALMIC DRUGS ADVISORY COMMITTEE

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                         Thursday, May 6, 2004

 

                               8:00 a.m.

 

 

 

             Advisors and Consultants Staff Conference Room

                           5630 Fishers Lane

                          Rockville, Maryland

                                                                 2

 

                              PARTICIPANTS

 

      Louis R. Cantilena, Jr., M.D., Ph.D., Chair

      LCDR Dornette Spell-LeSane, MHA, NP-C, Executive

      Secretary

 

      DERMATOLOGIC AND OPHTHALMIC DRUGS ADVISORY

      COMMITTEE MEMBERS

 

                Roselyn E. Epps, M.D.

                Robert Katz, M.D.

                Paula Knudson (Consumer Rep)

                Peter A. Kresel, M.B.A. (Industry Rep)

                Sharon S. Raimer, M.D.

                Eileen W. Ringel, M.D.

                Jimmy D. Schmidt, M.D.

                Thomas R. Ten Have, Ph.D.

                Elizabeth S. Whitmore, M.D.

                Michael G. Wilkerson, M.D.

 

      NONPRESCRIPTION DRUGS ADVISORY COMMITTEE MEMBERS

 

                Michael C. Alfano, D.M.D., Ph.D.

                  (Industry Rep)

                Neal L. Benowitz, M.D.

                Leslie Clapp, M.D.

                Frank F. Davidoff, M.D.

                Jack E. Fincham, Ph.D.

                Y.W. Francis Lam, Pharm.D.

                Sonia Patten, Ph.D. (Consumer Rep)

                Alastair Wood, M.D.

      CONSULTANTS (VOTING)

 

                Alan Bisno, M.D.

                Mahmoud Ghannoum, M.Sc., Ph.D.

      FDA

 

                Jonca Bull, M.D.

                Charles Ganley, M.D.

                Jonathan Wilkin, M.D.

                                                                 3

 

                            C O N T E N T S

 

                                                              PAGE

 

      Call to Order and Introductions:

                Louis R. Cantilena, Jr., M.D., Ph.D.             5

      Conflict of Interest Statement:

                LCDR Dornette Spell-LeSane, MHA, NP-C            8

 

      Welcome and Introductory Remarks:

                Charles Ganley, M.D.                            11

 

                      Efficacy and Labeling Issues

                 for the Over-the-Counter Drug Products

                    Used in Treatment of tinea pedis

                  in Patients 12 years of Age and Over

 

      FDA Presentation

 

      Natural History of tinea pedis and Dermatophyte

         Infections:

                Joseph Porres, M.D., Ph.D.                      12

 

      Study Design and Efficacy Results for tinea pedis

         Clinical Trials (Rx and OTC):

                Kathleen Fritsch, Ph.D.                         44

 

      History and Overview of OTC Topical Antifungal Drug

         Products Monograph:

                Houda Mahayni, Ph.D.                            67

 

      Topical Antifungal Drug Product Labeling:

                Daiva Shetty, M.D.                              94

 

      Infectious Disease Complications of tinea pedis:

                Alan Bisno, M.D.                               127

 

      Microbiology and Dermatophyte Resistance Related to

        the Treatment of tinea pedis:

                Mahmoud Ghannoum, M.Sc., Ph.D.                 154

 

      Committee Discussion                                     178

                                                                 4

 

                      C O N T E N T S (Continued)

 

      Open Public Hearing

 

      Consumer Healthcare Products Association:

                Doug Bierer, Ph.D.                             193

                Boni E. Elewski, M.D.                          194

                Doug Bierer, Ph.D.                             214

 

      Schering-Plough:

                John Clayton, M.D.                             220

 

      Novartis:

                Helmut H. Albrecht, M.D., M.S., FFPM           231

 

      Committee Discussion                                     299

 

                                                                 5

 

  1                      P R O C E E D I N G S

 

  2                 Call to Order and Introductions

 

  3             DR. CANTILENA:  Good morning.  I am Louis

 

  4   Cantilena.  I am Director of the Division of

 

  5   Clinical Pharmacology and Medical Toxicology at the

 

  6   Uniformed Services University of the Health

 

  7   Sciences in Bethesda, Maryland.  I am going to be

 

  8   chairing this joint session of the Nonprescription

 

  9   Drugs Advisory Committee and the Dermatologic and

 

 10   Ophthalmic Drugs Advisory Committee held here in

 

 11   Rockville.

 

 12             Before we get started with the agenda and

 

 13   the conflict of interest statement, I would like to

 

 14   go around the room and have everyone introduce

 

 15   themselves and state their affiliation.  We can

 

 16   start to my right since there are more filled seats

 

 17   to the right than left.

 

 18             DR. RINGEL:  I am Dr. Eileen Ringel.  I am

 

 19   a dermatologist in Waterville, Maine and loosely

 

 20   affiliated with Mary Hitchcock Medical Center.

 

 21             DR. LAM:  Francis Lam from the University

 

 22   of Texas of Texas Health Science Center at San

 

                                                                 6

 

  1   Antonio, a member of NDAC.

 

  2             DR. PATTEN:  Sonia Patten.  I am consumer

 

  3   representative on NDAC.  I am an anthropologist on

 

  4   faculty at Macalester College in St. Paul,

 

  5   Minnesota.

 

  6             DR. WILKERSON:  Michael Wilkerson, Tulsa,

 

  7   Oklahoma, Hillcrest Healthcare Systems.

 

  8             DR. RAIMER:  Sharon Raimer, dermatologist,

 

  9   University of Texas in Galveston.

 

 10             DR. EPPS:  Roselyn Epps, Chief, Division

 

 11   of Dermatology, Children's National Medical Center,

 

 12   Washington, D.C.

 

 13             DR. BENOWITZ:  I am Neal Benowitz from

 

 14   U.C., San Francisco, internal medicine, clinical

 

 15   pharmacology, medical toxicology, and on the

 

 16   Nonprescription Drug Committee.

 

 17             MS. KNUDSON:  Paula Knudson on the

 

 18   Dermatology Committee as the community

 

 19   representative.  I am an IRB administrator.

 

 20             MR. KRESEL:  I am Peter A. Kresel, Senior

 

 21   Vice President of Global Regulatory Affairs with

 

 22   Allergan in Irvine, California.  I am the industry

 

                                                                 7

 

  1   representative for the Dermatologic and Ophthalmic

 

  2   Drugs Advisory Committee.

 

  3             DR. ALFANO:  I am Michael C. Alfano, Dean,

 

  4   College of Dentistry at New York University.

 

  5             DR. TEN HAVE:  Tom Ten Have, biostatistics

 

  6   and epidemiology at the University of Pennsylvania.

 

  7             DR. WOOD:  I am Alastair Wood from

 

  8   Vanderbilt.

 

  9             DR. GANLEY:  I am Charlie Ganley, Director

 

 10   of Over-the-Counter Drugs at FDA.

 

 11             DR. WILKIN:  I am Jonathan Wilkin,

 

 12   Director of the Division of Dermatologic and Dental

 

 13   Drug Products, FDA.

 

 14             DR. KATZ:  I am Robert Katz,

 

 15   dermatologist, Rockville, Maryland and Clinical

 

 16   Assistant Professor of Medicine at Georgetown.  I

 

 17   am part of the FDA Advisory Committee.

 

 18             DR. SCHMIDT:  I am Jimmy Schmidt from

 

 19   Houston, Texas.

 

 20             DR. DAVIDOFF:  I am Frank Davidoff.  I am

 

 21   on NDAC.  I am an internist and Editor Emeritus of

 

 22   the Annals of Internal Medicine.

 

                                                                 8

 

  1             DR. WHITMORE:  Beth Whitmore.  I am a

 

  2   dermatologist in private practice, Wheaton,

 

  3   Illinois.

 

  4             LCDR SPELL-LeSANE:  Dornette Spell-Lesane,

 

  5   Acting Executive Secretary for NDAC.

 

  6             DR. CANTILENA:  Did we miss anyone?

 

  7             Go ahead, Dr. Bisno.

 

  8             DR. BISNO:  I am Alan Bisno, Professor

 

  9   Emeritus of Internal Medicine, University of Miami,

 

 10   School of Medicine.

 

 11             DR. CANTILENA:  Thank you.

 

 12             Dornette will read the conflict of

 

 13   interest statement for this meeting.

 

 14                  Conflict of Interest Statement

 

 15             LCDR SPELL-LeSANE:  Good morning.  The

 

 16   following announcement addresses the issue of

 

 17   conflict of interest with respect to this meeting

 

 18   and is made a part of the record to preclude even

 

 19   the appearance of such at this meeting.

 

 20             Based on the agenda, it has been

 

 21   determined that the topics of today's meeting are

 

 22   issues of broad applicability and there are no

 

                                                                 9

 

  1   products being approved at this meeting.  Unlike

 

  2   issues before a committee in which a particular

 

  3   product is discussed, issues of broader

 

  4   applicability involve many industrial sponsors and

 

  5   academic institutions.

 

  6             All Special Government Employees have been

 

  7   screened for their financial interests as they may

 

  8   apply to the general topics at hand.  To determine

 

  9   if any conflict of interest existed, the Agency has

 

 10   reviewed the agenda and all relevant financial

 

 11   interests reported by the meeting participants.

 

 12             The Food and Drug Administration has

 

 13   granted general matters waivers to the Special

 

 14   Government Employees participating in this meeting

 

 15   who require a waiver under Title 18, United States

 

 16   Code, Section 208.

 

 17             A copy of the waiver statements may be

 

 18   obtained by submitting a written request to the

 

 19   Agency's Freedom of Information Office, Room 12A-30

 

 20   of the Parklawn Building.

 

 21             Because general topics impact so many

 

 22   entities, it is not prudent to recite all potential

 

                                                                10

 

  1   conflicts of interest as they apply to each member,

 

  2   consultant, and guest speaker.

 

  3             FDA acknowledges that there may be

 

  4   potential conflicts of interest, but because of the

 

  5   general nature of the discussion before the

 

  6   committee, these potential conflicts are mitigated.

 

  7             With respect to FDA's invited industry

 

  8   representatives, we would like to disclose that Mr.

 

  9   Peter Kresel and Dr. Michael Alfano are

 

 10   participating in this meeting as industry

 

 11   representatives acting on behalf of regulated

 

 12   industry.  Mr. Kresel is employed by Allergan, Dr.

 

 13   Alfano is the Dean of College of Dentistry at New

 

 14   York University.

 

 15             In the event that the discussions involve

 

 16   any other products or firms not already on the

 

 17   agenda for which FDA participants have a financial

 

 18   interest, the participants' involvement and their

 

 19   exclusion will be noted for the record.

 

 20             With respect to all other participants, we

 

 21   ask in the interest of fairness that they address

 

 22   any current or previous financial involvement with

 

                                                                11

 

  1   any firm whose product they may wish to comment

 

  2   upon.

 

  3             Thank you.

 

  4             DR. CANTILENA:  Thank you, Dornette.

 

  5             Now we will have our kickoff from Dr.

 

  6   Charlie Ganley of FDA.

 

  7                Welcome and Introductory Comments

 

  8             DR. GANLEY:  Thank you.  I am just going

 

  9   to say a few words.

 

 10             First, I wanted to thank the members of

 

 11   the Nonprescription Drugs Advisory Committee and

 

 12   the Dermatologic and Ophthalmic Drugs Advisory

 

 13   Committee for participating in this discussion.

 

 14             Today, we are going to talk about tinea

 

 15   pedis.  It is not a high profile disease, but it

 

 16   does affect millions of people in the United States

 

 17   each year, and it is important to those individuals

 

 18   who have the disease.

 

 19             So, we are looking forward to the

 

 20   discussion today.  I think the executive summary

 

 21   and the questions provide you with some of the

 

 22   concerns we have, the current products, and the

 

                                                                12

 

  1   current development programs that are going on

 

  2   right now.

 

  3             I think John Wilkin is going to talk a

 

  4   little later, prior to answering the questions

 

  5   about some of the issues, so I think we ought to

 

  6   just start with the FDA presentations.

 

  7             DR. CANTILENA:  Thank you, Dr. Ganley.

 

  8   For the members of the committee, your blue folder

 

  9   in front of you has slides for all FDA speakers

 

 10   except for the last person, so as soon as we get

 

 11   those, we will hand those out to you.

 

 12             We would like to then start.  Dr. Porres

 

 13   from FDA will be the first FDA speaker, and he will

 

 14   then be followed by four other speakers.

 

 15                         FDA Presentation

 

 16                Natural History of Tinea Pedis and

 

 17                     Dermatophyte Infections

 

 18             DR. PORRES:  I am Joseph Porres, a medical

 

 19   officer in the Division of Dermatological and

 

 20   Dental Drug Products.  I don't suppose that is a

 

 21   conflict of interest for this presentation.

 

 22             [Slide.]

 

                                                                13

 

  1             I would like to start by sharing with you

 

  2   a few points about the natural history of tinea

 

  3   pedis.  Later on, I would also like to share some

 

  4   points with you about clinical trials for tinea

 

  5   pedis, just to set the tone.

 

  6             In the first part, we talk about natural

 

  7   history, and I will cover the types of clinical

 

  8   presentations for tinea pedis, dermatophyte

 

  9   species, which most often cause this infection, the

 

 10   so-called dermatomycosis syndrome, some of the

 

 11   factors which may predispose someone to develop

 

 12   tinea pedis, factors that complicate tinea pedis

 

 13   and complications that may develop from tinea

 

 14   pedis.

 

 15             I will try to give you a brief outlook of

 

 16   epidemiology, and will talk about recurrence, some

 

 17   people who have been treated.  We talk about

 

 18   diagnosis of tinea pedis and a little bit about

 

 19   treatment.

 

 20             [Slide.]

 

 21             There are two main anatomic subtypes of

 

 22   tinea pedis - interdigital, which some people refer

 

                                                                14

 

  1   to as intertriginous, in between the toes, and

 

  2   plantar.

 

  3             Within the plantar, there are two distinct

 

  4   types - moccasin and vesicobullous.

 

  5             Let's talk a little bit more about each

 

  6   one of these.

 

  7             The interdigital often comes with

 

  8   pruritus, erythema, some scaling, occasionally

 

  9   fissure and maceration particularly if there has

 

 10   been overgrowth with some bacterial or candida

 

 11   species.

 

 12             The moccasin type, which is the one

 

 13   affecting the sides of the foot, tends to be

 

 14   dry-looking and scaling, sometimes there may be

 

 15   pruritus, sometimes there may be some erythema.

 

 16             The vesicobullous usually affects the

 

 17   plantar of the foot or the arch of the foot, and

 

 18   the vesicles is the main component.  Oftentimes,

 

 19   there may be itching, scaling, and erythema.

 

 20             Most patients seem to present with a

 

 21   combination of some of these features.  It is rare

 

 22   to find someone who has just one pure type.

 

                                                                15

 

  1             Then, we have the term "athlete's foot,"

 

  2   which is sort of a generic term that the layman

 

  3   uses when they refer to just about any type of

 

  4   fungus infection on the foot.  It is a loose term,

 

  5   it is hard to define.  It is not really a medical

 

  6   term.

 

  7             [Slide.]

 

  8             Now, about the organisms that tend to

 

  9   cause these infections.  The most common is

 

 10   Trichophyton rubrum, which is the predominant

 

 11   organism in this country since World War II, and it

 

 12   tends to account for about anywhere from 60 to 80

 

 13   percent of cases of tinea pedis, mainly tends to

 

 14   cause the plantar, moccasin type.

 

 15             Occasionally, there are some teeny tiny

 

 16   blisters on the plantar of the foot that quickly

 

 17   dry up and leave a collarette of scales, which has

 

 18   been described as very typical for Trichophyton

 

 19   rubrum.

 

 20             It may spread to the nail and then

 

 21   particularly is responsible for cases of distal

 

 22   subungual onychomycosis.  It can also spread to

 

                                                                16

 

  1   other body parts, which we will see in a minute.

 

  2             The second most common species of

 

  3   dermatophyte is Trichophyton mentagrophytes,

 

  4   usually responsible for about 15 percent of cases.

 

  5   It tends to be causative for the vesicular type,

 

  6   and it may also spread to the nails, but it tends

 

  7   to mostly cause superficial white nail involvement.

 

  8             Finally, we have Epidermophyton floccosum,

 

  9   which tends to affect about 7 percent of the cases,

 

 10   and then there are other species, which are rare,

 

 11   also recovered in cultures of larger studies.

 

 12             [Slide.]

 

 13             This is a typical representation of an

 

 14   interdigital tinea pedis.

 

 15             [Slide.]

 

 16             Here we have the tinea plantaris with the

 

 17   tiny collarettes.  These were vesicles that broke

 

 18   readily, and as you can see, clearly resembles

 

 19   dryness of the foot.  Many patients will look at

 

 20   these and think it is just dryness, and even some

 

 21   physicians may consider this dryness and not treat

 

 22   it.  Rarely, it will be symptomatic.

 

                                                                17

 

  1             [Slide.]

 

  2             Here we have the vesicular type, more

 

  3   abrupt, more acute, more likely to have symptoms.

 

  4             [Slide.]

 

  5             This is the typical moccasin type, which

 

  6   again many patients will look at this and think,

 

  7   oh, my God, my feet are very dry, and they won't

 

  8   even suspect they have a fungus.  Oftentimes, it

 

  9   will itch, and even some physicians may call this

 

 10   just dry skin.

 

 11             [Slide.]

 

 12             Now, let's talk about the dermatomycosis

 

 13   syndrome described for Trichophyton rubrum.  The

 

 14   hallmark is the moccasin type infection, and from

 

 15   here it can spread.  There can be spreading between

 

 16   household members back and forth. It can spread

 

 17   directly to the nails or to the interdigital area

 

 18   of the feet.

 

 19             Then, by spreading distally, it can go

 

 20   into the hands and from there to the fingernails.

 

 21   It can go to areas of the body, sometimes it may

 

 22   infect the hair follicles, producing a distinct

 

                                                                18

 

  1   clinical picture referred to as Majocchi's

 

  2   granuloma.

 

  3             It can go to the groin also, and then it

 

  4   is called tinea cruris.  These types of spreading

 

  5   usually occur when we dress and bring our clothes

 

  6   up, passing by the foot, or with towels we may use

 

  7   for different areas of the body.

 

  8             [Slide.]

 

  9             Now, there are some predisposing factors

 

 10   that could be important.  It has been said

 

 11   repeatedly that tinea pedis is far more common in

 

 12   closed communities like army barracks and boarding

 

 13   schools, or among people who frequent public baths

 

 14   and swimming pools.

 

 15             It is probably important to have some

 

 16   local trauma for the infection to set in, trauma

 

 17   like you can develop if you go on a long march and

 

 18   your feet are going to be sweaty and hot and

 

 19   occluded by occlusive foot gear, and you may suffer

 

 20   from immersion into water or end up with wet feet

 

 21   just from your own perspiration.

 

 22             If the shoes are very tight fitting, there

 

                                                                19

 

  1   may be repeated friction and trauma, which also may

 

  2   contribute to set up a portal of infection for the

 

  3   dermatophyte.

 

  4             It has been said that usually, it is

 

  5   important to have a species of organism to be able

 

  6   to cause infection.  This was demonstrated in

 

  7   Vietnam, for instance, until they found that it was

 

  8   the hair of rats that was the vehicle for the

 

  9   infection of many of the soldiers with

 

 10   Trichophyton.

 

 11             Again, if you look at a household, it is

 

 12   said, at least in one study, that about 17 percent

 

 13   of the members of the household are likely to have

 

 14   concomitant tinea pedis, and there may be a

 

 15   familial predisposition based on perhaps inadequate

 

 16   immunological response that may facilitate these

 

 17   patients to develop a chronic infection.

 

 18             [Slide.]

 

 19             Now, tinea pedis may become complicated if

 

 20   the patient is either immunosuppressed or has any

 

 21   atopic constitution, or is diabetic, or has

 

 22   compromised circulation, or there is repeated

 

                                                                20

 

  1   trauma, again ill-fitting shoes or tight-fitting

 

  2   shoes, and many of these things are more likely to

 

  3   appear among the geriatric population.

 

  4             [Slide.]

 

  5             One interesting complication from tinea

 

  6   pedis could be cellulitis.  It is probably not

 

  7   exceedingly common, but among people who do have

 

  8   cellulitis of the lower extremities, a great number

 

  9   of them seem to have a pre-existing tinea pedis.

 

 10   This might have been unrecognized for a long time

 

 11   by patient and physician.

 

 12             Treatment may not have been given, or, if

 

 13   given, maybe was used too short a period of time,

 

 14   or perhaps the nail was not treated and reinfection

 

 15   kept taking place, or maybe it was a diabetic

 

 16   patient who had decreased sensory perception and

 

 17   would not recognize the pruritus that otherwise may

 

 18   alert one of having the infection.

 

 19             [Slide.]

 

 20             Let's talk a little bit about

 

 21   epidemiology.  A number of studies have rated the

 

 22   degree of infection among the population at large,

 

                                                                21

 

  1   and do find rates as low as 15 percent and as high

 

  2   as 70 percent.

 

  3             It has been said that among people who

 

  4   attend the general clinic, if one were to look at

 

  5   their feet, about 40 percent of them tend to have

 

  6   tinea pedis, oftentimes unsuspected by the patient.

 

  7             However, among the patients who do go to a

 

  8   doctor to seek treatment for the tinea pedis,

 

  9   interestingly, many of them do have already nail

 

 10   involvement with a fungus. There are a number of

 

 11   cases that remain undiagnosed for a long time.

 

 12             Interestingly, dermatophytes have been

 

 13   isolated from the feet of normal individuals in

 

 14   varying rates.  They have been isolated from public

 

 15   showers, from swimming pools, and from shoes and

 

 16   socks of affected individuals.

 

 17             [Slide.]

 

 18             Now, what happens to a person who has been

 

 19   treated afterwards?  It has been very hard to find

 

 20   some data that I can share with you about this.

 

 21             Luckily, I found one set of two papers

 

 22   which look at the same population, one by

 

                                                                22

 

  1   Bergstresser, where they treated a number of people

 

  2   with 200 fungals, twice a day, either for one week

 

  3   or for four weeks, and then, a second paper by

 

  4   Elewski and others, where they look at the same

 

  5   patients 15 to 18 months later.

 

  6             [Slide.]

 

  7             So, let me show you what they found.

 

  8   There were 193 evaluable patients with interdigital

 

  9   tinea pedis.  Again, the treatment was twice a day,

 

 10   and it was either terbinafine cream in this case or

 

 11   clotrimazole cream, and there were 2 ounces for

 

 12   each drug treatment, one week or four weeks.

 

 13             They looked at it 15 to 18 months later,

 

 14   and for this particular part of the study, they

 

 15   only reported the mycology cure rates.

 

 16             [Slide.]

 

 17             There were 193 patients evaluable in the

 

 18   study.  Of these, 130 were declared mycology cure

 

 19   at the end of 12 weeks of the study.  Of these,

 

 20   they were able to follow up 93 during the 15 to 18

 

 21   months of the second part of the study, and, of

 

 22   these 93, 44 felt that they needed more treatments,

 

                                                                23

 

  1   so we consider this either insufficiently treated,

 

  2   or a relapse, or a reinfection, and there is really

 

  3   no way at this point to distinguish which one of

 

  4   the three possibilities we are dealing with here.

 

  5             Then, they looked at the patients who

 

  6   didn't feel they had need for more treatment.

 

  7   There was it appeared to be cure, and they took

 

  8   cultures.  Of these 49, 24 developed a positive

 

  9   culture anyway.

 

 10             As a sideline, of these 24, 8 of them had

 

 11   an organism that this time was identified with a

 

 12   different name than the one given at baseline.  It

 

 13   is hard to tell whether one of the two might have

 

 14   been misdiagnosed or whether this actually

 

 15   represents infection with a different organism.

 

 16             So, all together, we see that there were

 

 17   78 percent of the people who had originally been

 

 18   called "mycology cure," who relapsed or reinfected

 

 19   at some time after the treatment.

 

 20             [Slide.]

 

 21             Now, let's go a little bit into how we

 

 22   make a diagnosis of tinea pedis.  The main part

 

                                                                24

 

  1   here is clinical. We look at the signs and symptoms

 

  2   and try to recognize what may be part of the

 

  3   typical picture.

 

  4             It can be aided by mycology, which

 

  5   consists of a direct microscopic examination,

 

  6   usually referred to as KOH, and of which there are

 

  7   many variants, and then the culture.

 

  8             The nice thing about the KOH is that it

 

  9   can provide a quick diagnosis, confirming the

 

 10   clinical impression, and therefore it would help to

 

 11   avoid delaying giving the indicated treatment or

 

 12   avoid prescribing a treatment that may not be

 

 13   appropriate.

 

 14             [Slide.]

 

 15             Now, if a physician wants to treat tinea

 

 16   pedis and goes to the literature to see how to

 

 17   treat it, you will find information similar to

 

 18   this.  This is just one example.

 

 19             I look at this current textbook,

 

 20   "Treatment of Skin Disease," by Lebohl, published

 

 21   by Mosby in 2003, and they report results for

 

 22   terbinafine from different studies, clotrimazole,

 

                                                                25

 

  1   miconazole, and a couple of others.

 

  2             Oftentimes, they give the results for

 

  3   mycology cure and other times they just say cure

 

  4   rates and do not specify what kind of cure it was,

 

  5   but looking at the numbers here in the right

 

  6   column, I suspect that they are mostly referring to

 

  7   mycology cures.

 

  8             Sometimes they tell us how long were those

 

  9   patients treated that reached these rate numbers,

 

 10   and oftentimes they will tell us the dosage that

 

 11   was used, but sometimes they don't tell us.  They

 

 12   just say, well, terbinafine 97 percent cures, and

 

 13   we don't know what this means.  It is unfortunate

 

 14   that this information is so scant that it is hard

 

 15   for the clinician to really figure out what these

 

 16   numbers represent.

 

 17             I would like you to sort of keep an idea

 

 18   in mind about the magnitude of these rates when the

 

 19   statistician brings data from the studies that she

 

 20   had reviewed, just keep this in mind.

 

 21             [Slide.]

 

 22             Now, let's talk a little bit about

 

                                                                26

 

  1   clinical trials for tinea pedis.  I would like to

 

  2   focus a little bit on dose ranging studies and on

 

  3   clinical trials for safety and efficacy.

 

  4             [Slide.]

 

  5             Dose ranging studies for tinea pedis are

 

  6   particularly always recommended by the Agency when

 

  7   drug developers come here for meetings and

 

  8   orientation. Unfortunately, most of the time this

 

  9   recommendation is ignored.  This is too bad because

 

 10   with dose ranging studies, it could be helpful to

 

 11   try to determine what is the most interesting dose

 

 12   that may have the best safety and efficacy profile.

 

 13             Now, in dose ranging studies, usually,

 

 14   there are three elements that can be studied:  drug

 

 15   strength, drug concentration, the frequency of

 

 16   application, and the duration of treatment.

 

 17             We have some limitations here.  Drug

 

 18   strength, sometimes there are certain higher doses

 

 19   that we cannot study either because they may have

 

 20   an unsafe profile or for chemistry reasons, perhaps

 

 21   the drug reaches maximum solubility and we cannot

 

 22   study any concentrations above that.

 

                                                                27

 

  1             Now, frequency of application also has

 

  2   some limitations.  We can expect compliance of

 

  3   patients to reach up to a certain limit.  If we

 

  4   tell a patient to apply something once a day or

 

  5   twice a day, they are likely to do it.  If we tell

 

  6   them to use it 74 times a day, they are not likely

 

  7   to do it, so studying things more than twice a day

 

  8   probably is not very practical.

 

  9             So, we are left with duration of treatment

 

 10   which is where we have the greatest latitude,

 

 11   however, marketing pressures seem to make drug

 

 12   developers aim for ever decreasing durations of

 

 13   treatment, perhaps so they can advertise that a

 

 14   product can kill the organism in fewer days than

 

 15   the other competing product.  Sometimes these may

 

 16   be at the expense of efficacy.

 

 17             [Slide.]

 

 18             Now, in clinical safety and efficacy

 

 19   trials, I would like to focus about how do we

 

 20   assess results of these trials and what the

 

 21   outcomes from these assessments will be.

 

 22             [Slide.]

 

                                                                28

 

  1             What we assess or what has been assessed

 

  2   routinely is mycology, again direct microscopic

 

  3   examination and mycology culture, and clinical, a

 

  4   variety of signs and symptoms, and there are

 

  5   studies which have just looked at a couple of

 

  6   these, others that look at many.

 

  7             Others make a composite of this, others

 

  8   may use what is called the investigator's global

 

  9   assessment, which is kind of like a comprehensive

 

 10   picture of what the disease looks like at that

 

 11   particular point.

 

 12             [Slide.]

 

 13             The outcomes from these assessments are

 

 14   usually mycology cure, which involves having a

 

 15   negative KOH in a negative culture.  We don't like

 

 16   this term very much at the FDA.  We would like to

 

 17   refer to it as negative culture because perhaps it

 

 18   is not really a cure in many cases unless it is

 

 19   accompanied by a clinical cure, as well.

 

 20             Then, we have clinical outcomes.  One is

 

 21   effective treatment, which requires not only

 

 22   negative mycology or mycology cure, but also

 

                                                                29

 

  1   absence of symptoms and at most, some residual

 

  2   signs remaining.

 

  3             Here, I should introduce or remind you of

 

  4   a concept of skin turnover.  The epidermis has a

 

  5   maximum speed at which it can turn over its cells,

 

  6   which is about four weeks, so you could have a

 

  7   patient who is actually a cure, and may still have

 

  8   some residual erythema or some residual scaling.

 

  9             However, after these four weeks, we should

 

 10   be expecting that these residual signs should not

 

 11   be present in a patient who is a cure.

 

 12             Then, we go into complete cure, which is

 

 13   the gold standard, where mycology is negative or

 

 14   mycology cure, and there are no signs or symptoms

 

 15   left of the disease.

 

 16             [Slide.]

 

 17             Now, in clinical safety and efficacy

 

 18   studies, oftentimes the inclusion/exclusion

 

 19   criteria that come with the protocols do not seem

 

 20   to mimic the population which could be expected to

 

 21   actually use these products in the real world once

 

 22   the product is approved.

 

                                                                30

 

  1             For instance, they tend to include only

 

  2   people who are very healthy and who perhaps have

 

  3   disease limited to just a small area, such as toe

 

  4   webs, and exclude more difficult cases to treat

 

  5   that might reduce their overall efficacy rate, so

 

  6   they exclude people with onychomycosis or who have

 

  7   the moccasin type, which they apparently think is

 

  8   harder to treat, and they will exclude people who

 

  9   are diabetic or immunosuppressed, or who may have

 

 10   compromised circulation, but all of these patients

 

 11   would be expected, they will be users of the

 

 12   product later on.

 

 13             At this point, I would like to introduce

 

 14   Dr. Kathleen Fritsch, who will give you a summary

 

 15   of her review of some studies.

 

 16             Thank you for your attention.

 

 17             DR. GANLEY:  If anyone had questions for

 

 18   Dr. Porres now, they could probably ask them.

 

 19             DR. CANTILENA:  We actually have time

 

 20   slotted, actually, plenty of time before lunch, but

 

 21   I guess if there are specific questions, perhaps we

 

 22   have time for one or two specific questions for Dr.

 

                                                                31

 

  1   Porres before we go to the next speaker.

 

  2             Yes, Dr. Ten Have.

 

  3             DR. TEN HAVE:  I have a question regarding

 

  4   the definition of the efficacy rates on page 9 that

 

  5   were reported.  I missed the definition.  Could you

 

  6   just repeat it?

 

  7             DR. PORRES:  In the handout, page 9?

 

  8             DR. TEN HAVE:  Handout, page 9.

 

  9             DR. PORRES:  The question, if I

 

 10   understood, is how is cure defined here?  Okay.

 

 11             DR. TEN HAVE:  How are the efficacy rates

 

 12   defined based on a cure definition?

 

 13             DR. PORRES:  I am glad you asked that

 

 14   question, because the clinician, looking at this

 

 15   information in textbooks, should be asking the same

 

 16   question.  The point is that when you look at the

 

 17   sources in the literature, they don't tell you

 

 18   anything.  They just give you some rates and hope

 

 19   that you will think that these products are all

 

 20   wonderful, and they don't tell you how these

 

 21   numbers are derived, and you are lost.

 

 22             So, that is precisely the point I was

 

                                                                32

 

  1   trying to make.

 

  2             DR. CANTILENA:  So, the answer is they are

 

  3   really not well defined.

 

  4             DR. PORRES:  They don't tell us, they just

 

  5   give us a summary.

 

  6             DR. CANTILENA:  Dr. Wood.

 

  7             DR. WOOD:  My question may be an extension

 

  8   of the last one.  On the last slide, you talk about

 

  9   the exclusion criteria that include harder cases to

 

 10   treat.  I presume you mean by that, that the

 

 11   outcome is poorer, is that right, that the cure

 

 12   rate is lower?

 

 13             DR. PORRES:  The people who may be harder

 

 14   to treat--

 

 15             DR. WOOD:  I understand that is what it

 

 16   says, but do you mean by that, that they are harder

 

 17   to treat because the efficacy is lower in that

 

 18   group?  I mean diabetics aren't harder to treat per

 

 19   se, and they must either have poorer outcome, or do

 

 20   you mean that diabetics can't rub the stuff on

 

 21   their foot, you know, what do you mean by that?

 

 22             Just to finish the question, I assume what

 

                                                                33

 

  1   is meant there is that the outcome is poorer in

 

  2   these patients, what are the data to support that?

 

  3             DR. PORRES:  I think you will have to ask

 

  4   the drug developers why do they want to exclude

 

  5   those patients in the first place.  They don't give

 

  6   us a rationale, they just want to exclude them

 

  7   maybe to keep the study neater, and I am not aware

 

  8   of any data that actually shows whether they are

 

  9   easier to treat or more difficult to treat, but

 

 10   that is the way they design their protocols.

 

 11             Now, the moccasin type--

 

 12             DR. WOOD:  So, the slide says you excluded

 

 13   harder cases.

 

 14             DR. PORRES:  Yes.

 

 15             DR. WOOD:  Are there data to support them

 

 16   being harder, or is that just--

 

 17             DR. PORRES:  They assumed they are going

 

 18   to be harder.

 

 19             DR. WOOD:  I see.

 

 20             DR. PORRES:  For instance, if there is

 

 21   nail involvement, they may be more prone to have

 

 22   reinfection from the nail if they are not treating

 

                                                                34

 

  1   the nail at the same time, so they suspect that

 

  2   those are going to complicate the outcomes.

 

  3             DR. WOOD:  But you have no data to say

 

  4   that the outcome is poorer in these patients?

 

  5             DR. PORRES:  No.

 

  6             DR. WOOD:  That is what I am trying to get

 

  7   at.

 

  8             DR. PORRES:  We don't have the data.

 

  9             DR. WOOD:  It relates directly to the

 

 10   question.  That is why I am pushing this part.

 

 11             DR. PORRES:  No.

 

 12             DR. CANTILENA:  Dr. Fincham.

 

 13             DR. FINCHAM:  Dr. Porres, I am assuming

 

 14   that these criteria, either inclusion or exclusion,

 

 15   are set by the manufacturer, there is no

 

 16   constraints on those designs.

 

 17             DR. PORRES:  Well, they send us the

 

 18   protocols.  We look at them, and sometimes, you

 

 19   know, we make suggestions. We encourage the study

 

 20   of all comers.  Sometimes they insist they want to

 

 21   study just a very narrow group, and sometimes we

 

 22   are more influential than others.

 

                                                                35

 

  1             DR. CANTILENA:  A comment from Dr. Wilkin.

 

  2             DR. WILKIN:  Actually, you caught it right

 

  3   at the very end, and sometimes they do.  We have

 

  4   had some tinea pedis trials where patients with

 

  5   onychomycosis, often the same fungus that is

 

  6   affecting the plantar surface of the foot is also

 

  7   in the nail.

 

  8             We have had some trials like that, so I

 

  9   think it is not all or none, and it is true that we

 

 10   don't know for sure that they are harder, but we

 

 11   sense that there may be some lower efficacy, but we

 

 12   don't have good numbers on that, that is correct.

 

 13             DR. CANTILENA:  Dr. Alfano.

 

 14             DR. ALFANO:  My question relates to the

 

 15   fact that you spoke about predisposing factors, and

 

 16   you mentioned trauma is regularly associated to get

 

 17   this infection started.

 

 18             What happens with those predisposing

 

 19   factors in the course of the disease, i.e., if the

 

 20   subject doesn't change their tight shoes, do they

 

 21   start with hyperkeratosis from the irritation from

 

 22   the shoes, and is it appropriate to expect that to

 

                                                                36

 

  1   go away if they don't change their predisposing

 

  2   factors?

 

  3             DR. PORRES:  There is really no hard data

 

  4   looking at what happens on a series of cases from

 

  5   the beginning to the end, but this is the general

 

  6   gestalt, the general feel for what is felt, how

 

  7   this disease evolves, and it is felt that these

 

  8   factors are important in either facilitating

 

  9   development of the disease or in making it worse,

 

 10   but there is no hard data that anyone would show if

 

 11   you wear your shoes 10 minutes longer, you are more

 

 12   prone to have disease than it you wear them 10

 

 13   minutes less, but it is felt that usually, that is

 

 14   the case, but there is no hard data for any of

 

 15   this.  This is kind of like a field that has

 

 16   developed through the years, that most people seem

 

 17   to agree as a general concept.

 

 18             DR. CANTILENA:  Our final question over

 

 19   here.  Dr. Benowitz.

 

 20             DR. BENOWITZ:  Two questions.  The first

 

 21   one, you had said that as many as 70 percent of the

 

 22   general population can have positive cultures. 

 

                                                                37

 

  1   Given that in the recurrent studies, does a

 

  2   persistent positive culture with a clinical

 

  3   response mean that there will be a clinical

 

  4   recurrence?

 

  5             DR. PORRES:  Could you rephrase the

 

  6   question again?  I am sorry.

 

  7             DR. BENOWITZ:  You said that as many as 70

 

  8   percent of the population, assumingly not

 

  9   clinically infected, can have positive cultures.

 

 10             DR. PORRES:  No, no, that is not what I

 

 11   said, I am sorry.  What I said is that some people,

 

 12   published reports looking at the incidence of tinea

 

 13   pedis in a particular population like maybe in

 

 14   India or Canada, or somewhere, and they report that

 

 15   they found 70 percent of the people at large had

 

 16   the disease.

 

 17             DR. BENOWITZ:  Oh, had the clinical

 

 18   infection.  I guess the other part is still valid.

 

 19             If you have a positive culture, but you

 

 20   have a clinical response, does that always

 

 21   translate into a later clinical recurrence?

 

 22             DR. PORRES:  If you have--

 

                                                                38

 

  1             DR. BENOWITZ:  You have been treated, you

 

  2   have a clinical response, but you do not have a

 

  3   mycologic response, does that always predict a

 

  4   clinical recurrence?

 

  5             DR. PORRES:  Well, if there is clinical

 

  6   cure, you say, but the culture is still positive?

 

  7             DR. BENOWITZ:  Yes.

 

  8             DR. PORRES:  That would never be called a

 

  9   success by definition, so I don't think anybody has

 

 10   ever looked to see what happened to the patient

 

 11   afterwards.  It is just declared a failure, and

 

 12   there is no follow-up.

 

 13             DR. BENOWITZ:  Is there any issue of a

 

 14   carrier state, like we see with other infections?

 

 15   Is that an issue here?

 

 16             DR. PORRES:  Possibly, there is no hard

 

 17   data, there is contamination with other household

 

 18   members or other school members or other army

 

 19   fellows, you know, but there is really no hard data

 

 20   for any of these things.

 

 21             DR. BENOWITZ:  Okay.  The second question

 

 22   is if an expert dermatologist is seeing a patient

 

                                                                39

 

  1   who has these infections, and they are diabetic or

 

  2   they are immunocompromised, would they be treated

 

  3   any differently from any other patient?  What is

 

  4   the standard of care for treatment of these more

 

  5   high risk patients?

 

  6             DR. PORRES:  The dermatologist would want

 

  7   to make sure that whoever is taking care of the

 

  8   diabetes for that patient would have provided

 

  9   adequate treatment or if they are

 

 10   immunocompromised, that they have the adequate

 

 11   treatment, you know, just as a general feel for my

 

 12   practice, I have seen people who have maybe HIV or

 

 13   something else, and they have tinea, and I can

 

 14   figure they are much harder to treat and the

 

 15   treatment is much, much longer, and oftentimes they

 

 16   stop because they get tired of treating these for

 

 17   months or they stop when they feel better, thinking

 

 18   that maybe they have cured the problem, but it was

 

 19   just a little bit too early, and within a few

 

 20   months they come back with full-blown disease.

 

 21             So, the dermatologist can treat the skin,

 

 22   but usually, we need the concurrence of the other

 

                                                                40

 

  1   types of physicians who treat the other components

 

  2   like vascular disease or whatever.

 

  3             DR. BENOWITZ:  I guess my point is would a

 

  4   dermatologist initiate systemic antifungal therapy

 

  5   rather than try topical therapy first if someone is

 

  6   at high risk?

 

  7             DR. PORRES:  Well, that is an interesting

 

  8   question and I didn't want to address it here

 

  9   because we are talking about topical antifungals,

 

 10   but if you look at the textbooks and references on

 

 11   how to treat the disease, there are many who would

 

 12   say that you need to use also systemic treatment

 

 13   for tinea pedis together with topical antifungals.

 

 14   Some still say that.

 

 15             DR. BENOWITZ:  I think it is important for

 

 16   us because that really affects labeling for high

 

 17   risk patients. We need to know what patients need

 

 18   to understand about their disease.

 

 19             DR. PORRES:  You are absolutely correct,

 

 20   and that is why we are here today.

 

 21             DR. CANTILENA:  Thank you, Dr. Benowitz.

 

 22             We have one final comment from Dr.

 

                                                                41

 

  1   Schmidt, and then, since you work here, Dr. Wilkin,

 

  2   you can have the final, final comment.

 

  3             DR. SCHMIDT:  I think at least in Texas, I

 

  4   don't think we really cure these people of any of

 

  5   these things, and I think that moccasin type tinea,

 

  6   if someone has an immunologic defect where they

 

  7   just can't process and kill the T. rubrum, then, in

 

  8   your first slide of the person pulling the toes

 

  9   apart, the little piggies, you know, are too close.

 

 10             I think the mechanical trauma comes first,

 

 11   and then the tinea is secondary, so I think it

 

 12   behooves us to have some like education, you know,

 

 13   for the patients, because unless you can keep the

 

 14   air flowing with Thinsulate socks, spacers, drying

 

 15   agents, powders, changing shoes, wearing wooden

 

 16   shoe trees, you know, there are a million things

 

 17   that you can do, you will never cure these people

 

 18   with this interdigital tinea, never ever in your

 

 19   lifetime.

 

 20             Then, I think, the same way with this

 

 21   moccasin type tinea, I mean I think this stuff is

 

 22   in the environment, and these people are going to

 

                                                                42

 

  1   get it recurrently, because it seems like people

 

  2   come in during the summer and their fungus flares

 

  3   up, and during the winter, even if you don't treat

 

  4   them, these things tend to clear up.

 

  5             Now, I wanted to comment on this thing of

 

  6   whether we treat people more aggressively when they

 

  7   have problems. It's hard to treat patients who have

 

  8   diabetes or they have recurrent cellulitis.

 

  9   Usually, these people, it comes from the fourth and

 

 10   fifth toe web, you know, from this macerated

 

 11   interdigital tinea is the point of entry, and, yes,

 

 12   I do, I will sometimes treat these people

 

 13   systemically, but I think drying agents and good

 

 14   foot care is probably the most important thing.

 

 15             The same thing with the onychomycosis, you

 

 16   know, just simple things will help this, but I

 

 17   never tell anybody I am going to cure them.  I just

 

 18   say, listen, when this stuff comes back, you are

 

 19   just going to treat it again.

 

 20             DR. CANTILENA:  Dr. Wilkin.

 

 21             DR. WILKIN:  I would like to respond to

 

 22   Dr. Benowitz's question about after treatment, can

 

                                                                43

 

  1   you still get the dermatophytes, and there is a

 

  2   paper in the Journal of the American Academy of

 

  3   Dermatology, February 1995, Dr. Elewski is the

 

  4   first author, it's a multi-authored publication.

 

  5             Long-term outcome of patients with

 

  6   interdigital tinea pedis, treated with terbinafine

 

  7   or clotrimazole, and one of the points made is that

 

  8   even after successful treatment in the sense that

 

  9   the inflammatory signs and symptoms have gone away,

 

 10   one can still culture the organism.

 

 11             So, I think this is the experience that

 

 12   most dermatologists have, as well, and then I was

 

 13   going to add the part that Dr. Schmidt has already

 

 14   taken care of, you know, the dermatologist, I

 

 15   think, attacks the tropical environment inside the

 

 16   shoe, which is what keeps the fungus going.

 

 17             Also, sometimes the dermatophyte can

 

 18   actually survive on the inside surface of the shoe,

 

 19   so we know that some patients actually, eventually

 

 20   need to get a new pair of shoes, and there is a lot

 

 21   of weekly applications of topical products.

 

 22             Certainly, that is off label, but I know

 

                                                                44

 

  1   that that is done, a lot of drying powders, and,

 

  2   yes, there is a lot of attention, but I think in

 

  3   general the first approach is topical, but it is

 

  4   with a fairly comprehensive strategy for making it

 

  5   the wrong environment for the dermatophyte.

 

  6             DR. CANTILENA:  Thank you.  Thank you, Dr.

 

  7   Porres.

 

  8             Dr. Fritsch.

 

  9              Study Design and Efficacy Results for

 

 10             Tinea Pedis Clinical Trials (Rx and OTC)

 

 11             DR. FRITSCH:  Good morning.  I am Kathleen

 

 12   Fritsch.  I am a biostatistician with the Division

 

 13   of Biometrics III.  I will be presenting some more

 

 14   background information on the study design for

 

 15   tinea pedis clinical trials, and then I will be

 

 16   presenting some efficacy data from NDA submissions.

 

 17             [Slide.]

 

 18             First, I will be looking at the basic

 

 19   clinical trial design.

 

 20             [Slide.]

 

 21             Generally, these trials are randomized,

 

 22   double-blind, multicenter, vehicle-controlled

 

                                                                45

 

  1   trials.

 

  2             In the past, there generally have been two

 

  3   indications, the tinea pedis indication, the OTC

 

  4   equivalent of athlete's foot, and these trials will

 

  5   usually evaluate either all comers, with both the

 

  6   plantar and the interdigital variant, or study the

 

  7   subtypes individually, or if they focus their

 

  8   clinical trials primarily on the interdigital type,

 

  9   then, they get a more limited indication of

 

 10   athlete's foot between the toes or interdigital

 

 11   tinea pedis.

 

 12             Most of the development over the last

 

 13   decade has focused on the interdigital variant.

 

 14   Most of the products approved for the full

 

 15   indication were approved more than a decade ago.

 

 16             [Slide.]

 

 17             In terms of patients that are evaluated in

 

 18   these studies, for randomization into the trial and

 

 19   receiving treatment, you need a positive KOH and

 

 20   clinical signs and symptoms.

 

 21             In order to verify that tinea pedis is

 

 22   actually the diagnosis, in order to be analyzed for

 

                                                                46

 

  1   efficacy, usually, the patients are also required

 

  2   to have a positive baseline culture, however, since

 

  3   it can take up to four weeks to get the results of

 

  4   a culture, the treatment is often completed by the

 

  5   time those baseline culture results are known.

 

  6             However, the solution then is to just

 

  7   analyze for efficacy, what we call the modified

 

  8   intent to treat, or MITT population, those that

 

  9   have positive KOH, positive culture, and the

 

 10   appropriate clinical signs and symptoms.

 

 11             In most clinical trials, we will find that

 

 12   about two-thirds of the patients will end up having

 

 13   a positive baseline culture, and that can have an

 

 14   impact on choosing the sample size for a study.

 

 15             [Slide.]

 

 16             As Dr. Porres mentioned, there are three

 

 17   efficacy endpoints that are analyzed in these

 

 18   clinical trials that involve mycological and

 

 19   clinical outcomes.  They are nested within each

 

 20   other in that negative mycology is required for

 

 21   both effective treatment and complete cure.

 

 22             The effective treatment is getting to a

 

                                                                47

 

  1   mild state and also includes the patients that get

 

  2   to the complete cure state, and the complete cure

 

  3   state is the absence of the signs and symptoms.

 

  4             So, they are nested within each other.

 

  5             [Slide.]

 

  6             Again, to put up the specific definitions

 

  7   for these three endpoints, negative mycology, also

 

  8   referred to as mycological cure, is a negative KOH

 

  9   and culture.

 

 10             An effective treatment also requires the

 

 11   negative mycology and is some sort of a mild state

 

 12   of the disease, the clinical presentation.

 

 13   Generally, we say mild or no signs and no symptoms.

 

 14   From trial to trial, the specific definition for

 

 15   effective treatment does vary.

 

 16             Our recommendation these days is to define

 

 17   it as, at most, mild erythema and scaling, but in

 

 18   the past trials, there may be other ways to define

 

 19   a mild state that have been used.  Sometimes

 

 20   effective treatment is designated in the clinical

 

 21   trials as the primary endpoint.

 

 22             Of course, the strongest endpoint is the

 

                                                                48

 

  1   complete cure, which is the absence of signs and

 

  2   symptoms, negative mycology.  This is often the

 

  3   primary endpoint in the clinical trials, and the

 

  4   Agency generally recommends to use complete cure as

 

  5   the primary endpoint.

 

  6             Again, the signs and symptoms that are

 

  7   evaluated usually include erythema, pruritus, and

 

  8   scaling, and may include any of the other signs and

 

  9   symptoms, as well.

 

 10             [Slide.]

 

 11             For the study phases, there is usually a

 

 12   treatment period and a post-treatment follow-up

 

 13   period.

 

 14             Most products have a treatment duration

 

 15   between one and four weeks.  Then, the patients are

 

 16   followed for, at a minimum of at least two weeks

 

 17   after treatment.  The amount of follow-up will

 

 18   generally depend on the length of treatment.

 

 19             For a one-week product, the treatment

 

 20   period usually is at least five to eight weeks.  If

 

 21   the treatment is for four weeks, the follow-up

 

 22   period may be shorter, it may be only two to four

 

                                                                49

 

  1   weeks.  In both cases, this puts the patients at

 

  2   about six to nine weeks after they have started

 

  3   their treatment for when they will be primarily

 

  4   evaluated.

 

  5             [Slide.]

 

  6             Again, the reason for following patients

 

  7   into the post-treatment follow-up period is to

 

  8   allow for the epidermal turnover, as Dr. Porres

 

  9   mentioned, may take at least four weeks, so we may

 

 10   not expect the clearance of signs until some point

 

 11   after treatment has ended, say, at least six weeks

 

 12   after the start of treatment even if the fungus is

 

 13   eradicated earlier.

 

 14             Because of this, there may be a

 

 15   significant time lag in either weeks or possibly

 

 16   months between when treatment ends and when a cure

 

 17   could be assessed.

 

 18             [Slide.]

 

 19             The second part of my presentation will

 

 20   focus in on specific data that have been submitted

 

 21   to the Agency.  I will be presenting the efficacy

 

 22   results from selected clinical trials.

 

                                                                50

 

  1             [Slide.]

 

  2             The clinical trials that I have selected

 

  3   for my presentation come from NDA reviews.  The

 

  4   oldest one dates back to 1988, and all of the

 

  5   studies come from vehicle-controlled trials and

 

  6   were in general considered the pivotal trials for a

 

  7   particular drug product.

 

  8             Using these criteria, I have identified

 

  9   nine drug products.  They may involve different

 

 10   formulations or treatment regimens, and they

 

 11   represent six different active ingredients, so

 

 12   there are some multiple formulations and treatment

 

 13   regimens.

 

 14             The nine products are roughly split

 

 15   between those that are available OTC and by

 

 16   prescription, and also split between those that are

 

 17   recommended for one week's use and for four weeks'

 

 18   use.

 

 19             Of the nine, seven were designed for the

 

 20   indication of interdigital tinea pedis, and the two

 

 21   oldest ones have the indication for tinea pedis.

 

 22             [Slide.]

 

                                                                51

 

  1             To take a look at the size of the database

 

  2   that is available for each of these products, I

 

  3   will be presenting the products only by code letter

 

  4   A through I.

 

  5             We see that the products have a database

 

  6   of roughly about 50 patients on an active

 

  7   ingredient up to about 250, and in some cases, we

 

  8   have two trials that were two vehicle-controlled

 

  9   trials, and in some cases, we have one.  So, we do

 

 10   have a variety of sample sizes represented for our

 

 11   products here, so A through I.

 

 12             [Slide.]

 

 13             As I move into the displays of the actual

 

 14   data from these trials, I want to make a caveat

 

 15   that these data do not represent head-to-head

 

 16   comparisons of the products, therefore, we cannot

 

 17   make any direct comparisons of relative efficacy

 

 18   from one product to another.

 

 19             Success rates in these trials are greatly

 

 20   influenced by the particular patients that are

 

 21   enrolled in a trial, types of concomitant diseases

 

 22   they may have, whether they have onychomycosis, how

 

                                                                52

 

  1   severe the baseline clinical signs and symptoms

 

  2   must be could affect the success rates.

 

  3             The specific clinical study procedures,

 

  4   how the samples are collected, who analyzes the

 

  5   skin samples, whether a target lesion is analyzed,

 

  6   whether the whole foot is analyzed, all that can

 

  7   influence the success rate.

 

  8             As I mentioned before, the endpoints are

 

  9   identified differently in a trial, is it a global,

 

 10   is it specific symptoms, what symptoms are

 

 11   evaluated, all of that, how is missing data

 

 12   handled, all that can influence the success rates.

 

 13             So, we will look at this in terms of

 

 14   trying to pick up general trends and patterns that

 

 15   we can.

 

 16             [Slide.]

 

 17             I have got data on the negative mycology,

 

 18   effective treatment, and complete cure rates for

 

 19   the nine products, so we will present those next.

 

 20             [Slide.]

 

 21             This first graph represents the negative

 

 22   mycology.  These are the negative mycology rates at

 

                                                                53

 

  1   end of treatment, so Week 1 for the one-week

 

  2   products, and Week 4 for the four-week products.

 

  3             The orange bars represent the active.  We

 

  4   can see what kind of eradication we can expect to

 

  5   find for a one-week treatment.  For a one-week

 

  6   treatment, we can see that, for the most part,

 

  7   about 40 to 50 percent of patients will have

 

  8   negative KOH and negative culture by the end of

 

  9   treatment.

 

 10             For the products that are used for four

 

 11   weeks, the negative mycology rate is somewhat

 

 12   higher at Week 4, about 60 to 70 percent of

 

 13   patients will have the negative mycology at the end

 

 14   of treatment.

 

 15             [Slide.]

 

 16             If we go to the primary timepoint that was

 

 17   specified in each particular protocol for the time

 

 18   of assessment, usually, Week 6, 8, or 9, we see

 

 19   that, in general, at this timepoint, patients can

 

 20   get to about 60, 70, or 80 percent negative

 

 21   mycology rates by the primary timepoint for

 

 22   evaluation, so that is about what we can expect for

 

                                                                54

 

  1   getting rid of the dermatophyte, and it is fairly

 

  2   consistent across the products here.

 

  3             Again, the endpoints that involve the

 

  4   clinical signs and symptoms are based on these

 

  5   patients that achieve negative mycology only.

 

  6             [Slide.]

 

  7             In terms of effective treatment, this will

 

  8   be getting negative KOH in culture and getting down

 

  9   to some sort of a mild state of disease.

 

 10             We see that for Week 1, only a relatively

 

 11   small proportion of patients are actually able to

 

 12   get to the mild state by the time they are finished

 

 13   with their treatment regimen, about 2 percent to 18

 

 14   percent of patients.  So, the remaining subjects

 

 15   would have some sort of symptoms beyond just mild

 

 16   erythema and mild scaling remaining by the end of

 

 17   treatment.

 

 18             At four weeks, where they have had a

 

 19   longer time to wait before they stop their

 

 20   treatment, roughly around half of the patients are

 

 21   able to get to a mild state of disease, and the

 

 22   remaining half would still have more severe signs

 

                                                                55

 

  1   and symptoms remaining.

 

  2             So, that is what a patient may be able to

 

  3   expect to see by the time they are finished with

 

  4   their treatment.

 

  5             [Slide.]

 

  6             By the time we get out to the Week 6 to 9,

 

  7   where the skin may have had a chance to turn over a

 

  8   little bit, we see again about 40, 50, 60 percent

 

  9   of patients will be able to get to the mild state

 

 10   with the negative mycology, and the remaining

 

 11   subjects would have more symptoms remaining.

 

 12             [Slide.]

 

 13             Finally, the gold standard of complete

 

 14   cure where we can completely eradicate these signs

 

 15   and symptoms, as well as the dermatophyte, for one

 

 16   week treatment, as may be expected because of the

 

 17   time for skin turnover, very few patients will be

 

 18   actually completely clear of their signs and

 

 19   symptoms.

 

 20             Almost everybody has some signs or

 

 21   symptoms remaining or dermatophyte remaining by the

 

 22   end of one week of treatment.  Even for those that

 

                                                                56

 

  1   continue to four weeks, roughly, 15 percent of

 

  2   patients are able to get completely rid of their

 

  3   signs and symptoms, and the remainder will have at

 

  4   least something remaining even at the end of four

 

  5   weeks of treatment.

 

  6             [Slide.]

 

  7             To go out to the primary timepoint, again

 

  8   we see about the same value across the board.

 

  9   About 20 percent, maybe 30 percent in some cases,

 

 10   of patients are able to completely get rid of their

 

 11   signs and symptoms six to nine weeks after starting

 

 12   treatment, which is about two to four weeks after

 

 13   treatment for the four-week treatments and five to

 

 14   eight weeks after treatment for the one-week

 

 15   treatments.

 

 16             [Slide.]

 

 17             Next, I will go into some specific tables

 

 18   for the specific signs and symptoms, and I will

 

 19   present this information by visit.  The visits that

 

 20   are evaluated in a particular clinical trial depend

 

 21   on the design.

 

 22             I will be presenting data for erythema,

 

                                                                57

 

  1   scaling, and pruritus, and for this presentation,

 

  2   since signs and symptoms have not been collected in

 

  3   the same way in all trials, I have the data

 

  4   available in the format I want for only two

 

  5   products, a one-week product and a four-week

 

  6   product.

 

  7             [Slide.]

 

  8             We start with erythema.  This will be the

 

  9   percentage of subjects that will be clear of their

 

 10   erythema at a particular visit.  On the left, Drug

 

 11   Product D is a one-week treatment, and Drug Product

 

 12   F is a four-week treatment.

 

 13             If we take a look at the percentage of

 

 14   subjects, in this case, we started off with about

 

 15   15 percent of subjects were clear of their erythema

 

 16   at baseline in this trial.  After one week of

 

 17   treatment, that number improved to about 25

 

 18   percent, and then as we go out in time to the time

 

 19   we may expect to see the skin turnover, by Week 4

 

 20   to 6, we are getting up to about 50 percent.

 

 21             This trial went out to 12 weeks, and by

 

 22   that point, we have about 50 to 60 percent of

 

                                                                58

 

  1   patients clear of their erythema by the end of the

 

  2   trial, compared to about 30 percent on vehicle.

 

  3             A similar pattern for this four-week

 

  4   treatment.  It takes a while for the number of

 

  5   patients to get clear of their erythema.  By about

 

  6   Week 4, again we are about 45 percent, 50 percent

 

  7   of patients.  So, we can see kind of the time

 

  8   trajectory of how many weeks it takes to start to

 

  9   see clearance of the erythema.

 

 10             [Slide.]

 

 11             Scaling.  In this case, all of the

 

 12   subjects that have scaling at baseline, and we see

 

 13   that for the one-week treatment, if we look at the

 

 14   number of patients that are clear of their scaling,

 

 15   about 2 percent of patients were clear of scaling

 

 16   by the end of treatment.  Again, not too surprising

 

 17   based on the length of epidermal turnover.

 

 18             By four weeks, we are up to a little over

 

 19   10 percent, and we max out at about 25 percent.

 

 20   So, this may be the rate-limiting factor for why we

 

 21   see little complete clearance is scaling is

 

 22   persistent in the vast majority of patients.

 

                                                                59

 

  1             Similarly, over here, by about Week 4, we

 

  2   are up to 20 percent, maxing out at about 30

 

  3   percent of patients able to completely clear of

 

  4   their scaling.

 

  5             [Slide.]

 

  6             Finally, for pruritus, we will see that on

 

  7   this drug, for the one-week treatment, we do

 

  8   actually see a substantial bump from baseline to

 

  9   the end of treatment at Week 1, go from about 15

 

 10   percent with no pruritus at baseline to about 45

 

 11   percent by the end of treatment.

 

 12             Again, we do see continued improvement for

 

 13   this product after treatment has ended, getting up

 

 14   to about 75 percent of patients by Week 9 who are

 

 15   clear of their pruritus, and the vehicle rate drops

 

 16   off, although interestingly, during the one week of

 

 17   treatment, the active and the vehicle have the same

 

 18   benefit in terms of pruritus, however, the active

 

 19   patients do continue to improve.

 

 20             Similarly, for Drug Product F, we see

 

 21   continued improvement on the pruritus, in this case

 

 22   during the course of treatment, maxing out at about

 

                                                                60

 

  1   70 percent again for the number of patients clear

 

  2   of their pruritus.

 

  3             Again, also substantial vehicle benefit,

 

  4   however, the vehicle rate does drop off after

 

  5   treatment.

 

  6             [Slide.]

 

  7             The summary of the efficacy results.  From

 

  8   this data, we can see that there is a time lag of

 

  9   several weeks between the end of treatment and when

 

 10   the signs and symptoms may be cleared, particularly

 

 11   for the one-week products where the treatment is

 

 12   stopped before the epidermal turnover can take

 

 13   place.

 

 14             In most cases, patients will have signs

 

 15   and symptoms remaining into the post-treatment

 

 16   period, and rough ballpark figures of the typical

 

 17   cure rates for the various endpoints, complete cure

 

 18   rates are roughly 20, maybe 30 percent for most

 

 19   products.

 

 20             Effective treatment may be about half of

 

 21   the patients.  Negative mycology rates, around

 

 22   two-thirds to three-fourths of the patients will be

 

                                                                61

 

  1   able to get to the negative mycology in the

 

  2   post-treatment period.

 

  3             Thank you.

 

  4             DR. CANTILENA:  Thank you, Dr. Fritsch.

 

  5             We have time for a couple of questions for

 

  6   Dr. Fritsch.

 

  7             Dr. Benowitz.

 

  8             DR. BENOWITZ:  I am just curious.  What is

 

  9   the basis for someone doing a one-week trial versus

 

 10   a four-week trial, are the products different, why

 

 11   is that done?

 

 12             DR. FRITSCH:  Basically, it is the

 

 13   sponsor's preference.  If they want to market a

 

 14   one-week product and they think they can get the

 

 15   efficacy that they want in one week.  We have not

 

 16   seen very much data that compares a product across

 

 17   multiple durations.

 

 18             That is one of the reasons we have been

 

 19   asking for dose ranging.  It is usually we either

 

 20   get results for one week, or we get results for

 

 21   four weeks.  We have not seen much comparative

 

 22   data, but generally, it is the sponsor's decision

 

                                                                62

 

  1   on what type of product they would like to market.

 

  2             DR. BENOWITZ:  So, if we looked at the

 

  3   products, they would basically be the same in both

 

  4   groups in terms of active ingredients?

 

  5             DR. FRITSCH:  In terms of for the data

 

  6   presentation I made, there is six different active

 

  7   ingredients that were represented.

 

  8             DR. BENOWITZ:  I understand.  I am just

 

  9   saying that if you look at drugs that were selected

 

 10   for a one-week trial versus a four-week trial, they

 

 11   are basically the same medications in both, same

 

 12   active ingredients?

 

 13             DR. FRITSCH:  There is only one case where

 

 14   we have data both on a one-week use and a four-week

 

 15   use.  Otherwise, the products that are one week are

 

 16   different than the products that are four weeks.

 

 17             DR. BENOWITZ:  I understand that the

 

 18   specific product name is different, but in terms of

 

 19   the active ingredients.

 

 20             DR. FRITSCH:  The active ingredients, yes.

 

 21             DR. BENOWITZ:  Are they also generally

 

 22   different or are they basically the same?

 

                                                                63

 

  1             DR. FRITSCH:  Generally, they are

 

  2   different.  There is one product that is

 

  3   recommended for use for either one week or four

 

  4   weeks, and then there are products that are only

 

  5   recommended for one week, and there are products

 

  6   that are only recommended for four weeks.

 

  7             So, generally, the one-week products are

 

  8   different from the four-week products in terms of

 

  9   active ingredients.

 

 10             DR. BENOWITZ:  Thanks.

 

 11             DR. CANTILENA:  Ms. Knudson.

 

 12             MS. KNUDSON:  I want to know, on these

 

 13   studies that you have just presented, do you have

 

 14   any idea how many patients dropped out of the

 

 15   studies and at what timepoints did they drop out?

 

 16             DR. FRITSCH:  Yes, that is generally

 

 17   included.  For the most part, roughly, in maybe a

 

 18   six-week trial, there might be about 10 to 15

 

 19   percent of patients that drop out. One of the

 

 20   difficulties with the data I have presented, our

 

 21   current standards would be to generally either

 

 22   count the patients that drop out as either failures

 

                                                                64

 

  1   or last observation carried forward.

 

  2             For the older trials, often the results

 

  3   that I have presented exclude the dropouts.  I did

 

  4   not go back and try and correct for intent to treat

 

  5   the way that the older trials did, so that is one

 

  6   variability, that the older trials often ignored

 

  7   dropouts.  Recently, we definitely count them in

 

  8   our results.

 

  9             DR. CANTILENA:  Thank you.

 

 10             Dr. Ringel.

 

 11             DR. RINGEL:  I have a question about

 

 12   negative mycology.  I was wondering if that is

 

 13   considered negative KOH and culture or only

 

 14   negative culture.

 

 15             The reason I am asking is that most

 

 16   physicians consider culture in other areas of

 

 17   mycobiology to be a gold standard, whereas, as with

 

 18   dermatophytes, there are various reasons why a

 

 19   culture might be negative, where the KOH would be

 

 20   positive, either bacterial contamination, sampling

 

 21   error, the patient has been using topical

 

 22   antifungals.

 

                                                                65

 

  1             So, I guess the question is if a KOH is

 

  2   positive, a culture is negative, is that considered

 

  3   positive mycology or negative mycology?

 

  4             DR. FRITSCH:  You must have both negative

 

  5   KOH and negative culture to be counted as negative

 

  6   mycology.

 

  7             DR. RINGEL:  Thank you.

 

  8             DR. CANTILENA:  Thank you.  Now we have

 

  9   Mr. Kresel.

 

 10             MR. KRESEL:  My question was answered

 

 11   earlier.

 

 12             DR. CANTILENA:  Dr. Epps.

 

 13             DR. EPPS:  Partially, my question was

 

 14   addressed with the positive KOH, negative mycology,

 

 15   but how much within your group was just positive

 

 16   KOH and negative culture?  Do you have any data

 

 17   regarding that?

 

 18             DR. FRITSCH:  Yes, the positive KOH and

 

 19   negative culture, I have seen a few.  There is

 

 20   definitely some that come through with positive KOH

 

 21   and negative culture.

 

 22             DR. EPPS:  Because it may be that this is

 

                                                                66

 

  1   not viable, but present--

 

  2             DR. FRITSCH:  There is lots of problems

 

  3   with the four-week, you know, a negative culture,

 

  4   did you have the fungus in the plate or not, that

 

  5   is definitely a problem, so there are definitely

 

  6   some that do come through.

 

  7             DR. CANTILENA:  Thank you.

 

  8             Dr. Lam.

 

  9             DR. LAM:  I just want to clarify just to

 

 10   make sure.  The data that you present only

 

 11   represent one strength of each of the products.

 

 12             DR. FRITSCH:  One strength of each

 

 13   product, yes.

 

 14             DR. CANTILENA:  Thank you.  Any other

 

 15   questions from the committee?  Dr. Wood.

 

 16             DR. WOOD:  The elephant in the room here

 

 17   is what the efficacy is with systemic therapy, as

 

 18   well.  Is somebody going to talk about that?

 

 19             I realize we are here to consider topical

 

 20   therapy, but as we get to some of these questions,

 

 21   my feelings about them would be substantially

 

 22   influenced by knowing what we are going to accept

 

                                                                67

 

  1   as the expected efficacy rate from systemic

 

  2   therapy.

 

  3             Clearly, given the efficacy rate shown

 

  4   here, and consumers' views of that will be

 

  5   different if there is effective therapy out there

 

  6   that is of an order of magnitude different.

 

  7             So, is someone going to, for the record,

 

  8   show us that, an efficacy rate from terbinafine

 

  9   systemically?

 

 10             DR. CANTILENA:  Dr. Ganley, do you have

 

 11   anyone?  If you have to look that up, we can

 

 12   certainly have that after lunch.  So, why don't we

 

 13   have someone be checking on that.  That is a good

 

 14   point.

 

 15             Our next speaker from FDA, Dr. Mahayni.

 

 16               History and Overview of OTC Topical

 

 17                Antifungal Drug Products Monograph

 

 18             DR. MAHAYNI:  Good morning, ladies and

 

 19   gentlemen. My name is Houda Mahayni.  I am

 

 20   interdisciplinary scientist in the Division of

 

 21   Over-the-Counter Drug Products.

 

 22             [Slide.]

 

                                                                68

 

  1             I will give you a brief introduction about

 

  2   the mechanism by which OTC drugs are regulated.

 

  3   Then, I will describe an overview of the OTC Drug

 

  4   Monograph System. Finally, I will discuss the OTC

 

  5   drug monograph for topical antifungals with special

 

  6   emphasis on those ingredients used to treat

 

  7   athlete's foot tinea pedis.

 

  8             [Slide.]

 

  9             Most of you are familiar with the NDA

 

 10   process, so in order to introduce the monograph

 

 11   system, I am going to briefly contrast the two

 

 12   mechanisms by which OTC drug products are

 

 13   regulated, highlighting the key differences between

 

 14   the two mechanisms.

 

 15             NDA is drug product-specific.  It requires

 

 16   pre-market approval, and information submitted

 

 17   under the NDA is confidential, whereas, in the OTC

 

 18   drug monograph, is an active ingredient-specific,

 

 19   and ingredients are designate as GRASE, which is

 

 20   generally recognized as safe and effective. There

 

 21   is no need for pre-market approval.  Finally, the

 

 22   information is public.

 

                                                                69

 

  1             [Slide.]

 

  2             I hope this introduction gives you a

 

  3   flavor of how the two mechanisms differ.  I will

 

  4   not be talking about the NDA mechanism in this

 

  5   talk, but I will focus for the rest of this talk on

 

  6   the OTC Drug Monograph System.

 

  7             [Slide.]

 

  8             The OTC drug review began in 1972 as a

 

  9   review of the safety and effectiveness of OTC drugs

 

 10   on the market at that time.  FDA initiated the OTC

 

 11   drug review by identifying a number of therapeutic

 

 12   categories for which FDA is to establish OTC drug

 

 13   monographs.

 

 14             OTC drug monographs list the conditions of

 

 15   use that are generally recognized as safe and

 

 16   effective or GRASE, and on the next slide I will be

 

 17   talking to you about what is meant by the condition

 

 18   of use.

 

 19             [Slide.]

 

 20             What is really included in the monograph

 

 21   system is the conditions of use, and those include

 

 22   the active ingredients, whether it's single

 

                                                                70

 

  1   ingredient or combination, dosage strength, dosage

 

  2   form, labeling requirements, such as uses,

 

  3   directions, and warnings, and finally, in some

 

  4   cases, final formulation testing.

 

  5             [Slide.]

 

  6             The OTC drug review is a four-step public

 

  7   rulemaking process, and each step builds upon the

 

  8   other.  Here, I will be listing all the four steps

 

  9   and I will go over these steps in more detail in

 

 10   subsequent slides.

 

 11             First, the advisory review panel meets.

 

 12   Then, after the panel meets, the FDA publishes the

 

 13   Advance Notice of Proposed Rulemaking, which is

 

 14   generally referred to as the ANPR.

 

 15             Next, FDA publishes the tentative final

 

 16   monograph, or TFM, and finally, the FDA publishes

 

 17   the final rule, or FM.

 

 18             [Slide.]

 

 19             The panel is a group of experts in a

 

 20   particular OTC drug category.  The panel was

 

 21   charged with reviewing the data of OTC ingredients

 

 22   marketed prior to 1975 and assessing whether these

 

                                                                71

 

  1   ingredients are safe and effective for GRASE

 

  2   conditions for the OTC drug monograph.

 

  3             The panel give the nomenclature Category I

 

  4   for ingredients, all conditions under which

 

  5   products are generally recognized as safe and

 

  6   effective, and are not misbranded.

 

  7             Category II are for ingredients or

 

  8   conditions under which products are generally

 

  9   recognized not as safe and effective or are

 

 10   misbranded.

 

 11             Category III are for ingredients or

 

 12   conditions when the available data are insufficient

 

 13   to permit final classification at the time.

 

 14             Keep in mind that these classifications

 

 15   are not only given for ingredients, but for

 

 16   condition of use as defined earlier, which includes

 

 17   labeling requirements and final formulation

 

 18   testing.

 

 19             [Slide.]

 

 20             Next, the FDA publishes the Advance Notice

 

 21   of Proposed Rule, or ANPR, in the Federal Register

 

 22   to announce its intention of creating the OTC drug

 

                                                                72

 

  1   monograph.  The ANPR also contains the panel

 

  2   report, which lists recommended GRASE conditions.

 

  3             Then, following the publication of the

 

  4   ANPR, interested persons may submit comments or

 

  5   additional data to the panel, and they are given 90

 

  6   days to make those comments in.

 

  7             [Slide.]

 

  8             FDA next publishes the tentative final

 

  9   monograph, or TFM, in the Federal Register as its

 

 10   preliminary position regarding the safety and

 

 11   effectiveness of each active ingredient in

 

 12   particular category.

 

 13             The TFM is based on FDA interpretation of

 

 14   data provided by the panel, the panel

 

 15   recommendations, and any new data submitted in

 

 16   response to the Advance Notice of Proposed Rule.

 

 17             Following its publication, there is also

 

 18   an additional 90 days comment period for interested

 

 19   persons who may want to submit comments and

 

 20   additional data on what was contained in the TFM.

 

 21             [Slide.]

 

 22             FDA reviews all comments and data

 

                                                                73

 

  1   submitted during the tentative final monograph

 

  2   comment period and amends the TFM to create the

 

  3   final monograph or final rule. The monograph is a

 

  4   set of rules published in the Federal Register.

 

  5             The regulation gets published in the Code

 

  6   of Federal Regulations.  That includes an effective

 

  7   date after which any product marketed under the

 

  8   monograph must comply with the conditions used that

 

  9   were described in the monograph.

 

 10             As I said, each step in the monograph

 

 11   builds upon and is a continuation of the previous

 

 12   step.  Although the FM is the final step in the OTC

 

 13   Drug Monograph System, FDA can amend the final

 

 14   monograph to include additional GRASE conditions,

 

 15   such as adding new active ingredients.

 

 16             [Slide.]

 

 17             Now that I gave you a general overview of

 

 18   the OTC Drug Monograph System, I am going to shift

 

 19   and talk specifically about the history of OTC

 

 20   topical antifungal monograph with special emphasis

 

 21   on those ingredients used to treat athlete's foot

 

 22   tinea pedis.

 

                                                                74

 

  1             [Slide.]

 

  2             The panel met in the late seventies and

 

  3   early eighties, and then FDA published the Advance

 

  4   Notice of Proposed Rulemaking in 1982.

 

  5             The panel expressed its concern about the

 

  6   ingredients only mitigating symptoms rather than

 

  7   curing condition as is apparent by the statement

 

  8   that in order to best serve the consumers, an OTC

 

  9   product must provide more than temporary

 

 10   symptomatic relief of athlete's foot, jock itch,

 

 11   and ringworm.

 

 12             The panel required at least one

 

 13   well-designed clinical study demonstrating an

 

 14   active ingredient treat athlete's foot as evidence

 

 15   of effectiveness, and it recommended an ingredient

 

 16   as GRASE if it was significantly more effective

 

 17   than vehicle.

 

 18             [Slide.]

 

 19             In reviewing the clinical trial, the panel

 

 20   defined a well-controlled study as one that met the

 

 21   following criteria:  To be double-blinded and

 

 22   randomized, vehicle-controlled, test groups of

 

                                                                75

 

  1   adequate size, entry criteria based on clinical

 

  2   signs and symptoms with diagnosis verified by

 

  3   positive KOH and culture, and standardized dosing

 

  4   regimen usually four weeks treatment for athlete's

 

  5   foot, and finally, the follow-up examinations

 

  6   performed at the end of treatment and final

 

  7   evaluation of clinical results corroborated by

 

  8   negative KOH and negative culture two weeks after

 

  9   treatment ends.

 

 10             A relatively small percentage of the

 

 11   studies submitted to NDA met these criteria.

 

 12             [Slide.]

 

 13             The panel reviewed approximately 50

 

 14   clinical studies along with in vitro and animal

 

 15   studies to assess the safety and effectiveness of

 

 16   about 35 active ingredients.

 

 17             Of these clinical studies, roughly 10 were

 

 18   designed to demonstrate the effectiveness of active

 

 19   ingredients in treating athlete's foot, but most

 

 20   were poorly designed.  This was because there was

 

 21   considerable variability in the study protocol.

 

 22             Enrollment for most studies was based on

 

                                                                76

 

  1   the diagnosis of tinea pedis by a physician instead

 

  2   of these studies, this diagnosis was confirmed by

 

  3   positive KOH and positive culture.

 

  4             Treatment duration varied between two to

 

  5   six weeks with treatment duration being four weeks

 

  6   in most studies.

 

  7             These studies assessed the efficacy at

 

  8   different timepoints and used different criteria

 

  9   for cure.

 

 10             All these factors make it difficult to

 

 11   compare the cure rates of the monograph products to

 

 12   those of the NDA products.  Based on this review of

 

 13   the study, the panel recommended that six active

 

 14   ingredients be classified as GRASE, and I will

 

 15   share with you these ingredients in the slide

 

 16   talking about the final monograph.

 

 17             [Slide.]

 

 18             In addition, the panel proposed the idea

 

 19   of simple and concise labeling that should enable

 

 20   the consumers to clearly understand the results

 

 21   that can be anticipated from the use of the

 

 22   product.

 

                                                                77

 

  1             Example of indication recommended by the

 

  2   panel includes treat athlete's foot for the

 

  3   treatment of athlete's foot or for the relief of

 

  4   itching.

 

  5             Labeling or products used for the

 

  6   treatment of athlete's foot should include the

 

  7   following warning:  If irritation occurs or of

 

  8   there is no improvement within four weeks,

 

  9   discontinue use and consult a doctor or pharmacist.

 

 10             Furthermore, the panel stated that

 

 11   directions should be clear and direct.  They should

 

 12   provide the user with sufficient information to

 

 13   enable safe and effective use of the product.

 

 14             Based on the clinical study, which

 

 15   generally involved four weeks' treatment, the panel

 

 16   determined that OTC topical antifungals should be

 

 17   applied twice a day for four weeks to be most

 

 18   effective.

 

 19             [Slide.]

 

 20             Seven years later, after the NPR was

 

 21   published, the Agency published the TFM.  In the

 

 22   TFM, FDA reviewed 25 clinical studies.  Those

 

                                                                78

 

  1   studies were submitted following the publication of

 

  2   the ANPR or Advance Notice of Proposed Rule.

 

  3             Six of these 25 studies addressed

 

  4   athlete's foot. Based on these studies, FDA agreed

 

  5   with the panel recommendation in terms of

 

  6   ingredients to be included in the monograph with

 

  7   the exception of two active ingredients, nystatin

 

  8   was classified as not GRASE, and they decided to

 

  9   include povidone and iodine as GRASE.

 

 10             [Slide.]

 

 11             After the TFM was published, FDA published

 

 12   the FM, the final monograph four years later.  In

 

 13   the final monograph, FDA reviewed about 10 studies

 

 14   submitted after the tentative final monograph and

 

 15   found the following active ingredients as GRASE for

 

 16   the treatment of athlete's foot.

 

 17             FDA found all other ingredients considered

 

 18   in this rulemaking not to be GRASE for us in OTC

 

 19   topical antifungals.  In addition, the final

 

 20   monograph includes labeling similar to that

 

 21   recommended by the panel in the Advance Notice of

 

 22   Proposed Rule.

 

                                                                79

 

  1             All of the active ingredients listed here,

 

  2   they were indicated for the treatment of athlete's

 

  3   foot, as well as for the relief of symptoms.  Only

 

  4   one product tolnaftate was also indicated for the

 

  5   prevention of athlete's foot.  In addition, all

 

  6   these active ingredients were also indicated for

 

  7   the treatment of ringworm, tinea corporis, and jock

 

  8   itch, tinea cruris.

 

  9             [Slide.]

 

 10             As I told you, final monograph can be

 

 11   amended following its publication.  FDA published a

 

 12   proposed amendment and subsequently, a final rule

 

 13   in August 2000 to modify the labeling of OTC

 

 14   topical antifungal.

 

 15             This amendment added the word "most" to

 

 16   the indication statement between the introductory

 

 17   phrase and the name of the condition for which the

 

 18   product was to be used, for instance, cures "most"

 

 19   athlete's foot.

 

 20             FDA recognized that OTC topical

 

 21   antifungals do not cure or treat all conditions

 

 22   commonly thought by consumers to be athlete's foot

 

                                                                80

 

  1   or jock itch.

 

  2             FDA also noted that varying percentages of

 

  3   subjects were clinically and mycologically cured of

 

  4   athlete's foot infection, therefore, inserting the

 

  5   word "most" in this case would give and help the

 

  6   consumers know what to expect from these products.

 

  7             This is important since consumers

 

  8   self-select OTC topical antifungals, and do not

 

  9   diagnose.  The Agency believed that this labeling

 

 10   should more accurately inform the consumers what to

 

 11   expect from using these products.

 

 12             Also, FDA pointed out that this amended

 

 13   label is consistent with the current labeling

 

 14   approved for OTC vaginal antifungal drug products

 

 15   marketed under NDA.  Since these are also topical

 

 16   antifungals with different sites of administration

 

 17   and for consistency, OTC labeling for this

 

 18   particular class should be the same.

 

 19             In addition to this amendment, in February

 

 20   2002, after reviewing approximately eight clinical

 

 21   studies submitted after the FM, FDA proposed to add

 

 22   clotrimazole as GRASE active ingredients for the

 

                                                                81

 

  1   treatment of athlete's foot, jock itch, and

 

  2   ringworm.

 

  3             [Slide.]

 

  4             In summary, OTC drug monographs allow

 

  5   determination of safety and effectiveness of an

 

  6   entire therapeutic drug class.

 

  7             OTC topical antifungal monograph lists

 

  8   GRASE active ingredients and labeling for OTC drug

 

  9   products that treat athlete's foot, jock itch, and

 

 10   ringworm, as well as prevent athlete's foot,

 

 11   because ingredients found GRASE for one condition

 

 12   is given the same GRASE classification for other

 

 13   conditions because of the similarity of these

 

 14   conditions.

 

 15             From the data submitted the monographs, it

 

 16   is difficult to directly compare the cure rates for

 

 17   monograph and NDA drug products that treat

 

 18   athlete's foot because they were not directly

 

 19   comparable due to considerable variability in the

 

 20   study protocol.

 

 21             Finally, by including the word "most" in

 

 22   the indication, we can say to consumers what to

 

                                                                82

 

  1   expect from using these products and what to expect

 

  2   from them.

 

  3             Thank you.

 

  4             DR. CANTILENA:  Thank you, Dr. Mahayni.

 

  5             I guess we should ask that all depends

 

  6   what you mean by "most," but we will actually talk

 

  7   about that this afternoon.

 

  8             Questions from the committee?  Dr. Wood.

 

  9             DR. WOOD:  Well, that was going to be my

 

 10   question. "Most" certainly means, as you said, it

 

 11   is the last thing, it helps the consumer.

 

 12             If I look at the slides in the last talk,

 

 13   on page 10, which of these studies support "most"

 

 14   in your view?  On the Slide 19 on page 10, you

 

 15   added the word "most" because you felt that

 

 16   reflected the data.

 

 17             Which of the studies specifically on Slide

 

 18   19 do you think tell you that, or would tell me

 

 19   that?

 

 20             DR. MAHAYNI:  Actually, the word "most"

 

 21   was added because at the time, there was not a

 

 22   specific study, but because of the lower percentage

 

                                                                83

 

  1   of cure rate for these ingredients, the word "most"

 

  2   was added to the monograph to indicate to consumers

 

  3   that it is not going to treat every clinical

 

  4   condition that will be presented.

 

  5             DR. WOOD:  Right, but "most" implies at

 

  6   least more than 50 percent, and most people I think

 

  7   would assume that it was closer to 100 than 50

 

  8   percent.  I don't think any interpretation of

 

  9   "most" implies less than 50 percent, does it?  I

 

 10   mean is there a definition that you are aware of

 

 11   that implies that most people do something, implies

 

 12   less than 50 percent?

 

 13             DR. CANTILENA:  How about if we have

 

 14   actually Dr. Ganley answer the question, since he

 

 15   probably had more to do with that than Dr. Mahayni.

 

 16             DR. GANLEY:  This whole process started

 

 17   before I got to D.C., but I am generally

 

 18   accountable for it.

 

 19             DR. CANTILENA:  All right, there is the

 

 20   copout, so now you can answer.

 

 21             DR. GANLEY:  No, I accept responsibility

 

 22   for it.

 

                                                                84

 

  1             I guess at the time, it is a rather

 

  2   complicated thing, is that it will treat most

 

  3   dermatophytes.  Also, the thinking was that if you

 

  4   put just cures there without some qualifier, that

 

  5   people think that it is closer to 100 percent cure.

 

  6             Now, "most" may not have been the

 

  7   appropriate adjective and maybe some other

 

  8   qualifying term, but I think that is one of the

 

  9   issues that we need to discuss, whether that really

 

 10   was a good idea and whether we need to revise the

 

 11   language a little bit.  It gets back to how you

 

 12   convey information to the consumer as what their

 

 13   expectation can be, but I think I would acknowledge

 

 14   that it actually didn't accomplish what I think the

 

 15   original intent of the Agency was in that, to give

 

 16   some perception that it's not 100 percent cure,

 

 17   that it is something less than that.

 

 18             I think if you look at the data for

 

 19   effective treatment and cures most, people will

 

 20   argue that effective treatment is a reasonable

 

 21   level of success also, and that generally is above

 

 22   50 percent, so I mean you can discuss that today

 

                                                                85

 

  1   and the logic, but I would acknowledge that it

 

  2   didn't solve the situation at all.

 

  3             DR. WOOD:  I guess there are two issues,

 

  4   does it cure and is it most, and I am thinking of

 

  5   this in terms of the treatment of heart failure.

 

  6   You know, it is perfectly legitimate to have a

 

  7   treatment for heart failure that is effective in

 

  8   most patients, but we probably wouldn't allow

 

  9   labeling that said it cured most patients, or HIV,

 

 10   or whatever it was we were treating.

 

 11             I mean I think it is the juxtaposition of

 

 12   both that we need to be discussing.

 

 13             DR. GANLEY:  I think the difference I

 

 14   would argue there is that in heart failure, you are

 

 15   not going to cure the underlying condition, you are

 

 16   going to treat the symptoms and improve their

 

 17   survival potentially, you don't cure them of the

 

 18   disease, but infectious disease, you can cure

 

 19   people's disease, and that is where the difference

 

 20   is.

 

 21             So, it does get a little tricky in how you

 

 22   are going to convey that information to the

 

                                                                86

 

  1   consumer and what their expectation may be.

 

  2             DR. WOOD:  That is why I think it is

 

  3   important to have in the discussion, what the

 

  4   efficacy is for systemic therapy, because I think

 

  5   that was exactly my point earlier, where there is

 

  6   alternative therapy available that may have a very

 

  7   different efficacy rate, it is important then to

 

  8   revisit this to make sure that this provides some

 

  9   information that is at least contemporaneous for

 

 10   what the other therapies can do.

 

 11             DR. CANTILENA:  That is a very good point.

 

 12   We will have an opportunity this afternoon to

 

 13   discuss that further.

 

 14             Dr. Lam.

 

 15             DR. LAM:  For the product to be classified

 

 16   as Category I, what type of cure are we talking

 

 17   about, are we talking about mycology cure or

 

 18   complete cure?

 

 19             DR. MAHAYNI:  No, Category I does not

 

 20   relate to actually cure, because most of these

 

 21   studies did not define the complete cure.  The

 

 22   category is really reflected on what the

 

                                                                87

 

  1   ingredients, Category I is ingredients that are

 

  2   seen as safe and effective, or generally recognized

 

  3   as safe and effective, and not misbranded.

 

  4             But as far as cure rate, there were a

 

  5   variety of studies that had a different way of

 

  6   qualifying what is cure rate, and no way to compare

 

  7   them or say what is the cutoff rate for that.

 

  8             DR. HOLEMAN:  Matthew Holeman.  If I could

 

  9   just sort of clarify real quick.

 

 10             DR. CANTILENA:  Okay.

 

 11             DR. HOLEMAN:  Basically, remember that

 

 12   most of the studies that these were based on were

 

 13   submitted to the Agency in the seventies, the late

 

 14   seventies, so the standards there were very

 

 15   different than our standards today.

 

 16             So, as Houda pointed out in her talk

 

 17   today, there was a great variability in how these

 

 18   studies were designed, and some of these studies, I

 

 19   think the majority looked at just mycological

 

 20   cures.  Some of them did include some clinical

 

 21   cure.

 

 22             I don't know that any actually looked at

 

                                                                88

 

  1   complete clinical cure, most of them were probably

 

  2   mycological, but it is really hard.  There is a lot

 

  3   of variability in all these studies.

 

  4             DR. CANTILENA:  Dr. Fincham.

 

  5             DR. FINCHAM:  I just have more of a

 

  6   comment than a question.  I think this is all very

 

  7   interesting, how we are deciding what cure means

 

  8   and what most means, but I guess at some point, we

 

  9   are all consumers, but I am concerned about the

 

 10   consumers that aren't in this room that see the

 

 11   advertisements for these products and see cure,

 

 12   they may not even look at most, but just see the

 

 13   word "cure" and make assumptions based upon that.

 

 14             I don't expect anybody to have an answer

 

 15   to that, but it is a comment that I think we need

 

 16   to perhaps consider later.

 

 17             DR. CANTILENA:  Yes, I think we will have

 

 18   an answer this afternoon.

 

 19             Go ahead, Mr. Kresel.

 

 20             MR. KRESEL:  I am sure that when the

 

 21   monograph was developed, there was probably debate

 

 22   over the terminology and what it should say, but

 

                                                                89

 

  1   since the labeling doesn't define cure, and

 

  2   therefore I think it is very difficult for the

 

  3   consumer to really know what they are getting when

 

  4   it says "cures most," we might want to go back and

 

  5   talk about that debate between treats and cures.

 

  6             DR. CANTILENA:  Dr. Benowitz, the final

 

  7   question.

 

  8             DR. BENOWITZ:  Just a question about the

 

  9   GRASE criteria.  For example, nystatin was not

 

 10   accepted as GRASE, so is that because of efficacy,

 

 11   or are there some safety issues with some of these

 

 12   products, as well?

 

 13             DR. MAHAYNI:  I don't recall for what

 

 14   purpose that was taken out of the GRASE category or

 

 15   classification.

 

 16             DR. BENOWITZ:  But just do you know, are

 

 17   there any safety issues for any of these products?

 

 18             DR. MAHAYNI:  For nystatin itself?

 

 19             DR. BENOWITZ:  No, just for the variety of

 

 20   antifungals.  I know some probably don't work, but

 

 21   should we be thinking about any safety issues for

 

 22   any of these antifungals?

 

                                                                90

 

  1             DR. MAHAYNI:  For most what I have done

 

  2   for preparation of the advisory committee meeting,

 

  3   we focused on the efficacy.  I didn't particularly

 

  4   look at the safety, I didn't go over what study was

 

  5   submitted to the monograph for safety purpose,

 

  6   because we were focusing here on efficacy rate, so

 

  7   I reviewed all the effectiveness studies that were

 

  8   listed in the monograph, so I can't answer your

 

  9   question.

 

 10             DR. BENOWITZ:  I am wondering if anyone at

 

 11   FDA has information about hypersensitivity or other

 

 12   safety issues involving these agents.

 

 13             DR. CANTILENA:  Dr. Ganley, does your

 

 14   staff have that?

 

 15             DR. GANLEY:  We can look for that, but I

 

 16   suspect that, you know, today, when we look at

 

 17   today, what we asked for in studies and what they

 

 18   may have looked at back in the seventies, there may

 

 19   have been safety information that looked at

 

 20   exposure, you know, to a group of individuals.  It

 

 21   wasn't a specific study that would address that.

 

 22             Today, there are irritation studies,

 

                                                                91

 

  1   photocarcinogenicity studies, and a whole variety

 

  2   of different studies that may be asked of a topical

 

  3   agent, and John could probably address it better

 

  4   than I can.

 

  5             But I would suspect that if you go back

 

  6   and look at that, it was basically data that was

 

  7   submitted about use in various populations, and

 

  8   there was no significant adverse effects.

 

  9             DR. CANTILENA:  We have a comment over

 

 10   here from Kresel.

 

 11             MR. KRESEL:  I was just going to say,

 

 12   because I am the oldest one here, and remember back

 

 13   then, there were very skimpy studies that were

 

 14   done, and there probably wasn't enough to really

 

 15   come to a conclusion, not that there was any

 

 16   particularly negative data and probably the sponsor

 

 17   didn't do an awful lot.

 

 18             DR. CANTILENA:  Thank you.

 

 19             Did you have a comment, Dr. Bisno, that is

 

 20   related to this?

 

 21             DR. BISNO:  Just a comment which I will

 

 22   deal with slightly in my talk, which is if you look

 

                                                                92

 

  1   at the 13 episodes that have been reported to the

 

  2   FDA, according to the information we got, about

 

  3   cellulitis related to these topical products, most

 

  4   of them, if you look at them, look like their

 

  5   hypersensitivity reactions someone got.  They got

 

  6   it and then a day later they developed inflammation

 

  7   of some sort, it wasn't really compatible with what

 

  8   one would think would be a cellulitis.

 

  9             So, at least in those very scanty reports,

 

 10   one would suspect that at least a number of them

 

 11   were actually hypersensitivity related in one way

 

 12   or another.

 

 13             DR. CANTILENA:  Dr. Katz.

 

 14             DR. KATZ:  In response to a previous

 

 15   question as far as nystatin, why that was excluded

 

 16   from the GRASE, I would assume that it was because

 

 17   it is in not effective, it is not effective for

 

 18   these conditions.

 

 19             DR. CANTILENA:  Dr. Schmidt.

 

 20             DR. SCHMIDT:  Ladies and gentlemen, you

 

 21   all are very lucky today, because you have somebody

 

 22   who is older than Dr. Kresel, and also we were

 

                                                                93

 

  1   interested in these medications in the seventies,

 

  2   and actually, when I was a resident, I helped in

 

  3   some of these studies.

 

  4             These studies, at least the ones we did,

 

  5   were very well done and I think, you know, as I

 

  6   recall, there were very few side effects with these

 

  7   different medications although some of these

 

  8   things, it seemed like the vehicles were almost as

 

  9   good as the medications.

 

 10             So, I just want to say that you all are

 

 11   lucky.

 

 12             DR. CANTILENA:  We are very lucky.  We

 

 13   have an investigator here, as well as an advisory

 

 14   committee member.

 

 15             Dr. Whitmore.

 

 16             DR. WHITMORE:  With regard to contact

 

 17   hypersensitivity and such, I think the chemicals

 

 18   themselves are not big-time contact allergens by

 

 19   any means, and it would be more likely the

 

 20   excipient agents.

 

 21             DR. CANTILENA:  Thank you very much.

 

 22             Our next FDA presenter is Dr. Shetty.

 

                                                                94

 

  1             Topical Antifungal Drug Product Labeling

 

  2             DR. SHETTY:  My name is Daiva Shetty.  I

 

  3   am a medical officer in the Division of

 

  4   Over-the-Counter Drug Products.

 

  5             [Slide.]

 

  6             My talk will consist of several different

 

  7   topics. First, I will briefly present some

 

  8   marketing and postmarketing safety data for topical

 

  9   and antifungal drug products.  I will focus more in

 

 10   detail on labeling issues for this class of drugs

 

 11   and also provide some examples how we convey

 

 12   efficacy information to consumers.

 

 13             [Slide.]

 

 14             First, I will start with the marketing

 

 15   data.

 

 16             [Slide.]

 

 17             There are 11 active ingredients approved

 

 18   for tinea pedis indication through New Drug

 

 19   Applications for prescription and over-the-counter

 

 20   use.  There are also, as mentioned earlier, 7

 

 21   monograph active ingredients that the Agency found

 

 22   to be generally recognized as safe and effective. 

 

                                                                95

 

  1   Both prescription and over-the-counter products are

 

  2   widely used for the treatment of dermal fungal

 

  3   infections.

 

  4             [Slide.]

 

  5             The Division of Surveillance analyze the

 

  6   prescription and over-the-counter sales trends and

 

  7   drug use patterns for topical antifungals.

 

  8             Two IMS health databases were used to

 

  9   gather this information, National Sales

 

 10   Perspectives and National Disease and Therapeutic

 

 11   Index.

 

 12             [Slide.]

 

 13             The first database, National Sales

 

 14   Perspectives, measures the volume of drug products,

 

 15   prescription and nonprescription, going from

 

 16   manufacturers into a market in terms of eaches.  An

 

 17   each is IMS's unit of measure for single items,

 

 18   such as tubes, jars, or individual retail packages.

 

 19             This database does not provide the

 

 20   demographics of consumers purchasing the drugs.  It

 

 21   does not give the indication for use or the amount

 

 22   of drug actually used.

 

                                                                96

 

  1             [Slide.]

 

  2             This slide shows the National Sales

 

  3   Perspectives data for topical antifungals in 2003.

 

  4   Over-the-counter topical antifungal drug products

 

  5   accounted for over 20 million eaches, while

 

  6   prescription products accounted for around 16

 

  7   million eaches in 2003.

 

  8             This is somewhat surprising to us given

 

  9   that over-the-counter products are freely available

 

 10   to consumers for their purchase and use.  Keep in

 

 11   mind that the sales data are for topical antifungal

 

 12   ingredients in general, and do not reflect the

 

 13   tinea pedis indication.

 

 14             [Slide.]

 

 15             Here is the table from the same database

 

 16   listing active ingredients, prescription and

 

 17   nonprescription, approved for the treatment of

 

 18   tinea pedis in terms of sales. We can see that

 

 19   monograph ingredients highlighted on this slide in

 

 20   yellow account for the highest volume sold.

 

 21             [Slide.]

 

 22             The second IMS health database, National

 

                                                                97

 

  1   Disease and Therapeutic Index, estimates the use of

 

  2   drugs by collecting data on drug products

 

  3   mentioned, but not necessarily prescribed, during

 

  4   visits to a panel of approximately 2,000 to 3,000

 

  5   office-based physicians.

 

  6             These data are collected and projected

 

  7   nationally to reflect national prescribing

 

  8   patterns.  It may include profiles and trends of

 

  9   diagnoses, patients, and treatment patterns.  It

 

 10   does not, however, capture patients who

 

 11   self-diagnose and purchase over-the-counter drugs.

 

 12             [Slide.]

 

 13             My final slide on marketing displays data

 

 14   from National Disease and Therapeutic Index.  The

 

 15   vertical axis shows the numbers of users, and the

 

 16   percentages of bar graphs reflect a fraction of all

 

 17   drugs.

 

 18             In 2003, the most common agents

 

 19   recommended by a physician to treat tinea pedis

 

 20   were those listed on this slide, and all of them

 

 21   except for terbinafine are prescription products.

 

 22             [Slide.]

 

                                                                98

 

  1             In the second part of my talk, I will

 

  2   briefly summarize findings from the FDA's Adverse

 

  3   Event Reporting System.  There is a full review

 

  4   included in your background packages.

 

  5             [Slide.]

 

  6             We requested the Office of Drug Safety to

 

  7   review all the adverse event reports received

 

  8   through the Adverse Event Reporting System for all

 

  9   topical antifungal agents focusing on two issues:

 

 10   lack of efficacy and cellulitis cases.

 

 11             [Slide.]

 

 12             There are certain limitations to these

 

 13   data.  There are no adverse event reporting

 

 14   requirements for monograph ingredients.  Therefore,

 

 15   reporting for those drug products may be

 

 16   significantly underrepresented.

 

 17             The report gives only crude numbers for

 

 18   the active ingredients.  That means that you don't

 

 19   have a denominator and cannot estimate the

 

 20   incidence of each report.  Some ingredients are

 

 21   marketed in multiple formulations for several

 

 22   different indications which will not be reflected

 

                                                                99

 

  1   in the report.

 

  2             Finally, causality of what is the primary

 

  3   suspect drug in the report was not assessed.

 

  4             [Slide.]

 

  5             Given all the limitations, the search

 

  6   found a total of 4,741 reports for 15 active

 

  7   ingredients, of which the most common, 35 percent

 

  8   reported a lack of efficacy.

 

  9             This is a very high percentage.  In our

 

 10   experience, we don't usually see that a third of

 

 11   all reports would be associated with a lack of

 

 12   efficacy of the drug.

 

 13             The majority of the lack of efficacy

 

 14   reports in AERS database were associated with these

 

 15   listed four ingredients, and the numbers in the

 

 16   package reflect year of approval of that particular

 

 17   drug in the U.S.

 

 18             Given this high number of low efficacy

 

 19   reports, we worried if there are some consequences,

 

 20   such as missed or mistreated diagnosis.

 

 21             [Slide.]

 

 22             What we could do is search our database

 

                                                               100

 

  1   for cellulitis reports.  The Office of Drug Safety

 

  2   found 13 cases of cellulitis associated with those

 

  3   15 topical antifungal agents.

 

  4             Cellulitis in these 13 cases was reported

 

  5   as an adverse event, and was not a condition being

 

  6   treated.  Although more cases of cellulitis were

 

  7   reported for terbinafine and miconazole, based on

 

  8   this small number of spontaneously submitted

 

  9   adverse event reports, we are unable to say that

 

 10   particular antifungal agents are associated with

 

 11   more or less cellulitis cases than other agents.

 

 12             [Slide.]

 

 13             More on the issue of cellulitis, you will

 

 14   hear later today presented by Dr. Bisno.  I will

 

 15   summarize 13 AERS cases.

 

 16             All 13 cases were diagnosed as cellulitis

 

 17   and were primarily of U.S. origin.  The patients

 

 18   were using the antifungal agents for a variety of

 

 19   reasons, but tinea pedis is the predominant reason.

 

 20             Cellulitis symptoms typically started one

 

 21   day after application of the topical agent, and the

 

 22   sites most often affected were the lower

 

                                                               101

 

  1   extremities.  One patient reported having diabetes

 

  2   and seven patients reported hospitalization.

 

  3             Of the seven hospitalization cases, one

 

  4   patient was hospitalized for worsening Parkinson's

 

  5   disease, and cellulitis in this patient was

 

  6   diagnosed, but was not the reason for

 

  7   hospitalization.

 

  8             The six remaining cases were for

 

  9   cellulitis, however, it was unclear in two cases

 

 10   that the cellulitis occurred before or after the

 

 11   administration of the antifungal agent.

 

 12             [Slide.]

 

 13             The last part of my presentation is

 

 14   over-the-counter labeling issues.

 

 15             [Slide.]

 

 16             There are three types of labeling for

 

 17   topical antifungal drug products:  prescription

 

 18   labeling for prescription drug products and two

 

 19   types of over-the-counter drug labeling for

 

 20   monograph and NDA drug products.

 

 21             Given the efficacy rates for this class of

 

 22   drugs and numerous consumer complaints on the lack

 

                                                               102

 

  1   of efficacy, it is apparent that consumers may not

 

  2   understand that they may not achieve symptom relief

 

  3   or cure by the end of the treatment.  Current

 

  4   labeling does not specifically communicate this

 

  5   message.

 

  6             [Slide.]

 

  7             I will start with prescription labeling.

 

  8   Information conveyed on prescription labeling is

 

  9   targeted at health care providers.  It has detailed

 

 10   information on drug pharmacology, microbiology,

 

 11   preclinical and clinical data, indications,

 

 12   contraindications, warnings, and dosage and

 

 13   administration.

 

 14             [Slide.]

 

 15             This is an example of the indications and

 

 16   usage section on prescription labeling for topical

 

 17   antifungals drug products.  The point of this slide

 

 18   is to show that at it lists specific conditions,

 

 19   that are in yellow and underlined, and specific

 

 20   fungi that particular ingredient is effective

 

 21   against.

 

 22             [Slide.]

 

                                                               103

 

  1             The Directions for Use Section in

 

  2   Prescription Labeling gives the duration of use for

 

  3   the particular product, for example, two weeks for

 

  4   tinea corporis or tinea cruris, and four weeks for

 

  5   tinea pedis.

 

  6             [Slide.]

 

  7             Expectations of treatment are also

 

  8   specified in Prescription Labeling.  Sample of such

 

  9   a labeling is shown on this slide.  If a patient

 

 10   shows no clinical improvement after four weeks of

 

 11   treatment, the diagnosis should be reviewed.

 

 12             This information does not appear on

 

 13   patients' container labeling, and it is very

 

 14   dependent on a physician who is prescribing and

 

 15   giving instructions to the patient.

 

 16             [Slide.]

 

 17             The second type is labeling for

 

 18   over-the-counter monograph products.

 

 19             [Slide.]

 

 20             This is an example of over-the-counter

 

 21   drug facts labeling format, which appears on the

 

 22   carton of each over-the-counter drug.  Labeling of

 

                                                               104

 

  1   OTC monograph ingredients conveys indication in the

 

  2   Uses Section, which follows Active Ingredient

 

  3   Section.

 

  4             There are two statements in the Uses

 

  5   Section on all monograph antifungal products.

 

  6             The first is a required statement, and it

 

  7   states, "Treats or cures most athlete's foot."

 

  8             The second is an optional statement, and

 

  9   states relieves or for relief of a list of

 

 10   symptoms, such as itching, burning, cracking, and

 

 11   scaling.

 

 12             [Slide.]

 

 13             Labeling for monograph ingredients

 

 14   specifies four week duration of treatment and

 

 15   directs the consumer to seek medical advice if

 

 16   symptoms persist at the end of the treatment.

 

 17             Under the Directions Section, it states,

 

 18   "Use daily for four weeks, and if condition

 

 19   persists longer, ask a doctor."

 

 20             [Slide.]

 

 21             Also, the Warning Section states, "Stop

 

 22   use and ask a doctor if irritation occurs or if

 

                                                               105

 

  1   there is no improvement within four weeks," which

 

  2   is the label duration of treatment.

 

  3             [Slide.]

 

  4             The third type of labeling is for

 

  5   over-the-counter NDA drug products.  There are a

 

  6   few differences between the labeling of monograph

 

  7   ingredients and products marketed under NDAs.

 

  8             [Slide.]

 

  9             The Uses Section of NDA nonprescription

 

 10   product labeling is usually consistent with the

 

 11   Uses Section of the products marketed under the

 

 12   monograph except when conditions studied in

 

 13   clinical trials are somehow different.

 

 14             For instance, if patients enrolled into

 

 15   clinical trials get only interdigital tinea pedis,

 

 16   this will be reflected in the Uses Section, as is

 

 17   shown on this slide, "Cures most athlete's foot

 

 18   between the toes, and effectiveness on bottom or

 

 19   side of foot is unknown."

 

 20             The second bullet is also similar to

 

 21   optional indication statements as monograph

 

 22   ingredients.

 

                                                               106

 

  1             [Slide.]

 

  2             The Directions Section on the

 

  3   over-the-counter NDA drug labeling also reflects

 

  4   the treatment regimen studied in clinical trials.

 

  5   We have two types of over-the-counter antifungal

 

  6   drug products for tinea pedis approved under NDAs.

 

  7             This is an example of product that is

 

  8   approved for four-week duration of treatment.

 

  9             [Slide.]

 

 10             This is an example of the labeling for

 

 11   product that is approved for one-week duration of

 

 12   treatment.

 

 13             [Slide.]

 

 14             The main difference between NDA and

 

 15   monograph product labeling is that NDA labeling

 

 16   does not specifically inform consumer about the

 

 17   time of expected outcome.  The warning simply

 

 18   states, "Stop use and ask a doctor if too much

 

 19   irritation occurs or gets worse."  There is no

 

 20   specific information on expected efficacy.

 

 21             [Slide.]

 

 22             Talking about efficacy, I would like to

 

                                                               107

 

  1   show a few examples of over-the-counter labeling,

 

  2   how we convey this information to consumers.

 

  3             [Slide.]

 

  4             Most of over-the-counter products are

 

  5   indicated for acute symptom relief.  Few have a lag

 

  6   time between the treatment initiation and

 

  7   completion, and the expected results.  Efficacy

 

  8   rates usually are not presented on over-the-counter

 

  9   labeling, which few products have.  If this

 

 10   information is present, it is presented in Drug

 

 11   Facts on the carton or in the package insert.

 

 12             [Slide.]

 

 13             One example is one of the newly-approved

 

 14   over-the-counter products that has a lag time

 

 15   between the initiation of treatment and complete

 

 16   response is omeprazole.  The Uses Section and the

 

 17   Direction Section both state that it may take one

 

 18   to four days for full effect.

 

 19             This information is included on the carton

 

 20   label, so consumers can read this statement when

 

 21   considering to purchase the product.  The same

 

 22   information is included in the package insert.

 

                                                               108

 

  1             [Slide.]

 

  2             The next example is an over-the-counter

 

  3   product with the efficacy information is labeling

 

  4   for minoxidil.  The following warning statement on

 

  5   the carton label is also available to consumers at

 

  6   the time of purchase.

 

  7             Under the section When Using this Product,

 

  8   it states, "It takes time to regrow hair.  Results

 

  9   may occur at two months with twice-a-day usage, and

 

 10   for some it may take four months to see results."

 

 11   The same information is included in the package

 

 12   insert.

 

 13             [Slide.]

 

 14             The last example is labeling for

 

 15   famotidine, which includes information about the

 

 16   efficacy rate of the product in the package insert.

 

 17   Two bar graphs demonstrate heartburn relief,

 

 18   prevention, or reduction for the drug product

 

 19   relative to placebo.

 

 20             Because this information is in the package

 

 21   insert, it is not available to consumers at the

 

 22   time of purchase, and we don't know if consumers

 

                                                               109

 

  1   reach this information at all.

 

  2             [Slide.]

 

  3             Today, we are seeking your advice.  Should

 

  4   the following be in the over-the-counter topical

 

  5   antifungal drug label?  Efficacy rates, time to

 

  6   symptom relief, expected time to cure, when to see

 

  7   a doctor, and whether ancillary measures to prevent

 

  8   tinea pedis, such as changing socks, wearing

 

  9   well-fitting, ventilated shoes, or cleaning showers

 

 10   should be emphasized on the label.

 

 11             This concludes my talk.

 

 12             DR. CANTILENA:  Thank you, Dr. Shetty.

 

 13             We have time for questions from the

 

 14   committee.  Dr. Lam.

 

 15             DR. LAM:  I want to go back to the Adverse

 

 16   Event Reporting System data that you presented,

 

 17   specifically regarding the 35 percent lack of

 

 18   efficacy data.

 

 19             Do you have information whether that was

 

 20   mostly associated with the one-week regimen, or the

 

 21   four-week regimen, or a combination of both?

 

 22             DR. SHETTY:  This is all, combination of

 

                                                               110

 

  1   all.

 

  2             DR. LAM:  Okay.  So, we don't even have a

 

  3   sense whether it is primary one week, because the

 

  4   data clearly showed that one week--

 

  5             DR. SHETTY:  We have more reports for

 

  6   one-week products.  Maybe the reviewer for the

 

  7   database will answer your question.

 

  8             DR. CANTILENA:  Yes, there is a comment

 

  9   over here?

 

 10             DR. PITTS:  My name is Marilyn Pitts.

 

 11   Actually, for the lack of efficacy reports, because

 

 12   of the extreme volume, we were unable to look at

 

 13   those reports individually, so we don't know the

 

 14   duration of treatment.  We don't know if's a

 

 15   one-week or four-week or three-week, or even if the

 

 16   patient used it once a day or twice a day.  So, we

 

 17   don't have that information.

 

 18             DR. LAM:  I will say that if there is a

 

 19   way that we can get a sense, it will be important

 

 20   for us to consider some of the issues either this

 

 21   afternoon or tomorrow.  There is no way to do that?

 

 22             DR. CANTILENA:  There probably are

 

                                                               111

 

  1   thousands, right?

 

  2             DR. PITTS:  There are thousands, there is

 

  3   almost 1,700 reports.  It takes a long time to even

 

  4   pull the images and then to go through and

 

  5   categorize and get that information.  It is

 

  6   extremely time-consuming and difficult to get that.

 

  7             DR. CANTILENA:  You know, we have really

 

  8   about three hours before we come back after lunch.

 

  9             [Laughter.]

 

 10             DR. CANTILENA:  There is a lot of FDA

 

 11   employees.  It is not going to happen, Dr. Lam.

 

 12             DR. LAM:  Are we going to consider the

 

 13   question whether--in your executive summary, you

 

 14   indicated that some of the manufacturers are

 

 15   considering developing products of less than

 

 16   one-week treatment duration--so, are we going to

 

 17   consider that at all today or not?

 

 18             DR. GANLEY:  I think it is done in the

 

 19   context of understanding what the cure rates are or

 

 20   effective treatments that we see, and the lack of

 

 21   dose-response information.

 

 22             In that context, if someone did a study

 

                                                               112

 

  1   that showed three days of treatment was as good as

 

  2   one month of treatment, and they figured out what

 

  3   the correct concentration is, well, that is pretty

 

  4   good, I think.

 

  5             The issue I think is we don't get that

 

  6   information.  It is really what beats vehicle and

 

  7   what kind of study is done, and I think that is

 

  8   where the committee has to start addressing, you

 

  9   know, from a dose-response, and one of the

 

 10   questions actually addresses that.

 

 11             I think that is the context, but I have no

 

 12   objection to have a one-day or a three, and we have

 

 13   had inquiries about a one-day treatment product.

 

 14   So, it is what is the bar that we want to set here,

 

 15   is it just that you beat vehicle or is it that we

 

 16   try to maximize the efficacy for consumers.

 

 17             DR. CANTILENA:  We have Clapp, Raimer,

 

 18   Schmidt, and Katz.

 

 19             DR. CLAPP:  This is just a question really

 

 20   based on curiosity.  Because of the sheer volume of

 

 21   complaints you have had, or consumer complaints,

 

 22   what is the method by which a consumer's concern of

 

                                                               113

 

  1   lack of efficacy gets to the FDA?

 

  2             DR. MAHAYNI:  Well, they just report like

 

  3   any other adverse event.  It is actually a

 

  4   complaint, but they call to Adverse Event Reporting

 

  5   System.

 

  6             DR. CLAPP:  But how does the consumer get

 

  7   to the Adverse Event Reporting System?  I don't

 

  8   think many physicians do it on this level.

 

  9             DR. MAHAYNI:  Maybe they call the number

 

 10   on the package and then it comes.  I don't know

 

 11   they come to us.

 

 12             MR. KRESEL:  Can I comment because

 

 13   pharmacovigilance is part of my department, as

 

 14   well?  They call the number that is on the bottle,

 

 15   and then we are required to report it to FDA.

 

 16             DR. CANTILENA:  And then FDA holds an

 

 17   advisory committee.

 

 18             Yes.  Did you have a comment about it?

 

 19             DR. PITTS:  Right, the Med Watch form is

 

 20   also available via the internet.  There is also a

 

 21   1-800 number. But I recognize that patients have to

 

 22   recognize that there is a system in place, and I

 

                                                               114

 

  1   don't think the carton actually has that

 

  2   information specifically, because even for health

 

  3   care providers, to recognize there is a system in

 

  4   place where if you have a complaint about a

 

  5   product, then, you should call.

 

  6             DR. CANTILENA:  Thank you.

 

  7             Dr. Raimer.

 

  8             DR. RAIMER:  I was just going to mention

 

  9   that most of the complaints were against agents

 

 10   that you could over the counter, so a lot of the

 

 11   patients probably had psoriasis or probably had

 

 12   eczema or probably did not have tinea in the first

 

 13   place, so there is no way to really judge whether

 

 14   the patient even had tinea to start with.

 

 15             So, a lot of the complaints, they have

 

 16   similar symptoms, so it would be difficult to know

 

 17   what the patient really had in the first place.

 

 18             DR. CANTILENA:  So, you are saying there

 

 19   is a problem in the setting of an OTC, you know,

 

 20   self-diagnosis?

 

 21             DR. RAIMER:  Yes.

 

 22             DR. CANTILENA:  Well, that is another

 

                                                               115

 

  1   issue that is not on our list of issues.

 

  2             DR. PITTS:  I am sorry, could I make a

 

  3   clarification?  Actually, we believe that the

 

  4   reports for the over-the-counter products are

 

  5   underrepresented.  If you look at the number of

 

  6   reports, the topical terbinafine and topical

 

  7   miconazole, those were previously prescription

 

  8   products, and if we were to probably look at that,

 

  9   we probably would see that most of those or some of

 

 10   those occurred more during the prescription process

 

 11   as opposed to the OTC process, so I don't have any

 

 12   idea.

 

 13             DR. RAIMER:  Even then, a lot of

 

 14   physicians do not do the mycology, they don't the

 

 15   KOH, they judge just clinically, so even then, I

 

 16   think a lot of those probably don't really

 

 17   represent tinea.

 

 18             DR. CANTILENA:  Dr. Schmidt.

 

 19             DR. SCHMIDT:  Before too long, I would

 

 20   like to address this about the cellulitis issue and

 

 21   get this on the table.

 

 22             These case reports are real dogs, you

 

                                                               116

 

  1   know, as far as cellulitis.  I don't think any of

 

  2   these people had really an adverse reaction to any

 

  3   of these medications, and I don't think they were

 

  4   cellulitis.  I think they were contact dermatitis.

 

  5             There was one patient that had TEN

 

  6   probably from Enbrel, and I think to put this down

 

  7   as these 13 cases of cellulitis, this really needs

 

  8   to be brought up and discussed.

 

  9             DR. CANTILENA:  I am not sure what that

 

 10   is, but there is an opportunity right after our

 

 11   next speaker, we will be actually talking about the

 

 12   complications.

 

 13             DR. PITTS:  Can I respond to that?

 

 14   Actually, the prescriber or the reporter identified

 

 15   the cases as cellulitis, we did not make any

 

 16   judgment call in terms of whether they were

 

 17   cellulitis or not, but this was what was actually

 

 18   reported by the health care practitioner that

 

 19   submitted the report for those cases.

 

 20             We are not making any judgment call as to

 

 21   whether or not they are good cases or bad cases.

 

 22   These are just the cases that were reported.

 

                                                               117

 

  1             DR. SCHMIDT:  Woof, woof, woof.

 

  2             DR. CANTILENA:  I think Dr. Schmidt has

 

  3   just made a judgment call.

 

  4             [Laughter.]

 

  5             DR. CANTILENA:  Dr. Katz.

 

  6             DR. KATZ:  I wanted to reemphasize that we

 

  7   should keep in mind the likelihood that the reports

 

  8   of lack of efficacy must represent a minuscule,

 

  9   tiny minuscule portion of people who have lack of

 

 10   efficacy, because the average folks out there are

 

 11   going to use this for what they perceive to be, as

 

 12   Dr. Raimer said, tinea pedis, and it doesn't work.

 

 13   They think it says it should relieve symptoms, it

 

 14   doesn't work in two or three applications, so they

 

 15   stop using it, and they take it as a loss.

 

 16             So, I wouldn't be surprised, if a survey

 

 17   was done at the 0.1 percent of reports you are

 

 18   getting.

 

 19             DR. CANTILENA:  Dr. Benowitz and then Dr.

 

 20   Alfano.

 

 21             DR. BENOWITZ:  It was striking to me that

 

 22   there was almost as many prescriptions by

 

                                                               118

 

  1   physicians for topical antifungals as OTC uses, and

 

  2   my question is, is this for insurance purposes, or

 

  3   is there some evidence that the antifungals that

 

  4   are available by prescription only work better or

 

  5   why is this the case?  It is very striking to me

 

  6   that there is such a huge volume of prescriptions.

 

  7             I guess that question might be to my

 

  8   dermatology colleagues about why that is occurring.

 

  9             DR. CANTILENA:  Anyone?  Comments from the

 

 10   Dermatology Committee?

 

 11             MR. KATZ:  Might it be that some of them

 

 12   were prescribed prior to its becoming OTC, for

 

 13   instance, clotrimazole has been OTC probably for,

 

 14   what, five or eight years, so maybe a lot of those

 

 15   reports were when it was prescription?

 

 16             DR. BENOWITZ:  This was 2003.

 

 17             MR. KATZ:  2003.  I would be very

 

 18   surprised because in recent years, we don't write

 

 19   prescriptions for that.  We just write it for the

 

 20   patients to get it at the drugstore.  We may write

 

 21   it down on a prescription, but without its being a

 

 22   signed prescription.

 

                                                               119

 

  1             DR. SHETTY:  Maybe the physicians are

 

  2   still used to prescribe or advice to use products

 

  3   that were prescription recently.

 

  4             DR. SCHMIDT:  May I comment just a minute?

 

  5   I think a lot of this, I don't really write for

 

  6   prescription topical antifungals anymore.  You

 

  7   know, the majority of them, they may have a funny

 

  8   name, but they will have the medication that is a

 

  9   prescription, but I think a lot of this is

 

 10   marketing by some of the drug companies.

 

 11             I think, to me, there are a lot of people

 

 12   who will still write prescriptions for things, and

 

 13   I think a lot of it is a marketing effort by the

 

 14   drug companies.

 

 15             DR. CANTILENA:  Other comments?

 

 16             DR. WOOD:  As I understand this, we don't

 

 17   know that this is OTC, do we?  I mean the Rx's may

 

 18   well be for systemic antifungals for this

 

 19   indication.

 

 20             DR. SHETTY:  Only topical antifungals.

 

 21             DR. WOOD:  Are you sure?  Are you sure of

 

 22   that?

 

                                                               120

 

  1             DR. SHETTY:  Yes.  We took out the

 

  2   systemic and we took out some ketoconazole.

 

  3             DR. WOOD:  So, the 15.7 million

 

  4   prescription were eaches for itches, that were all

 

  5   topical, is that right?

 

  6             DR. SHETTY:  Yes.

 

  7             DR. GANLEY:  I think that it was pointed

 

  8   out that we can't separate out, particularly for

 

  9   the prescription, which ones were for other

 

 10   conditions other than tinea pedis, and even for the

 

 11   OTCs, there is other claims.  I think tinea pedis,

 

 12   of the three that are over the counter, is probably

 

 13   the most common, but that is the difficulty.

 

 14             But is it a little surprising I think when

 

 15   you see the percentages here or the number of

 

 16   eaches for each.  I think what is interesting, too,

 

 17   is if you look at the National Sales Perspective,

 

 18   which was Slide 8, the Clotrimazole and

 

 19   betamethasone was the highest there in the number

 

 20   of eaches.

 

 21             But if you look at Slide 10, only 12

 

 22   percent of those prescriptions accounted for tinea

 

                                                               121

 

  1   pedis, so the 90 percent of those, you would have

 

  2   to assume then were related to other conditions

 

  3   where if someone saw a rash, didn't know if it

 

  4   required an antifungal or a steroid, so they gave

 

  5   them the combination product.

 

  6             So, it is difficult data to look at, but

 

  7   it is the best that we can do with it.

 

  8             DR. CANTILENA:  Thank you.

 

  9             Did you have a comment, Dr. Whitmore, on

 

 10   this topic?

 

 11             DR. WHITMORE:  I was going to agree with

 

 12   Dr. Schmidt as far as why prescriptions are written

 

 13   for prescription antifungals.  Marketing definitely

 

 14   is a big one, and the pharmaceuticals will come out

 

 15   with studies where they have certain efficacy rates

 

 16   in their control study or whatever, which is better

 

 17   than X drug.

 

 18             Also, oftentimes patients will have used

 

 19   their clotrimazole for two or three days or

 

 20   whatever, a short period of time, come in to the

 

 21   physician and say I am not better, so a

 

 22   prescription is written for something else.

 

                                                               122

 

  1             DR. CANTILENA:  Dr. Alfano.

 

  2             DR. ALFANO:  Dr. Shetty, your Slide 12,

 

  3   you said you searched the AERS data as of March

 

  4   16th.  What is the start date on that data?

 

  5             DR. SHETTY:  All the reports that were

 

  6   received.

 

  7             DR. ALFANO:  So, this is all reports like

 

  8   in the history of man?  I guess my point is so we

 

  9   saw 20 million eaches, whatever that translates to

 

 10   in terms of treatments, just for the year of 2003,

 

 11   so we are talking about tens of millions, if not

 

 12   hundreds of millions, of doses, treatments in this

 

 13   database for a condition for which the previous

 

 14   data presented said 40 percent of people who

 

 15   present to hospitals have the condition and 15 to

 

 16   70 percent of free-living Americans have the

 

 17   condition.

 

 18             So, I guess the trouble I am having is,

 

 19   you know, the perception that this is such a large

 

 20   database, it actually seems to be a very tiny

 

 21   database relative to the number of individuals who

 

 22   have the condition and who have treated the

 

                                                               123

 

  1   condition.

 

  2             DR. PITTS:  If I can respond, the AERS

 

  3   database, this is all reports in the database for

 

  4   those agents, for the topical agents, and we know

 

  5   that there is a significant amount of

 

  6   underreporting that occurs between recognizing that

 

  7   there is an adverse event and then having that

 

  8   person report it.

 

  9             With the topical agents, I would suspect

 

 10   that there is even less of a reason for people to

 

 11   draw a correlation, but there is a different time

 

 12   period where they came on the market, so it is

 

 13   really for all the ones that we have for the life

 

 14   that we have, but these are two different databases

 

 15   between the drug use data and the adverse event

 

 16   databases.  Those are different databases.

 

 17             DR. CANTILENA:  Dr. Katz.

 

 18             DR. KATZ:  I just want to clarify

 

 19   something.  What was mentioned, the

 

 20   over-the-counter products are being prescribed,

 

 21   were you referring to page 5 of this last

 

 22   presentation, where in 2003, most physicians

 

                                                               124

 

  1   recommended antifungals for tinea pedis, is that

 

  2   what you were referring to?

 

  3             DR. BENOWITZ:  No, what I was referring to

 

  4   was actually Slide 7, just showing the volume.

 

  5             DR. KATZ:  What page is that?

 

  6             DR. BENOWITZ:  Page 4, I was just

 

  7   referring to the volume of prescribed topicals.

 

  8             DR. KATZ:  That doesn't mean prescribed,

 

  9   number one.

 

 10             DR. SHETTY:  No, this is all in terms of

 

 11   eaches, whatever goes from manufacturer into the

 

 12   marketplace.

 

 13             DR. KATZ:  That is not prescribed.

 

 14             DR. SHETTY:  That is not prescribed.

 

 15             DR. KATZ:  And on page 5, where it says

 

 16   "National Disease and Therapeutic Index 2003"--

 

 17             DR. SHETTY:  This is a different database.

 

 18             DR. KATZ:  That is physician recommended.

 

 19             DR. SHETTY:  That physician mentioned

 

 20   during the visit.

 

 21             DR. KATZ:  That doesn't physician

 

 22   prescribed.

 

                                                               125

 

  1             DR. SHETTY:  No, that doesn't.

 

  2             DR. KATZ:  So, we should have that

 

  3   straight, because frequently, we will write--not

 

  4   frequently--always we will write if we want patient

 

  5   for tinea pedis to use clotrimazole, miconazole, we

 

  6   will write on the prescription, for patient to

 

  7   remember, so we will write on the prescription

 

  8   without signing it, without the patient's name on

 

  9   the top, just so they remember.

 

 10             That is physician recommended.  That

 

 11   includes not OTC, because

 

 12   Clotrimazole/betamethasone is not OTC, I don't know

 

 13   what Naftifine is, so I think that may have been

 

 14   the source of confusion.

 

 15             DR. GANLEY:  I just want to clarify, on

 

 16   that Slide 10, for the National Disease and

 

 17   Therapeutic Index, that could have been OTC or

 

 18   prescription.

 

 19             DR. SHETTY:  Right, Butenafine is

 

 20   nonprescription.

 

 21             DR. GANLEY:  Right, so it does suggest

 

 22   that the Ciclopirox, which I think is the Rx drug,

 

                                                               126

 

  1   is the most prescribed for tinea pedis.  You would

 

  2   have to think that if that is a prescription drug,

 

  3   and that is the most recommended, that they

 

  4   actually prescribed it.  That's the only thing I

 

  5   can take away from it.

 

  6             DR. CANTILENA:  We have a final comment

 

  7   over here from Mr. Kresel.

 

  8             MR. KRESEL:  I was just going to comment

 

  9   on the AERS database again and that is what then

 

 10   you look at a class of drugs that doesn't have a

 

 11   significant serious adverse event profile, it is

 

 12   not uncommon then to see that the most common

 

 13   consumer complaint would be lack of efficacy.

 

 14             My experience in getting consumer

 

 15   complaints is that consumers learn early on that if

 

 16   they call the sponsor and complain that their

 

 17   product didn't work, they will get a refund.

 

 18             DR. CANTILENA:  That certainly is an

 

 19   incentive, and I think we all have an incentive to

 

 20   take a break.  We will return at 10:30.

 

 21             [Break.]

 

 22             DR. CANTILENA:  Our first speaker for

 

                                                               127

 

  1   after the break here will be Dr. Alan Bisno from

 

  2   the University of Miami, School of Medicine,

 

  3   infectious disease complications of tinea pedis.

 

  4         Infectious Disease Complications of Tinea Pedis

 

  5             DR. BISNO:  Good morning.  My assignment

 

  6   this morning has been to discuss the relationship

 

  7   of tinea pedis and cellulitis of the lower

 

  8   extremities.  I am embarrassed to do this because,

 

  9   as I am going to tell you in a little while, there

 

 10   is much more that we don't know than what we do

 

 11   know about this particular subject.

 

 12             What I am going to do is start off with

 

 13   some introductory remarks about the epidemiology

 

 14   and nature and clinical nature of cellulitis in

 

 15   general, the problem of recurrent cellulitis and

 

 16   its control, and then go on to discuss in more

 

 17   detail what data there are available on tinea pedis

 

 18   and cellulitis of the lower extremities.

 

 19             Looking around this august group at the

 

 20   table, I know that I am bringing coals to Newcastle

 

 21   for most of you, but I have to apologize for that.

 

 22             [Slide.]

 

                                                               128

 

  1             First of all, what is known about the

 

  2   factors that predispose to lower extremity

 

  3   cellulitis, because certainly, tinea pedis is not

 

  4   the only one, and there is sort of two groups of

 

  5   factors that are known to predispose.

 

  6             First, is anything causing cutaneous

 

  7   disruption, trauma or surgery, burns or ulcers.

 

  8   Varicella is an interesting one, it is not limited

 

  9   to the lower extremities obviously, but

 

 10   pediatricians have known and infectious disease

 

 11   people have known for many years that children who

 

 12   get varicella may often get secondary cellulitis

 

 13   and even life-threatening bacteremias due to

 

 14   streptococcal infection of the varicella, so it's a

 

 15   good reason to have children immunized against

 

 16   varicella.

 

 17             Then, there is dermatophyte infections of

 

 18   all kinds, so cutaneous disruption is one issue,

 

 19   and then there are systemic factors that also

 

 20   predispose to cellulitis including lymphedema and

 

 21   venous insufficiency, obesity is a major risk

 

 22   factor, as I will discuss, ischemia, IV drug abuse.

 

                                                               129

 

  1   Obviously, we see lots of cellulitis in individuals

 

  2   who are parenteral drug abusers, both IV and skin

 

  3   poppers, and then immunosuppression.

 

  4             So, all of these are factors predisposing

 

  5   to lower extremity cellulitis.

 

  6             [Slide.]

 

  7             This is a typical case of cellulitis.  I

 

  8   don't know how well it shows here, but it is a

 

  9   diffuse inflammatory process involving the skin and

 

 10   subcutaneous tissues, and if this projects well

 

 11   enough, which in this lighting it might not, those

 

 12   of you who may be able to see that it is occurring

 

 13   along the site of a saphenous venectomy which was

 

 14   performed for coronary artery bypass grafting.

 

 15             [Slide.]

 

 16             Erysipelas is a little bit different.

 

 17   This is one of my patients with erysipelas, and it

 

 18   involves the more superficial areas of the skin,

 

 19   such that the lymphatics are greatly involved, and

 

 20   this leads to some of the special features of

 

 21   erysipelas, namely, that it is raised above the

 

 22   surrounding area, unlike the cellulitis that I

 

                                                               130

 

  1   showed you in the last slide, and that unlike

 

  2   cellulitis, there is a sharp demarcation between

 

  3   the involved and the uninvolved area.

 

  4             [Slide.]

 

  5             I just show this picture of classic facial

 

  6   erysipelas, which isn't really pertinent to what we

 

  7   are discussing today, simply to mention that

 

  8   nowadays, more and more, we don't see erysipelas in

 

  9   that area, but we do see it in lower extremities,

 

 10   as shown by this patient.

 

 11             You will have to accept my word, because

 

 12   of the lighting in here, that this is raised and

 

 13   well demarcated, and it is a case of erysipelas of

 

 14   the lower extremities, also happens to be one of

 

 15   those in the post-saphenous venectomy group.

 

 16             [Slide.]

 

 17             Sometimes this goes on to more extensive

 

 18   problems. These bullae and vesicles with

 

 19   dark-colored material in them don't necessarily

 

 20   mean that there is going to be an adverse outcome,

 

 21   but they are very worrisome in terms of the

 

 22   possibility, to me, they signify a lot of local

 

                                                               131

 

  1   toxin production, and some patients with cellulitis

 

  2   do go on to have deeper tissue infection which can

 

  3   even be life-threatening.

 

  4             I have taken care of one patient recently

 

  5   who has had three episodes of cellulitis, an obese,

 

  6   homeless patient with severe tinea pedis who had

 

  7   been in the intensive care unit three times, twice

 

  8   in shock, because of this kind of a problem.

 

  9             [Slide.]

 

 10             Well, the microbial etiology of erysipelas

 

 11   and cellulitis differs a little bit in that classic

 

 12   erysipelas, when you see the man that I showed you

 

 13   in the first slide, this is virtually always due to

 

 14   beta-hemolytic strep, mostly Group A, but now

 

 15   always.

 

 16             But the terms cellulitis and erysipelas

 

 17   are often used interchangeably, particularly in the

 

 18   European literature, so many of the studies that I

 

 19   quote or that you will see talk about erysipelas,

 

 20   and they say erysipelas and cellulitis

 

 21   interchangeably, and you can't really tell whether

 

 22   they are talking about erysipelas or cellulitis.

 

                                                               132

 

  1             In truth, that is not such a big deal

 

  2   because many cases are not so clear-cut as the

 

  3   examples that I have shown you, and it really is

 

  4   not always possible to classify it as one or

 

  5   another.

 

  6             The only reason I bring it up is because

 

  7   although classic erysipelas is virtually always

 

  8   beta-hemolytic strep, cellulitis can be due to a

 

  9   wide variety of organisms.  The list of organisms

 

 10   that can cause it is extremely long, but that is

 

 11   for another session.

 

 12             But in most cases, nevertheless, the vast

 

 13   majority of cases are due to beta-hemolytic strep

 

 14   or Staphylococcus aureus.  When you see typical

 

 15   lower extremity cellulitis with diffuse spreading

 

 16   erythema, and not localized pus, that is usually

 

 17   not staphylococcal, it is usually to beta-hemolytic

 

 18   strep, but not necessarily Group A.  It can be A,

 

 19   B, C, or G.

 

 20             [Slide.]

 

 21             It is important for us to discuss

 

 22   recurrent cellulitis because this is an important

 

                                                               133

 

  1   issue in relationship to what we are going to be

 

  2   talking about in terms of tinea pedis.

 

  3             Many patients with episodes of cellulitis

 

  4   experience recurrent attacks.  The percentage of

 

  5   patients in whom this occurs is variable depending

 

  6   upon the risk factors.

 

  7             DeGodoy and associates did a study of a

 

  8   large number of patients, and did lymphatic

 

  9   scintigraphy on these patients and found that 77

 

 10   percent of such patients had abnormalities of

 

 11   lymphatic drainage on scintigraphy, and it is

 

 12   believed that lymphatic drainage is progressive

 

 13   with recurrent episodes, thus exacerbating the

 

 14   problem, so we would really like to prevent

 

 15   recurrent cellulitis.

 

 16             [Slide.]

 

 17             I am going to show a couple of slides on

 

 18   antimicrobial prophylaxis of recurrent cellulitis

 

 19   for a couple of reasons.  The first is that we will

 

 20   get some idea of the baseline rates of recurrence,

 

 21   and the second is that since control of tinea pedis

 

 22   is one of the things we are going to be discussing

 

                                                               134

 

  1   today, that is only one method of preventing

 

  2   recurrent cellulitis, and now you have taught me

 

  3   this morning that most of these things don't work

 

  4   anyway, so I have to look at alternative ways to

 

  5   try to prevent recurrent cellulitis.

 

  6             It is generally written in the literature

 

  7   that patients who have frequent episodes of

 

  8   recurrent cellulitis should be put on continuous

 

  9   antimicrobial therapy to prevent this.  Many of you

 

 10   who practice dermatology in this group may have run

 

 11   into this issue, but it is surprising how little

 

 12   real data there are and how marginally effective

 

 13   such antimicrobial prophylaxis is.

 

 14             For instance, in this study by Wang, et

 

 15   al., 31 patients with definite or presumptive

 

 16   streptococcal cellulitis of the lower extremities

 

 17   were treated with monthly benzathine penicillin G

 

 18   injections, and 70 patients who declined and 14 who

 

 19   received incomplete prophylaxis served as controls.

 

 20             The recurrence rate was 12.9 percent in

 

 21   the treated patients and 19 percent in the

 

 22   controls, which wasn't statistically significant.

 

                                                               135

 

  1             Interestingly enough, benzathine

 

  2   penicillin G was spectacularly effective in

 

  3   reducing recurrences in patients who didn't have

 

  4   any predisposing factors, but not in those with

 

  5   predisposing factors.

 

  6             I have a hard time interpreting this study

 

  7   since the patients I see with recurrence all have

 

  8   predisposing factors.  One predisposing factor they

 

  9   didn't mention in the study, however, was tinea

 

 10   pedis, and that may have been a major unrecognized

 

 11   predisposing factor in this particular study.

 

 12             [Slide.]

 

 13             Here is another one of 40 patients with

 

 14   venous insufficiency or "lymphatic congestion," who

 

 15   had suffered two or more episodes of erysipelas

 

 16   during the previous three years.

 

 17             Twenty patients received oral penicillin

 

 18   or erythro for a median of 15 months with two

 

 19   recurrences versus 8 in 20 untreated controls.

 

 20   That is 40 percent, that is pretty impressive to

 

 21   me, but the p-value is only 0.06, and the authors

 

 22   themselves concluded that continuous prophylaxis is

 

                                                               136

 

  1   indicated only in patient with a high recurrence

 

  2   rate.

 

  3             There are other things you can do in these

 

  4   patients, such as giving them a prescription of

 

  5   antibiotic to have in their pocket in case they

 

  6   have the earliest signs at onset, they can

 

  7   frequently truncate the attacks.

 

  8             [Slide.]

 

  9             With that introduction, let's talk about

 

 10   tinea pedis and lower extremity cellulitis.  Here,

 

 11   I am really on very shaky grounds, because I am an

 

 12   infectious disease person, I am not a

 

 13   dermatologist, and I am going to quote some

 

 14   dermatologic literature, and it may or may not be

 

 15   current, so you guys can please straighten me out

 

 16   in the discussion period.

 

 17             I am quoting at least authority in the

 

 18   person of Dr. Albert Kligman, who published back in

 

 19   the 1970s the following:  that the recovery of

 

 20   fungi decreases as athlete's foot becomes

 

 21   progressively more severe; that aerobic microflora

 

 22   expands as the disease becomes more and more

 

                                                               137

 

  1   serious.

 

  2             Athlete's foot represents a continuum from

 

  3   a relatively asymptomatic, scaling fungal eruption

 

  4   to a symptomatic, macerated, hyperkeratotic process

 

  5   that results from the overgrowth of resident

 

  6   organisms if the stratum corneum is damaged by

 

  7   preexistent fungi.

 

  8             Overgrowth of the same organisms in

 

  9   normal, fungus-free interspaces does not produce

 

 10   lesions.

 

 11             [Slide.]

 

 12             In a more recent review in the Clinics in

 

 13   Podiatric Medical Surgery in 1996, the author made

 

 14   many of the same points.

 

 15             With progression of the process of

 

 16   dermatophytosis, the normal protective skin barrier

 

 17   becomes macerated and friable.

 

 18             As the process continues, the skin becomes

 

 19   debilitated and weakens as an effective barrier

 

 20   against infection.

 

 21             Fissures may occur, providing a portal of

 

 22   entry for any opportunistic organism in the area,

 

                                                               138

 

  1   resulting in cellulitis.

 

  2             [Slide.]

 

  3             Let's get on more specifically to tinea

 

  4   pedis and lower extremity cellulitis.

 

  5             This really dates back to the earliest

 

  6   studies that were published about saphenous

 

  7   venectomy and coronary artery bypass grafts and

 

  8   cellulitis.

 

  9             The first of the two studies that were

 

 10   published was that by Greenberg, et al., from Dr.

 

 11   Roman Kasankosis' group, and my own study with Dr.

 

 12   Larry Baddour, who was a fellow of mine, is now a

 

 13   professor at the Mayo Clinic, in the Annals of

 

 14   Internal Medicine in 1982.  I am not sure, sir, of

 

 15   you were the editor in 1982, but if you were, thank

 

 16   you for accepting the paper.

 

 17             Anyway, the initial studies focused upon

 

 18   patients who had undergone saphenous venectomy, and

 

 19   many of these infections were due to non-Group A

 

 20   beta-hemolytic streptococci, often B, C, or G, to

 

 21   the extent that you could get them.  In most cases

 

 22   of cellulitis, as you know, you don't get a

 

                                                               139

 

  1   microbiologic diagnosis.

 

  2             [Slide.]

 

  3             Of these two studies, Greenberg, et al.,

 

  4   really have precedence in terms of the tinea pedis

 

  5   issue because they described 9 men, age 48 to 72

 

  6   years, who developed cellulitis in the saphenous

 

  7   venectomy extremity.  Five of the 9 patients had

 

  8   recurrent episodes.

 

  9             The first infection was within 8 months

 

 10   post-op in 8 patients, but one was 8 1/2 years

 

 11   later.  I should interject here that actually, as

 

 12   we have had more experience with this, these things

 

 13   happen frequently months and many years afterwards.

 

 14   It is something that the cardiovascular surgeons

 

 15   never recognize because they don't see those

 

 16   patients at that point.

 

 17             Positive blood cultures in that study, in

 

 18   one patient, yielded beta-strep which weren't

 

 19   further characterized.

 

 20             All 9 had mild to severe tinea pedis of

 

 21   the involved leg, and they state there were no

 

 22   recurrences after aggressive topical or oral

 

                                                               140

 

  1   antifungal therapy.  That is all the information

 

  2   that is given, so we don't know how long it was

 

  3   given, how long it was followed, and that sort of

 

  4   thing.

 

  5             [Slide.]

 

  6             Dr. Baddour and I went back to our

 

  7   original studies and looked at our patients again,

 

  8   and we detailed 9 patients with post-CABG

 

  9   cellulitis, 5 of whom experienced from 2 to more

 

 10   than 20 recurrences.

 

 11             At the time were reported this in the

 

 12   1980s, it is amazing that clinicians were not

 

 13   recognizing this as cellulitis.  They were

 

 14   frequently thinking it was some sort of a deep

 

 15   venous thrombosis, and people were anticoagulated

 

 16   and all kinds of other things were done to them, so

 

 17   they ended up having many, many recurrences.

 

 18             But anyway, 7 of these patients had tinea

 

 19   pedis, and in 2 instances, control of

 

 20   dermatophytosis was associated with cessation of

 

 21   attacks.  I have to admit to you I can't remember

 

 22   now, 20 years later, how long we followed these

 

                                                               141

 

  1   patients, and they are only 2, so I am guilty of

 

  2   the same thing that I critiqued the last study for.

 

  3             [Slide.]

 

  4             Now, more recently, Dr. Semel and Goldin

 

  5   picked up on our work and did something very

 

  6   interesting, and their paper I think is included in

 

  7   the packet that you have.  They studied 20 patient

 

  8   with lower extremity cellulitis, but they excluded

 

  9   patients with trauma or peripheral vascular disease

 

 10   or chronic leg ulcers.  I am not sure why, but I

 

 11   suspect that those particular conditions are more

 

 12   likely to be associated with staphylococcal than

 

 13   with streptococcal infections.

 

 14             Anyway, they found athlete's foot present

 

 15   in 20 or 84 percent of the 24 episodes studied.

 

 16   Beta strep were isolated from ipsilateral two web

 

 17   spaces in 17 or 85 percent of the 20 cases.

 

 18             Then, they took 30 controls seen in a

 

 19   dermatologist's office for treatment of athlete's

 

 20   foot, but without cellulitis, and not a single one

 

 21   of them were they able to recover beta strep.  So,

 

 22   they concluded that only beta strep are recovered

 

                                                               142

 

  1   more frequently from patients than controls

 

  2             [Slide.]

 

  3             Now, I am going to quote a few other

 

  4   studies are less informative, but the literature is

 

  5   spotty in this regard.

 

  6             Thirty Venezuelan patients with erysipelas

 

  7   were reported, who were in otherwise good health.

 

  8   Forty-three percent of them had tinea pedis and in

 

  9   7 of 30 or 23 percent tinea pedis was found to be

 

 10   the unique predisposing factor, but there were no

 

 11   controls.

 

 12             Again, I don't know what the base

 

 13   prevalence of tinea pedis is in Venezuelan

 

 14   patients, is it 43 percent or is it 10 percent.  I

 

 15   don't have that information.

 

 16             [Slide.]

 

 17             Koutkia, et al., did a prospective but

 

 18   uncontrolled study of 62 hospitalized patients with

 

 19   cellulitis, and they identified a large number of

 

 20   possible predisposing factors here.  You can see

 

 21   that tinea pedis was present in 32 percent.  Again,

 

 22   with the data that we have presented this morning

 

                                                               143

 

  1   where the range of tinea pedis in normal

 

  2   populations can be 15 to 40 percent, is that a true

 

  3   association or not?  Again, it's an uncontrolled

 

  4   study.

 

  5             Interestingly enough, fully a quarter of

 

  6   the patients in their study were studied as

 

  7   post-CABG patients.

 

  8             [Slide.]

 

  9             The best study to date so far is the

 

 10   Dupuy, et al., study, and this is a case-controlled

 

 11   study of 167 patients hospitalized in 7 French

 

 12   hospitals for lower extremity cellulitis, and they

 

 13   compared it with 249 hospitalized controls.

 

 14             In a multivariate analysis, significant

 

 15   risk factors were disruption of the cutaneous

 

 16   barrier, such as ulcer, wounds, or dermatosis,

 

 17   lymphedema, venous insufficiency, leg edema and

 

 18   overweight.

 

 19             I should mention again obesity is a very

 

 20   powerful risk factor.  We just completed now a

 

 21   prospective case-controlled study of patient with

 

 22   recurrent cellulitis in which we found BMI was a

 

                                                               144

 

  1   highly strong predictor of cellulitis.  It was

 

  2   statistically significant with recurrent

 

  3   cellulitis.

 

  4             But at any rate, in Dupuy's study, toe-web

 

  5   intertrigo was present in 66 percent of patients

 

  6   and 23 percent of controls, for an odds ratio of

 

  7   6.6, and toe-web intertrigo was a strong risk

 

  8   factor, an odds ratio of 13.9 with a population

 

  9   attributable risk of 61 percent.

 

 10             [Slide.]

 

 11             I had a slide on the FDA adverse event

 

 12   reports, but I am not going to beat this dead horse

 

 13   since Dr. Schmidt has already woofed it to death,

 

 14   so I am not going to say any more about that.

 

 15             [Slide.]

 

 16             What are the unresolved issues that we

 

 17   have to deal with?  What is the risk of normal

 

 18   individuals with tinea pedis developing cellulitis

 

 19   at some time in their life?  We don't have any

 

 20   information on this whatsoever that I am aware of.

 

 21             Does the magnitude of risk justify a

 

 22   warning?  Certainly, if we don't know the magnitude

 

                                                               145

 

  1   of risk, we really can't say whether it justifies a

 

  2   warning, but I think the risk in normal individuals

 

  3   with tinea pedis has got to be extremely low.

 

  4   Again, we might have to stratify that as to what

 

  5   kind of tinea pedis are we talking about, are we

 

  6   talking about the kind of things we saw in the

 

  7   first slides with minor scaling, are we talking

 

  8   about really macerated toes, which I think may be

 

  9   an entirely different level of risk.

 

 10             Are the beta-hemolytic strep strains

 

 11   recovered from between the toes of patients with

 

 12   tinea pedis and cellulitis, such as those by the

 

 13   Semel and Goldin study, are those truly organisms

 

 14   responsible for cellulitis?  We don't know that.  I

 

 15   am unaware of reports of the same strain being

 

 16   recovered from toe cultures in cellulitis during a

 

 17   single attack of cellulitis, none in the literature

 

 18   that I know of.

 

 19             I personally have a case where I have

 

 20   recovered strep over about 10 years, three times,

 

 21   from a patient with tinea pedis and cellulitis, and

 

 22   looked at the M proteins under PCR, and, indeed,

 

                                                               146

 

  1   this is the same strain over and over, but was

 

  2   never recovered during the time of his acute

 

  3   illness.  Usually, these patients get whopped on

 

  4   antibiotics as soon as they get in, and you don't

 

  5   get positive cultures often from between the toes,

 

  6   so that is an unresolved issue.

 

  7             Another issue, unresolved issue, which I

 

  8   didn't put on this slide, is do we really have any

 

  9   idea whether treating tinea pedis will actually

 

 10   prevent recurrences.  I have given you all the data

 

 11   I know, and there are a couple of articles with

 

 12   observational data on a very small number of

 

 13   patients.

 

 14             Here is what we really need to do.  We

 

 15   really need to have a controlled trial of patients

 

 16   with athlete's foot to look at, in this controlled

 

 17   fashion, those who are well treated and those who

 

 18   aren't treated in terms of the incidence of

 

 19   cellulitis.

 

 20             But let's think about how you accomplish

 

 21   that. Obviously, in the general population, the

 

 22   incidence is so low that you would have to study

 

                                                               147

 

  1   thousands and thousands of patients for months to

 

  2   years, so you are not going to be able to do it.

 

  3             So, the best one would be patients with

 

  4   recurrent cellulitis.  There, you might have a

 

  5   chance, particularly with people with frequently

 

  6   recurrent cellulitis.  Then, you could have a

 

  7   controlled trial of treating the tinea pedis of

 

  8   patient with recurrent cellulitis and tinea pedis,

 

  9   and not treating it in another group of recurrent

 

 10   cellulitis and tinea pedis.

 

 11             You may have little problems with the

 

 12   Human Utilization Committee, but even if you could

 

 13   get it through there, you would only be studying

 

 14   probably one therapy or one therapeutic regimen.

 

 15   Again, you people have told me that half the time

 

 16   it is not going to work anyway, so I don't know how

 

 17   you can study this problem in a really effective

 

 18   manner, but certainly that is the kind of

 

 19   information we need and we don't have.

 

 20             [Slide.]

 

 21             So, what are the issues for the committee

 

 22   at this point?  Tinea pedis is only one of a number

 

                                                               148

 

  1   of risk factors for the development of lower

 

  2   extremity cellulitis, but one thing about it, it is

 

  3   one of the most modifiable of those factors, at

 

  4   least I thought it was before I walked in this room

 

  5   today.

 

  6             Now, the committee might wish to add a

 

  7   caution about the importance of eradication of

 

  8   tinea pedis in patients with such risk factors as

 

  9   lymphedema, venous insufficiency, edema of the

 

 10   legs, marked obesity, saphenous venectomy, or for

 

 11   CABG, or previous episodes of cellulitis.

 

 12             So, I would say that if you are going to

 

 13   do anything at all, the best you could do, at least

 

 14   in my humble opinion, is to put In at least a

 

 15   warning about the importance of assiduous treatment

 

 16   of tinea pedis in patients with these established

 

 17   risk factors.

 

 18             Thank you very much.

 

 19             DR. CANTILENA:  Thank you, Dr. Bisno.

 

 20             Questions from the committee for Dr.

 

 21   Bisno?  Yes, Dr. Epps.

 

 22             DR. EPPS:  I don't know whether it is more

 

                                                               149

 

  1   of a question or a comment.  Within the

 

  2   differential of a web space tinea pedis would be

 

  3   erythrasma, which is actually a bacterial

 

  4   infection.

 

  5             DR. BISNO:  Corynebacterium minutissimum.

 

  6             DR. EPPS:  Right.

 

  7             DR. BISNO:  I recently had a bacteremic

 

  8   patient with that, interestingly enough.

 

  9             DR. EPPS:  I wondered whether some of

 

 10   these cases of cellulitis, whether, in fact, they

 

 11   had tinea, whether they had erythrasma, and perhaps

 

 12   that could be an confounding issue.

 

 13             DR. BISNO:  I guess so, but look at the

 

 14   prevalence in the population of tinea pedis versus

 

 15   erythrasma.  I think there has got to be a

 

 16   magnitude of order difference.  I may be wrong

 

 17   about that, again, I am not a dermatologist.

 

 18             DR. CANTILENA:  Dr. Schmidt.

 

 19             DR. WHITMORE:  Dr. Bisno, I had a question

 

 20   for you regarding strep colonizing the skin.  It is

 

 21   not going to do that unless the integrity is

 

 22   disrupted, is that correct?

 

                                                               150

 

  1             DR. BISNO:  I am sorry?

 

  2             DR. WHITMORE:  Strep is not going to be

 

  3   growing in the skin unless the integrity of the

 

  4   skin is disrupted.

 

  5             DR. BISNO:  We used to think that, but it

 

  6   is not entirely true, and the way that we know that

 

  7   is in studies of children, underprivileged children

 

  8   with poor personal hygiene in areas where there is

 

  9   a lot of streptococcal pyoderma, and the studies by

 

 10   Wannamaker and Digianni and their associates in

 

 11   Minnesota many years ago showed that in those

 

 12   circumstances, you do get colonization of the skin

 

 13   with the pyoderma types of streptococci and then

 

 14   presumably due to trauma, abrasions, or insect

 

 15   bites, it gets converted into pyoderma.

 

 16             So, at least in certain instances, it

 

 17   could colonize normal skin, but generally, I think

 

 18   in general the answer is you wouldn't expect that

 

 19   to be part of the normal flora in a population of

 

 20   people who weren't underprivileged or who were able

 

 21   to maintain normal hygiene.

 

 22             DR. WHITMORE:  The only reason I ask that

 

                                                               151

 

  1   is because if that were true, which apparently it

 

  2   is not, then, we could select out patients who have

 

  3   disrupted skin, who are then actually put at risk

 

  4   for cellulitis because of their tinea, such as

 

  5   cracking in the web space or vesicular bullous on

 

  6   the foot where there is disruption.

 

  7             DR. BISNO:  That is a possibility.  I mean

 

  8   it seems to me that even with those strictures, you

 

  9   are going to be treating an awful lot of people.

 

 10   Of course, you would be treating those patients

 

 11   anyway, so I guess that would be fine, you would be

 

 12   wanting to do that anyway.

 

 13             DR. SCHMIDT:  My clinical impression is

 

 14   that treating these things does help the tinea, but

 

 15   the biggest problem that we see clinically, at

 

 16   least in Houston, is many of these people are these

 

 17   massively obese female who are completely immobile,

 

 18   and I don't really think that these people who have

 

 19   these recurrent cellulitises, at least in my

 

 20   experience, really live that long, you know, that

 

 21   there is something else that kills them, usually

 

 22   the obesity.

 

                                                               152

 

  1             I have one other question.  When you said

 

  2   obesity, you used the term--in Texas, we use TDF,

 

  3   too damn fat--but you said DMI.

 

  4             DR. BISNO:  Body mass index.

 

  5             DR. SCHMIDT:  Oh, that sounds a lot

 

  6   better.  Thank you.

 

  7             DR. CANTILENA:  We should probably strike

 

  8   that from the transcript, just so we don't get in

 

  9   trouble with Texas.

 

 10             DR. BISNO:  I think you have identified

 

 11   one group, that is for sure, but there are lots of

 

 12   other people who don't have those, particularly

 

 13   saphenous venectomy group, people who have had,

 

 14   let's say, nodal dissections for cancer and have

 

 15   chronic lymphedema.

 

 16             There are a number of other factors, and

 

 17   another area that we are seeing a lot of problems

 

 18   with, as I alluded to in one of the case

 

 19   discussions is the homeless, because they are out

 

 20   there, they can't really maintain good personal

 

 21   hygiene, they have horrible feet, and they are at

 

 22   risk for this, so I think that obese, and I

 

                                                               153

 

  1   wouldn't necessarily--I don't know about the sexual

 

  2   predilection for obesity, you know, we see obese

 

  3   men, too--and I work at the VA a lot.

 

  4             At any rate, I think obesity is certainly

 

  5   a major issue, but I don't think it's the only

 

  6   issue.

 

  7             DR. CANTILENA:  Yes, Dr. Davidoff.

 

  8             DR. DAVIDOFF:  One of the predisposing

 

  9   factors that is not on your second slide is

 

 10   diabetes, and yet, as a former diabetologist, I was

 

 11   a little surprised because certainly one of the

 

 12   great concerns of diabetologists and podiatrists is

 

 13   foot infection.  Perhaps you could comment on that.

 

 14             DR. BISNO:  Where something like

 

 15   controlled studies have been done on this, as in

 

 16   the DuPuy study, and actually even in our

 

 17   prospective case-controlled study, a lot of things

 

 18   you can't see in hospital records, but diabetes you

 

 19   certainly can, and it hasn't emerged as an

 

 20   independent risk factor.

 

 21             So, yes, I agree, I am always worried

 

 22   about diabetes, and I am always worried more

 

                                                               154

 

  1   staphylococcal and streptococcal infections, but

 

  2   nevertheless, I was careful not to say that because

 

  3   I don't have the data to back it up.

 

  4             DR. CANTILENA:  Go ahead, Dr. Fincham.

 

  5             DR. FINCHAM:  I was also curious about

 

  6   that because you did reference the Koutkia article

 

  7   that listed 50 percent diabetes.

 

  8             DR. BISNO:  That is the percentage in the

 

  9   general population.  I mean yes, I think we all

 

 10   have a feeling, a gut feeling that diabetes is a

 

 11   bad thing for infection and for the feet, but in

 

 12   terms of these kinds of infections, I don't have a

 

 13   chapter and verse to be able to state that.

 

 14             DR. CANTILENA:  Thank you, Dr. Bisno, a

 

 15   very excellent presentation.

 

 16             Our next speaker this morning would be Dr.

 

 17   Ghannoum who is from Case Western Reserve

 

 18   University talking about the microbiology aspect.

 

 19             Microbiology and Dermatophyte Resistance

 

 20             Related to the Treatment of Tinea Pedis

 

 21             DR. GHANNOUM:  Good morning, everybody,

 

 22   and thank you for inviting me to participate in

 

                                                               155

 

  1   this session.

 

  2             What I am going to try to talk to you

 

  3   today is about really the knowledge we have as far

 

  4   as antifungal susceptibility is concerned.  Again,

 

  5   this is really a new field, and I am going to

 

  6   present to you a lot of the data which was

 

  7   generated in the last, I would say five or so

 

  8   years.

 

  9             [Slide.]

 

 10             I thought I would put my conflict of

 

 11   interest at the beginning.  I direct the Center for

 

 12   Medical Mycology and I would say the vast majority

 

 13   of companies that do work with antifungals, we work

 

 14   with them as part of grants and contracts.

 

 15             Also, I act sometimes as consultant and

 

 16   speaker's bureau member for different companies, so

 

 17   it is not like one particular company, and I

 

 18   thought I would point to some of the relevant

 

 19   companies which we had grants, contracts, or

 

 20   speaker's bureau listed here.

 

 21             [Slide.]

 

 22             Let's talk now about antifungal agents and

 

                                                               156

 

  1   resistance.  As you know, in recent years, there

 

  2   are a number of compounds which have been

 

  3   introduced to treat fungal infections, and these

 

  4   are quite efficacious compounds, they work very

 

  5   well including the classes of allylamines and

 

  6   azoles, and really this is very, very good news as

 

  7   far as treating superficial infections.

 

  8             However, like with the introduction of any

 

  9   antimicrobial, the likelihood or the potential of

 

 10   resistance development is there.

 

 11             This has been very clearly illustrated

 

 12   when we look at systemic infections particularly

 

 13   with Diflucan or fluconazole when it was

 

 14   introduced.

 

 15             [Slide.]

 

 16             I did a literature search, just to give

 

 17   you an idea when resistance usually occurs.  I did

 

 18   a Medline search when the drug is introduced, and

 

 19   then a number of papers on resistance that came out

 

 20   after an introduction of the drug.  You notice

 

 21   like, for example, 5FC was introduced around here,

 

 22   then, you see this is the total papers on

 

                                                               157

 

  1   antifungal resistance increases.

 

  2             The same, you put miconazole,

 

  3   ketoconazole, again, you see the blips, and

 

  4   fluconazole or terconazole, again, you can see I

 

  5   would say resistance is reported about two years

 

  6   after the introduction of new antifungal agents.

 

  7             However, most of these studies I focused

 

  8   on are systemic antifungals, because really we

 

  9   don't have many papers, actually, we have nearly

 

 10   none that address this issue.

 

 11             [Slide.]

 

 12             I want now to focus a little bit on the

 

 13   dermatophytes.  In spite of the wide clinical use

 

 14   of topical antifungal agents, also agents to treat

 

 15   dermatophytosis, very little data is available on

 

 16   the antifungal susceptibility, as I just alluded

 

 17   to.

 

 18             This is possibly due to the fact that we

 

 19   really do not have a method, which is reference

 

 20   method documented that can measure antifungal

 

 21   susceptibility, and this is not a surprise.  We had

 

 22   the same situation with systemic antifungal agents

 

                                                               158

 

  1   for 30 or 35 years.

 

  2             We only had amphotericin B, so you really

 

  3   don't need to do this, however, when we start

 

  4   seeing the new agents, then, there was a need for

 

  5   developing a method, and the same thing is true

 

  6   when we talk about the topical antifungals.

 

  7             Griseofulvin was the one and now we have

 

  8   the classes of compounds that are also there.

 

  9   Because of this, there is really a need to develop

 

 10   a method.

 

 11             [Slide.]

 

 12             With that in mind, what we did in my group

 

 13   at the Center for Medical Mycology in Cleveland, in

 

 14   1998, we started to put a program to develop a

 

 15   method for measuring antifungal susceptibility.

 

 16             The compounds which we focused on are to

 

 17   dermatophytes.  These are the compounds which we

 

 18   focused on - terbinafine, griseofulvin,

 

 19   intraconazole, and fluconazole.

 

 20             [Slide.]

 

 21             As a result of this program, we published

 

 22   two papers on them, Norris, et al., and Jessup, et

 

                                                               159

 

  1   al.  In these articles, we were able to determine

 

  2   that optimal conditions for doing antifungal

 

  3   susceptibility.  The method is microdilution

 

  4   method, what type of media used, the inoculum,

 

  5   really all what you need if you want to do the

 

  6   proper antifungal susceptibility as dermatophytes

 

  7   are concerned.

 

  8             Once those papers are published, I am a

 

  9   member of the NCCLS, the National Committee for

 

 10   Clinical Laboratory Standards, I was asked to

 

 11   really head the group to develop antifungal

 

 12   susceptibility to the dermatophytes.

 

 13             [Slide.]

 

 14             Under the auspices of the NCCLS, we did a

 

 15   number of studies.  The first one was a intra- and

 

 16   inter-laboratory multicenter study to determine

 

 17   whether the developed method is really reproducible

 

 18   by other people in a way to try to form a document

 

 19   for that.

 

 20             Also, currently, we are conducting a

 

 21   quality control study to define some organisms, so

 

 22   that labs, when they want to do this, they have

 

                                                               160

 

  1   their QC isolates and they will be able to really

 

  2   know that the method they are performing is the

 

  3   right one.

 

  4             This is in preparation for our next

 

  5   meeting in January 2005.  That is when the NCCLS

 

  6   for antifungal agents meet.  We hope to have all

 

  7   this method approve and become part of the document

 

  8   M38.

 

  9             [Slide.]

 

 10             Once the method was developed, we started

 

 11   asking the question is there a resistance issue as

 

 12   far as dermatophytes are concerned.  With that, we,

 

 13   at the Center, we started really monitoring the

 

 14   antifungal susceptibility of dermatophytes.

 

 15             We had a number of dermatophytes.  We

 

 16   collected isolates where they come from different

 

 17   sources.  We had a set of isolates, sequential

 

 18   isolates obtained from patient with onychomycosis.

 

 19   They were enrolled in part of the clinical trial.

 

 20             We had routine clinical specimens.  Our

 

 21   lab received specimens from about 400, 500

 

 22   physicians, where we identified isolates through

 

                                                               161

 

  1   KOH, and this sort of thing, so we collected those

 

  2   also.

 

  3             We were the central lab for clinical

 

  4   trials for some topical agents, also those

 

  5   organisms, and finally, we did a couple of

 

  6   epidemiological studies, one on onychomycosis and

 

  7   one recently in tinea capitis, and we collected

 

  8   also those isolates.  These have been published in

 

  9   the American Journal of Dermatology, and this one

 

 10   also.

 

 11             In total, we have over 2,000 isolates

 

 12   which we tested.

 

 13             [Slide.]

 

 14             I am going to share with you some of the

 

 15   data we collected over the last few years.

 

 16             This is the dermatophytes which we

 

 17   collected from epidemiological studies, the two

 

 18   epidemiological studies that we mentioned.  This is

 

 19   the organism, rubrum, mentagrophytes, tonsurans,

 

 20   and canis, and this is the number of each species,

 

 21   in total 117 isolates were collected.

 

 22             This is the terbinafine susceptibility,

 

                                                               162

 

  1   and you can see this is the MIC in microgram per

 

  2   ml.  It went from less than 0.001 to 0.004, and you

 

  3   can see really 95 percent of the isolates were

 

  4   inhibited by 0.002 micrograms per ml, so it is

 

  5   quite good activity.

 

  6             [Slide.]

 

  7             This is the same isolates.  We looked at

 

  8   fluconazole, who did it do.  Again, you can see

 

  9   this is a broader range really of MICs, but I would

 

 10   say the vast majority could be inhibited from here

 

 11   to here, 0.5 to 4 micrograms per ml.

 

 12             A few isolates had I would say susceptible

 

 13   dose dependent sort of MICs, two and four of them

 

 14   had 16 or 32 micrograms per ml.

 

 15             [Slide.]

 

 16             We looked at itraconazole.  Itraconazole

 

 17   did I think the same, a good job.  The vast

 

 18   majority of organisms are inhibited within this

 

 19   range.  We had got 7 and like 8 isolates, 0.5 and

 

 20   1, which usually at least in the yeast area,

 

 21   because we had developed breakpoints, you would say

 

 22   maybe you suspect a little bit resistance, but this

 

                                                               163

 

  1   is a very, very big maybe, because we don't have

 

  2   breakpoints developed for dermatophytes.

 

  3             [Slide.]

 

  4             Now, this is for griseofulvin.  Again,

 

  5   these are from the epidemiological studies, and you

 

  6   see the vast majorities are quite susceptible and

 

  7   they responded well.

 

  8             [Slide.]

 

  9             Now, I move into some isolates which we

 

 10   got from the clinical trials, so really some of

 

 11   them saw patients, others did not see patients or

 

 12   the epidemiological part.

 

 13             The same picture could be painted.  You

 

 14   can see here for terbinafine, again look at this.

 

 15   Really, the vast majority are within what we

 

 16   expect.

 

 17             [Slide.]

 

 18             This is fluconazole.  Again, we see the

 

 19   same sort of susceptibility.  There is nothing that

 

 20   is up there.

 

 21             [Slide.]

 

 22             With itraconazole, the same story. 

 

                                                               164

 

  1   Remember I told you about 0.5 and 1, some isolates

 

  2   tend to be a little bit high, but not too high.

 

  3             [Slide.]

 

  4             With griseofulvin, we saw something a

 

  5   little bit more interesting, because unlike the

 

  6   isolates which came from the epidemiological study,

 

  7   we see a number here 22 and 5 isolates with MIC,

 

  8   which I would say higher than what we saw from

 

  9   epidemiologic.

 

 10             So, there is some feeling here that at

 

 11   least griseofulvin, the MIC is going up a little

 

 12   bit, and this had been observed by a colleague of

 

 13   mine in his study from New York Labs, where he

 

 14   showed that there is a little bit of increase in

 

 15   MIC against griseofulvin.

 

 16             [Slide.]

 

 17             Now, putting everything together for

 

 18   terbinafine, 1,300 isolates, and you can see the

 

 19   range of MIC, less than 0.001 to 0.25, and MIC50,

 

 20   which is the minimum inhibitor concentration that

 

 21   inhibited 50 percent of isolates, 0.002 and 0.015,

 

 22   the concentration that inhibited 90 percent of

 

                                                               165

 

  1   isolates.  So, in general, I would say it is quite

 

  2   active.

 

  3             [Slide.]

 

  4             This is the same story, but in a histogram

 

  5   format, and I am showing you about fluconazole.

 

  6   This is cumulative data, putting everything

 

  7   together, and you can see T. rubrum, T.

 

  8   mentagrophytes, and I would say here is where the

 

  9   crux of the isolates, most of them are inhibited.

 

 10             [Slide.]

 

 11             Itraconazole, we saw those here at 0.5 and

 

 12   1, a little bit higher.

 

 13             [Slide.]

 

 14             Griseofulvin, the same thing.  These are

 

 15   isolates which tend to be a little bit higher.

 

 16             [Slide.]

 

 17             To summarize this part of the talk, I

 

 18   would say that all the antifungal agents we looked

 

 19   at, fluconazole, griseofulvin, itraconazole, and

 

 20   terbinafine are active against the tested

 

 21   organisms.

 

 22             Really, no resistance to these drugs was

 

                                                               166

 

  1   detected, a question mark about griseofulvin.

 

  2             Now, terbinafine, when you compare

 

  3   everything as far as the level of MIC, I would say

 

  4   showed the most potent antifungal activity relative

 

  5   to the other agents.

 

  6             Now, some clinical isolates I mentioned

 

  7   had a little bit of elevated MIC to griseofulvin.

 

  8             [Slide.]

 

  9             We then focused a little bit more on a

 

 10   subset of isolates.  Remember those were about

 

 11   1,300.  We looked at the total number, we continued

 

 12   with terbinafine.  What we found is 99.4 percent of

 

 13   the isolates tested, they had an MIC listed as 0.06

 

 14   micrograms per ml.

 

 15             However, we detected a set of sequential

 

 16   isolates.  You remember I told you we had some

 

 17   isolates from the same patient over a period that

 

 18   had elevated MICs.  Because of this, we focused on

 

 19   them and we wanted to try to understand.

 

 20             [Slide.]

 

 21             Now, these isolates came from a clinical

 

 22   trial that has 1,500 patients.  They were treated

 

                                                               167

 

  1   to determine the efficacy and safety of oral

 

  2   terbinafine.  The selection criteria for this was

 

  3   culture positive at the initial visit.  In between,

 

  4   it could be at least in one or more visits, the

 

  5   positive culture also, and then at the end of the

 

  6   study, the culture was positive, as well, so

 

  7   obviously, we did not get rid of the culture.

 

  8             Now, in total, we had 38 patients positive

 

  9   for T. rubrum throughout the study.  We again

 

 10   focused on these and we looked at the number of

 

 11   organisms.  It was 140 sequential isolates from

 

 12   these 38 patients.

 

 13             [Slide.]

 

 14             Then, we wanted to know why are these

 

 15   patients failing.  The answer could be one of these

 

 16   three possibilities.  It could be due to decrease

 

 17   in antifungal susceptibility of the infecting

 

 18   organism, MIC going higher.

 

 19             It could be due to reinfection with a new

 

 20   genetically unrelated strain, or it could host

 

 21   factors.

 

 22             [Slide.]

 

                                                               168

 

  1             So, we started to answer each of these

 

  2   questions.

 

  3             First, is there a decrease in antifungal

 

  4   susceptibility of the sequential isolates?  We had

 

  5   140 isolates.  We did MIC for them, and what we

 

  6   found in all cases, the MIC of terbinafine from

 

  7   each patient set were either identical or within

 

  8   one tube dilution.  When there is one tube

 

  9   dilution, really, there is no difference, so I

 

 10   would say they are identical at least if you look

 

 11   at any of the MIC, that one to two tube dilutions

 

 12   are not considered significantly different.

 

 13             The same results were obtained within each

 

 14   set against the other drugs, fluconazole,

 

 15   itraconazole, and griseofulvin, showing you that

 

 16   there is no cross-resistance. All of them were

 

 17   actually susceptible.

 

 18             One exception we noted was where one

 

 19   organism, griseofulvin had a MIC 3-fold increase.

 

 20             [Slide.]

 

 21             Now, this is just to show you--I am not

 

 22   going to give all the data--just a representative

 

                                                               169

 

  1   example, and here we have MIC against flu, itra,

 

  2   terb, and griseo.  You can see low and the same.

 

  3   We did not see an increase as these patients were

 

  4   treated for the 12-week period.

 

  5             [Slide.]

 

  6             However, one patient had the sequential

 

  7   isolate that had elevated MIC out of the 38.  Look

 

  8   at this.  This was published by my group in

 

  9   Antimicrobial Agents and Chemotherapy last year.

 

 10             These are the different isolates at

 

 11   different visits, and here we put two isolates

 

 12   which are really standard, just to make sure we, as

 

 13   you said, quality control and they are susceptible

 

 14   to terbinafine.

 

 15             You can see here we used two different

 

 16   methods, macrodilution method and microdilution

 

 17   method, to measure the MIC.  At the very front, 4

 

 18   microgram per ml, and remember most of the

 

 19   isolates, really 99.4 percent of the isolates had

 

 20   an MIC of 0.002.  So, this is a significant

 

 21   increase in MIC.

 

 22             When you look at using the microdilution

 

                                                               170

 

  1   method, all the isolates had elevated MIC.  Using

 

  2   another method, the macrodilution, it made it even

 

  3   more interesting where at the beginning it was 4,

 

  4   but by the end of the study, the MIC microgram per

 

  5   ml was greater than 128, so it increased.

 

  6             So, that really puzzled us, and we wanted

 

  7   to know more.

 

  8             [Slide.]

 

  9             But before I go into these, I just want to

 

 10   conclude about the 38 patients.  Patient failure is

 

 11   not due to a decrease in antifungal susceptibility,

 

 12   because MICs were very similar, only one exception

 

 13   where all six isolates of T. rubrum were found to

 

 14   have greatly reduced susceptibility.  These, we

 

 15   analyzed them a little bit further.

 

 16             [Slide.]

 

 17             We wanted to know is there

 

 18   cross-resistance to other classes of antifungals.

 

 19   Suppose something happens and we have high MIC for

 

 20   something, does it go across to other drugs.  The

 

 21   answer is really put simply no.  Here, we see at

 

 22   least the azoles type of compound and griseofulvin.

 

                                                               171

 

  1   Look at the MIC, the same sequential isolate.  It

 

  2   is about the same irrespective of where it came

 

  3   from.

 

  4             [Slide.]

 

  5             When you look at other compounds in the

 

  6   same class, which is allylamine, we wanted to ask

 

  7   the question is there cross-resistance to other

 

  8   squalene epoxidase inhibitors., and for this we

 

  9   used again our control.  This we know is

 

 10   susceptible to all these agents, 0.002, so it is

 

 11   obviously susceptible, however, look at this.

 

 12             The naftifine, butenafine, tolnaftate, and

 

 13   tolciclate, they all had high numbers indicating

 

 14   that there is a cross-resistance to squalene

 

 15   epoxidase.

 

 16             [Slide.]

 

 17             Now, the question then, is it possible

 

 18   that the patient got infected with another strain,

 

 19   which was more resistant, so we looked at that.  We

 

 20   wanted to do genetically related studies to see

 

 21   whether they are the same or not.

 

 22             So, we performed RAPD analysis, which is

 

                                                               172

 

  1   random amplified polymorphic DNA analysis.

 

  2             [Slide.]

 

  3             I am not going to bore you with the

 

  4   method.  This is standard method.  This is how you

 

  5   extract the DNA.  This is how you do the analysis,

 

  6   you know, just to give you the cycle PCR, and this

 

  7   sort of thing, so I am not going to go over that.

 

  8             [Slide.]

 

  9             I am going to just show you the results of

 

 10   that.

 

 11             This shows you, this is the letter, and

 

 12   this is the standard ATCC just to make sure we have

 

 13   T. rubrum, and if you look at the other lanes, they

 

 14   are all very similar, indicating that the isolates

 

 15   obtained at sequential visits represented a single

 

 16   T. rubrum isolate, so it is not something which

 

 17   came new.

 

 18             [Slide.]

 

 19             The last possibility is, is it possible

 

 20   that the patient failure is due to host-related

 

 21   factors?

 

 22             To do that, we know, as I told you, this

 

                                                               173

 

  1   is part of the clinical trial, so the clinical data

 

  2   was all available, it was reviewed, and for the 38

 

  3   patients who failed, found the following points

 

  4   which we thought could be really host related.

 

  5             The first one, they had all these

 

  6   patients, the 38, 53 percent of them have a history

 

  7   of prior use of antifungals, so they have been

 

  8   using antifungals for a long time.

 

  9             Family history of onychomycosis, 60

 

 10   percent of patients had one or more member of their

 

 11   family with history of onychomycosis.  Does it mean

 

 12   that they are genetically predisposed?  I think a

 

 13   lot of people ask this question.  I think maybe

 

 14   there is some truth to it, but unfortunately, we

 

 15   don't have the study that proved it.

 

 16             The last one, 70 percent were over 45

 

 17   years old.  I am not saying this is old, I passed

 

 18   that a long time ago, but in a study which we

 

 19   published with Boni Elewski, what we did, we looked

 

 20   at patients who are 53 years old and compared them,

 

 21   and we found that people are more predisposed to

 

 22   have onychomycosis if they are 53 years and older

 

                                                               174

 

  1   compared to those 53 years and younger.

 

  2             With that in mind, age is really a

 

  3   contributing factor.

 

  4             [Slide.]

 

  5             Summary.  Our data indicate that the

 

  6   failure of patients to clear onychomycosis is not

 

  7   related to resistance development with one

 

  8   exception, that patient which we analyzed.  Not due

 

  9   to reinfection with a new T. rubrum strain, and may

 

 10   be attributed to host-related factors including

 

 11   family history of onychomycosis, prior antifungal

 

 12   treatment, an age.

 

 13             So, now I am going to try to put

 

 14   everything together is these last two slides.

 

 15             [Slide.]

 

 16             Where are we with dermatophyte

 

 17   susceptibility?  I can tell you a method to measure

 

 18   antifungal susceptibility is now established,

 

 19   unlike before which we didn't have.

 

 20             Only a few studies using this method have

 

 21   addressed whether resistance existed or not, which

 

 22   some of it you just saw.

 

                                                               175

 

  1             Based on these studies, the resistance, I

 

  2   don't believe it is a problem, most compelling data

 

  3   at least for terbinafine, which I shared with you.

 

  4             There is a lack of data concerning the

 

  5   susceptibility profile of agents.  The method is

 

  6   new, nobody used it and look at it.  We don't have

 

  7   that.

 

  8             For dermatophytes, unlike for yeasts, the

 

  9   in vitro-in vivo correlation is also lacking, like

 

 10   we need a lot of data from MIC and clinical data,

 

 11   and try to see is there a correlation with the in

 

 12   vitro data and the in vivo. We did this for the

 

 13   yeast, and it was published as part of the NCCLS.

 

 14             There is no breakpoints established for

 

 15   any of the drugs, the breakpoints which can tell

 

 16   you let's say 60 microgram is resistant, less than

 

 17   it's susceptible.  We don't have that for

 

 18   dermatophytes.  Obviously, the committee

 

 19   established it for the yeast.

 

 20             Now, information about the mechanism of

 

 21   resistance is also not available.  These strains

 

 22   which I talked to you obviously we did some

 

                                                               176

 

  1   molecular studies, and we believe there is a

 

  2   mutation in the squalene epoxidase.  This stuff is

 

  3   not published yet, but that's about the information

 

  4   as far as that is available for us on the mechanism

 

  5   of resistance.

 

  6             [Slide.]

 

  7             What needs to be done?  This is just me

 

  8   sitting trying to think, okay, what do you think

 

  9   should be done.  Of course, it is up to the

 

 10   committee to decide what they want to do.

 

 11             We need to establish baseline data

 

 12   concerning antifungal agents, which will also allow

 

 13   us to observe trends.  If we have a baseline at

 

 14   least for the compounds which are available, we

 

 15   know what is now, we can look after two, three

 

 16   years, and that could give us information whether

 

 17   there is an increase in MIC or not.

 

 18             Surveillance studies to determine the true

 

 19   frequency of antifungal resistance also should be

 

 20   implemented.

 

 21             Studies to establish in vitro-in vivo

 

 22   correlation should be undertaken.  Sometime this

 

                                                               177

 

  1   could be done in animal models at the beginning

 

  2   where you see there is strain with high MIC,

 

  3   another strain with low MIC.  You infect animal,

 

  4   treat them, and then see whether it worked or not

 

  5   based on the susceptibility.

 

  6             Data should be collected on both clinical

 

  7   and MIC from patients treated with various agents

 

  8   in an effort to establish breakpoints for different

 

  9   agents.

 

 10             Finally, I believe MIC data using the

 

 11   developed method should be collected as part of the

 

 12   drug approval study.  At least we know where the

 

 13   agent is.

 

 14             [Slide.]

 

 15             These are the people in my lab who did the

 

 16   work I just presented.  Mary Bradley, who did the

 

 17   DNA typing and followed the sequential.  Nancy

 

 18   Isham, a lot of the data which I showed you, she

 

 19   did it.  Steve Leidich is the molecular biologist

 

 20   who really tried to understand the fact that we

 

 21   have mutation at the squalene epoxidase.  Pranab

 

 22   Mukherjee also was helpful in the biochemical

 

                                                               178

 

  1   characterization of these isolates.

 

  2             Thank you very much.

 

  3             DR. CANTILENA:  Thank you, Dr. Ghannoum.

 

  4             Any questions from the committee?  Dr.

 

  5   Katz.

 

  6                       Committee Discussion

 

  7             DR. KATZ:  That's a very nice

 

  8   presentation.  I just have one comment and one

 

  9   question.  The comment, as far as patient failure

 

 10   and host susceptibility, and you question genetics,

 

 11   there is work showing people, not with

 

 12   onychomycosis, but with tinea pedis, with having

 

 13   defective delayed hypersensitivity to Trichophyton

 

 14   antigen in people who have familial tinea pedis,

 

 15   clinically, right through four generations getting

 

 16   tinea pedis.

 

 17             So, that's in the literature some 20, 30

 

 18   years ago.

 

 19             DR. GHANNOUM:  I just would comment I

 

 20   think Nadir Ziaz and Tozzi from Italy, yes, I

 

 21   agree.

 

 22             DR. KATZ:  My question on page 13,

 

                                                               179

 

  1   characterization of the sequential T. rubrum

 

  2   isolates with elevated MICs, I wondered whether you

 

  3   note any clinical correlation with those with high

 

  4   MICs, treatment failures or anything different

 

  5   clinically.

 

  6             Was that done or was it a laboratory--

 

  7             DR. GHANNOUM:  What we did was purely

 

  8   laboratory, but then we went and looked at the

 

  9   clinical data after this and tried to find a

 

 10   correlation, and really, the only factors which we

 

 11   found, as I said, age, and so on, but there was

 

 12   nothing.

 

 13             DR. KATZ:  No correlation of failure?

 

 14             DR. GHANNOUM:  Not as much, no.

 

 15             DR. CANTILENA:  Thank you.

 

 16             Dr. Wood.

 

 17             DR. WOOD:  I guess my questions are

 

 18   directed sort of where we may end up going towards

 

 19   labeling.  I have I suppose a genetic resistance to

 

 20   including stuff in labeling for which there is not

 

 21   good data to support it.

 

 22             So, I have a number of questions that

 

                                                               180

 

  1   occurred to me in listening to this.

 

  2             The first one is are there any data that

 

  3   support a relationship between MIC or other

 

  4   laboratory-measured resistance and outcome in terms

 

  5   of efficacy in therapy.  The reason I think that is

 

  6   critical is that the data you show, shows most of

 

  7   these isolates respond to less than 0.002

 

  8   micrograms per ml, and this is a 1 percent topical

 

  9   application, so even if you move one order of

 

 10   magnitude, you are still vastly below the

 

 11   concentrations that the organisms are exposed to.

 

 12             So, the first question is are there data

 

 13   that show a relationship between resistance and

 

 14   outcome, and how rigorous is that given the

 

 15   efficacy data that we saw earlier, which is not

 

 16   terrific.

 

 17             DR. GHANNOUM:  I think this is a good

 

 18   question.  The data as far as dermatophytes are

 

 19   concerned, I don't think they exist, as I said, but

 

 20   we have data where there is an in vitro-in vivo

 

 21   correlation for Diflucan, for example, and

 

 22   oropharyngeal candidiasis, and that was published

 

                                                               181

 

  1   by the NCCLS in Journal of Clinical Microbiology.

 

  2             Based on that data, we had breakpoints.

 

  3   This has not been done for dermatophytes, so

 

  4   obviously, we need to have this collected, but that

 

  5   data is robust, it was 600 patients.  It showed

 

  6   that--I can give you an example with fluconazole.

 

  7             If the MIC is less or equal to 8

 

  8   micrograms per ml, then, you consider it

 

  9   susceptible, and the success rate was 90 percent.

 

 10   If you go down in the MIC, let's say greater or

 

 11   equal to 64, then, the outcome is about 60 percent

 

 12   success rate.

 

 13             Now, obviously, fungal infections, that is

 

 14   one which is very important for us to consider, the

 

 15   disease of immunocompromise.  These patients, even

 

 16   sometimes if you have a good correlation, it is not

 

 17   necessarily that you are going to see success

 

 18   because we have so many underlying factors which

 

 19   need to be taken into consideration.

 

 20             DR. WOOD:  Well, 60 percent is still a lot

 

 21   better than the outcome in the clinical trials on

 

 22   Slide 19.

 

                                                               182

 

  1             DR. GHANNOUM:  Yes.

 

  2             DR. WOOD:  The second point relates to my

 

  3   fear that some of this might appear in labeling.

 

  4   Most of the host factors that you cite sort of

 

  5   relate to a potentially circular argument, so the

 

  6   fact that you have treated yourself before with an

 

  7   antifungal may reflect the fact you didn't respond

 

  8   to an antifungal before.

 

  9             It may reflect even the fact that you

 

 10   don't have a fungal infection, and you didn't

 

 11   respond last time, and you don't respond this time,

 

 12   and so on.  I mean I could go through it, lots of

 

 13   examples, but I think we have to be careful in

 

 14   taking relationships that are not well documented

 

 15   and including these as host factors that may affect

 

 16   response to therapy when these are not part of a

 

 17   randomized trial or appropriately controlled for.

 

 18             DR. GHANNOUM:  First of all, I go from the

 

 19   back.  I agree with you that it is very important

 

 20   to do more of these and collect the data.  The data

 

 21   which I showed you is really what is available, and

 

 22   that is the best thing we could do because we had a

 

                                                               183

 

  1   set of isolates from patients who were enrolled in

 

  2   clinical trial, and we had the clinical data, so

 

  3   that is the best case scenario.

 

  4             Now, one thing is really clear.  In the

 

  5   dermatology literature, really sometimes people

 

  6   don't even do KOH or culture, and then they go and

 

  7   treat, or they go sometimes and they say, look at

 

  8   their feet, and we know, for example, although I

 

  9   know we are talking about tinea pedis, but let's

 

 10   say onychomycosis, 50 percent of the time the cause

 

 11   of infection is nonfungal.

 

 12             Again, here, I am sure there are some

 

 13   other differential diagnosis which is included, but

 

 14   if the treating physicians don't do the

 

 15   identification and the KOH, and then you are right,

 

 16   maybe they don't have that, but at least with the

 

 17   limited amount of data, that is what I can say.

 

 18             DR. CANTILENA:  Thank you.

 

 19             Dr. Benowitz.

 

 20             DR. BENOWITZ:  To follow up on the

 

 21   comments of Dr. Wood, it would seem to me, since

 

 22   the concentrations are so high topically, it should

 

                                                               184

 

  1   never be a resistance issue, and one thing, I am

 

  2   not sure it was your presentation or someone

 

  3   else's, the question of just access, are these

 

  4   topical preparations, is the drug getting to the

 

  5   fungus, or is there some sort of barrier in the

 

  6   skin or the keratin or something, why are we not

 

  7   seeing 100 percent mycological cure in a week if

 

  8   you are giving such high concentrations to

 

  9   susceptible fungi.

 

 10             DR. GHANNOUM:  I think, as far as the

 

 11   access is concerned, there are some studies where

 

 12   they showed that there is skin level.  Let's say,

 

 13   for example, I know for at least two compounds,

 

 14   itraconazole and terbinafine, there are some

 

 15   studies by Fagerman where he showed they take, you

 

 16   know, the skin shaving, and they were able to

 

 17   isolate the drug, and the drug is there, so I think

 

 18   it is reaching there.

 

 19             Now, why they are not doing it, is it the

 

 20   patient compliance, is it the fact that there are

 

 21   other underlying diseases?  I think this needs to

 

 22   be addressed, so I have no idea.

 

                                                               185

 

  1             DR. CANTILENA:  Thank you.

 

  2             Dr. Wilkerson.

 

  3             DR. WILKERSON:  I think that was an

 

  4   excellent point.  I mean we have obviously learned

 

  5   today that we treat many and cure few.  So, in this

 

  6   situation, I don't think we really know the

 

  7   pharmacokinetics.

 

  8             We know that if we put 1 percent of

 

  9   compound in a cream, that it works for a few

 

 10   people, and one of the paradoxes has always been,

 

 11   extending over to onychomycosis, here, we have got

 

 12   something sticking out on the outside of the body,

 

 13   yet to be treated effectively, you have to treat

 

 14   someone orally instead of treating them topically.

 

 15             My guess is that the nature of these

 

 16   compounds is that we really don't reach very high

 

 17   concentration effective levels.  Otherwise, this

 

 18   data doesn't make any sense.

 

 19             At 0.002 micrograms per milliliter, we

 

 20   ought to be overwhelming these things, and

 

 21   obviously, there is a drug availability issue here

 

 22   which has not been addressed in the studies to

 

                                                               186

 

  1   date, so there is a problem there in terms of yes,

 

  2   the drug is there, but it is not in a bioavailable

 

  3   form, otherwise, it doesn't make any sense.

 

  4             My second comment is that since we have

 

  5   learned that we are not curing a whole lot of

 

  6   people, I want to know what your feeling is if you

 

  7   pulse treat someone with an antifungal versus

 

  8   continually treating someone, knowing what we know

 

  9   from the bacteriological literature that if you

 

 10   exposed organisms to sublethal amounts, are we, in

 

 11   fact, going to grow numerous strains of resistant

 

 12   organisms, and if we are looking at prophylaxis,

 

 13   which may come into our labeling later on here, is

 

 14   it better to pulse someone with higher

 

 15   concentrations and have holiday periods, or is it

 

 16   better to treat them continuous.

 

 17             Do we know that fungi and bacterial

 

 18   resistance behave in the same way?  Along those

 

 19   lines, do fungi lose their resistance over time if

 

 20   they are no longer exposed to the drug, or do they

 

 21   maintain it like bacteria do?

 

 22             DR. GHANNOUM:  I agree with you with the

 

                                                               187

 

  1   first one, but as far as pulse versus continuous--

 

  2             DR. WILKERSON:  I am speaking strictly

 

  3   topical, not oral therapy.

 

  4             DR. GHANNOUM:  Yes.  I really believe when

 

  5   you have a fungal infection, it is better to treat

 

  6   it continuously, at least from our experience.  You

 

  7   see, in dermatophytes, we don't have much

 

  8   information, but our experience with the other

 

  9   agents, again, like Diflucan, we noticed why did we

 

 10   have resistance there develop?  Because they

 

 11   underdose, they use to give 50 milligram.

 

 12             So, definitely, it's a recipe for

 

 13   resistance development, and we know in the lab if

 

 14   you take something, put it in some concentration,

 

 15   after some time you see MIC climbing.  So, as a

 

 16   microbiologist, I believe it is very important to

 

 17   give continuous therapy to at least eliminate the

 

 18   chance of the resistance development.

 

 19             The last question was?

 

 20             DR. WILKERSON:  Over time, if you have a

 

 21   resistant organism, does it lose its resistance, or

 

 22   does it maintain it like most bacteria do over a

 

                                                               188

 

  1   period of time once a drug is no longer present?

 

  2             DR. GHANNOUM:  I think, again from our

 

  3   knowledge with the other agents, it keeps it.  I

 

  4   have a strain, for example, took from a patient.

 

  5   The baseline was susceptible.  After 15 episodes,

 

  6   its resistant MIC is quite high, and we have been

 

  7   using it for a long time now as controls, and it is

 

  8   still there, so I don't think it loses it.

 

  9             DR. WILKERSON:  The obvious implication

 

 10   for this is that we need to have regimens that lead

 

 11   to the highest rate of eradication as possible as

 

 12   opposed to just maintaining the infectious state.

 

 13             DR. GHANNOUM:  Right.

 

 14             DR. CANTILENA:  Thank you.

 

 15             We have a question from Dr. Whitmore.

 

 16             DR. WHITMORE:  What Mike was just saying

 

 17   about failure rates and why we have such high

 

 18   failure rates, one of the things that is different

 

 19   with topicals versus systemic is if somebody tells

 

 20   you they take a pill, you know they have swallowed

 

 21   it.  They might not absorb it properly, but you

 

 22   know at least they have swallowed it.

 

                                                               189

 

  1             If somebody tells you they have put their

 

  2   antifungal on their tinea pedis, they might have

 

  3   put it just right in that one crack, who know how

 

  4   they are applying it.

 

  5             DR. GHANNOUM:  Also, a lot of time we have

 

  6   the same shoes, I mean they use the same shoes, we

 

  7   have the environment which is humid, and really,

 

  8   there are many, many factors which you need to

 

  9   address, and unfortunately, we really don't have

 

 10   relative good data.

 

 11             I mean I am new to the area of

 

 12   dermatophytes, my work, you know, time passes so

 

 13   quickly, the last eight, nine years I have been

 

 14   focusing a lot on dermatophytes, but before that,

 

 15   when I came into it, I tried to look at, there

 

 16   isn't relevant information.  So, I think it is very

 

 17   important for us to have a better understanding of

 

 18   the pathophysiology of the disease.

 

 19             DR. CANTILENA:  Any further questions?

 

 20             Okay.  If not, we will pause for lunch now

 

 21   and return to start the open public hearing at 1

 

 22   o'clock.

 

                                                               190

 

  1             [Whereupon, at 11:40 a.m., the proceedings

 

  2   were recessed, to be resumed at 1:00 p.m.]

 

                                                               191

 

  1             A F T E R N O O N  P R O C E E D I N G S

 

  2                                                    [1:00 p.m.]

 

  3             DR. CANTILENA:  Before we begin the open

 

  4   public hearing, the following statement is read

 

  5   from the Food and Drug Administration.

 

  6             Both the Food and Drug Administration and

 

  7   the public believe in a transparent process for

 

  8   information gathering and decisionmaking.  To

 

  9   ensure such transparency at the open public hearing

 

 10   session of the advisory committee meeting, FDA

 

 11   believes that it is important to understand the

 

 12   context of an individual's presentation.

 

 13             For this reason, FDA encourages you, the

 

 14   open public hearing speaker, at the beginning of

 

 15   your statement, to advise the committee of any

 

 16   financial relationship that you have in terms of

 

 17   the content, any financial relationship that you

 

 18   may have with any company or any group that is

 

 19   likely to be impacted by the topic of the meeting.

 

 20             For example, the financial information can

 

 21   include a company or a group's payment of your

 

 22   travel, lodging, or other expenses in connection

 

                                                               192

 

  1   with your attendance at the meeting.  Likewise, FDA

 

  2   encourages you at the beginning of your statement

 

  3   to advise the committee if you do not have any such

 

  4   financial relationships.

 

  5             If you choose not to address this issue of

 

  6   financial relationships at the beginning, it will

 

  7   not stop you from speaking at the meeting.

 

  8             Now that that is in the record, I think if

 

  9   you look at the open public hearing, who is

 

 10   scheduled, I think that we probably won't have a

 

 11   hard time with the conflict of interest, but it is

 

 12   something we have to do anyway.

 

 13             I will ask the committee actually to hold

 

 14   your questions until the end of the entire session

 

 15   and then we will have time for questions and

 

 16   answers at the end of the time period.

 

 17             The first group in the open public hearing

 

 18   is the Consumer Healthcare Products Association who

 

 19   will lead off and then I will ask you to then

 

 20   introduce the other speakers for the open public

 

 21   hearing.

 

 22             Thank you.

 

                                                               193

 

  1                       Open Public Hearing

 

  2             Consumer Healthcare Products Association

 

  3                        Doug Bierer, Ph.D.

 

  4             DR. BIERER:  Good Afternoon.  My name is

 

  5   Doug Bierer.  I am the Vice President of Regulatory

 

  6   and Scientific Affairs for the Consumer Healthcare

 

  7   Products Association.

 

  8             CHPA represents the vast majority of the

 

  9   distributors and manufacturers of topical

 

 10   antifungal products which are used for the

 

 11   treatment of tinea pedis.

 

 12             Our presentation today from industry will

 

 13   consist of three parts.  In the first part of our

 

 14   presentation, Dr. Boni Elewski, who is a well-known

 

 15   clinical dermatologist and expert in the field of

 

 16   topical fungal diseases, will talk about clinical

 

 17   endpoints, resistance, and safety.

 

 18             I will provide a few comments about the

 

 19   reported lack of efficacy, as well as some

 

 20   suggestions for enhanced labeling for OTC

 

 21   antifungal drug products.

 

 22             The second portion will be turned over to

 

                                                               194

 

  1   Schering-Plough Consumer HealthCare products, and

 

  2   the third portion will be Novartis Consumer Health,

 

  3   and they will make their separate presentations.

 

  4             Dr. Boni Elewski, as I mentioned before,

 

  5   has considerable experience both as a practicing

 

  6   dermatologist, as well as clinical researcher, for

 

  7   fungal infections.  She is very widely published

 

  8   about cutaneous fungal infection and shared

 

  9   guidelines of Care Committee for the treatment of

 

 10   tinea pedis for the American Academy of

 

 11   Dermatology.

 

 12                      Boni E. Elewski, M.D.

 

 13             DR. ELEWSKI:  Good afternoon, everyone,

 

 14   Mr. Chairman, ladies and gentlemen.  It is my

 

 15   pleasure to talk to you today about one of my

 

 16   favorite topics, tinea pedis.

 

 17             Before I begin my discussion, I want to

 

 18   add that I am a consultant under this capacity,

 

 19   working with CHPA, and I have also have been, and

 

 20   am, a consultant for many of the companies whose

 

 21   products will be discussed today, including both

 

 22   Novartis, who will be discussing today, and

 

                                                               195

 

  1   Schering-Plough.

 

  2             [Slide.]

 

  3             So, I am going to spend some time

 

  4   reviewing the scope of the problem, and then we

 

  5   will look at strategic issues regarding this

 

  6   problem.

 

  7             Tinea pedis is a common fungal infection

 

  8   caused by the dermatophyte fungi.  The most common

 

  9   is Trichophyton rubrum.  I happen to really like

 

 10   Trichophyton rubrum.  Its first case in the United

 

 11   States, interestingly enough, was in Birmingham,

 

 12   Alabama, in 1922.  I happen to live in Birmingham,

 

 13   Alabama, and so I tell my patients that we live in

 

 14   the fungus capital of the world, and I believe that

 

 15   actually.

 

 16             It is an infectious disease that affects

 

 17   the interdigital spaces and contiguous skin and has

 

 18   been mentioned this morning, it affects up to 70

 

 19   percent of the population.

 

 20             Dr. Rappon, in his textbook, wrote that

 

 21   our lifetime risk factor of getting tinea pedis

 

 22   living here in the United States is 70 percent, and

 

                                                               196

 

  1   it's more likely to get it if you do certain

 

  2   habits, such as you go to swimming pools or gyms or

 

  3   health spas, and there have been a lot of data

 

  4   coming from large studies and surveys looking at

 

  5   how common it is among swimmers, among people who

 

  6   go to gyms, and so forth, but must of the data from

 

  7   swimmers is very compelling, and people who go to

 

  8   swimming pools at any age have a very high risk of

 

  9   getting tinea pedis, which again confirms that it

 

 10   is an infectious disease.

 

 11             [Slide.]

 

 12             Well, what does it look like?  What we see

 

 13   is generally a dry, scaling process in the toe

 

 14   webs, most common between the third and fourth, and

 

 15   fourth and fifth web space.

 

 16             As you see here, this is a typical patient

 

 17   with interdigital tinea pedis.  Keep in mind that

 

 18   interdigital tinea pedis is what we are talking

 

 19   about today, not moccasin tinea pedis, but

 

 20   particularly interdigital tinea pedis.

 

 21             I would like to say as a sidebar that if

 

 22   this patient came into my office with a simple

 

                                                               197

 

  1   scaling process like you see, and this scale in

 

  2   between the toe webs, the treatment of choice would

 

  3   be a topical antifungal.

 

  4             A topical antifungal would be my

 

  5   preference, much better over an oral antifungal

 

  6   because it will be applied directly to the

 

  7   infection, as I will be addressing later.  I would

 

  8   not recommend an oral antifungal for treating this

 

  9   simple scaling process

 

 10             [Slide.]

 

 11             So, interdigital tinea pedis is very

 

 12   easily recognized by the consumer.  It is common.

 

 13   People who have it often have friends and relatives

 

 14   who have it.  They go to the gym, and their

 

 15   colleagues at the gym, friends at the gym, friends

 

 16   at the swimming pool had it, so they know what it

 

 17   looks like.

 

 18             It also has consistent symptoms, itching

 

 19   and burning in the toe webs.  There is also

 

 20   consistent signs - erythema or redness, scaling,

 

 21   hyperkeratosis, and fissures or cracking, and these

 

 22   are also the same signs that we capture when we do

 

                                                               198

 

  1   a study.

 

  2             [Slide.]

 

  3             So, what do we do for treating tinea pedis

 

  4   over the counter?  Well, first of all, I am happy

 

  5   to say that there is a large selection of effective

 

  6   over-the-counter antifungal drugs available for

 

  7   treating tinea pedis, some of which are

 

  8   monographed, and some are NDA switches at the full

 

  9   prescription strength.

 

 10             I would like to add that because they are

 

 11   both prescription and over the counter for some of

 

 12   these drugs, over the counter is as effective as

 

 13   the prescription topical antifungal and as safe as

 

 14   the prescription topical antifungal.

 

 15             [Slide.]

 

 16             So, how do we treat tinea pedis over the

 

 17   counter? Well, number one, you apply the antifungal

 

 18   to the affected area and to the adjacent skin once

 

 19   or twice a day as recommended by the manufacturer.

 

 20   You also treat for one or four weeks as recommended

 

 21   on the OTC label.

 

 22             Keep in mind that the signs and symptoms

 

                                                               199

 

  1   generally improve during or shortly after the

 

  2   treatment course.  That is a point I will come back

 

  3   to, because I think it was a very important point

 

  4   to address this morning.

 

  5             [Slide.]

 

  6             What is the real purpose to treat this

 

  7   infectious process?  Well, the real objective is to

 

  8   eliminate the dermatophyte, to eliminate the

 

  9   fungus.  The fungus resides, in this particular

 

 10   process, it's a superficial fungal infection and it

 

 11   resides in the outer layers of the stratum corneum,

 

 12   as you see here.

 

 13             I don't have a pointer, but it's these

 

 14   blue little dots that you see in the outer layer of

 

 15   the skin.  The red part here is the stratum

 

 16   corneum, and then you are getting into the

 

 17   epidermis and dermis, the lower part of the

 

 18   epidermis and the dermis here, below there.

 

 19             So, the very outer layer of the stratum

 

 20   corneum is where the infection resides, and because

 

 21   it is in the outer layer of the stratum corneum,

 

 22   when you apply topical antifungal, it is going to

 

                                                               200

 

  1   exceed the MIC of the dermatophyte.  It will reach

 

  2   the area.

 

  3             You won't have to worry about it getting

 

  4   there, because it will get there because you are

 

  5   applying it right on top of where the fungus is

 

  6   residing, so it is getting to the area and easily

 

  7   will exceed the MIC of the organism. This is not an

 

  8   issue.

 

  9             It may be an issue, however, if you use an

 

 10   oral agent, because if you take an oral agent to

 

 11   treat this, you have to get it absorbed, it may

 

 12   have to be metabolized, and then has to get into

 

 13   the skin.

 

 14             It is either going to get into the skin

 

 15   through passive diffusion, through excretion

 

 16   through the sweat, or through excretion through the

 

 17   sebum, which is why a drug like amphotericin B,

 

 18   which is, of course, a very potent drug for

 

 19   treating systemic infection, does not work at all

 

 20   for interdigital tinea pedis, because it will not

 

 21   get into the superficial layer of the stratum

 

 22   corneum at high enough levels to kill the

 

                                                               201

 

  1   dermatophyte.

 

  2             So, many patients at our institution who

 

  3   come in with a systemic infection and are given a

 

  4   drug, such as amphotericin B, may still have

 

  5   dermatophytosis.

 

  6             [Slide.]

 

  7             So, topical antifungals, the message is,

 

  8   are very effective applied to these superficial

 

  9   infections.  So, what happens after you apply the

 

 10   topical antifungal during and after the course of

 

 11   treatment?

 

 12             From my experience seeing patients, and I

 

 13   see patients almost every day, I am in the medical

 

 14   dermatology trenches, and I have been doing this

 

 15   for close to 25 years, itching and burning and

 

 16   generally alleviated very early in the therapy.

 

 17   Fortunately, for patients who suffer with itching,

 

 18   shortly after you start applying it, the itching

 

 19   and burning seem to go away.

 

 20             As mentioned however this morning, some

 

 21   clinical signs may take longer to resolve, and in

 

 22   some instances, from my experience, may not fully

 

                                                               202

 

  1   resolve at all.  There may be erythema or

 

  2   inflammation, scaling and hyperkeratosis, and the

 

  3   fissures and cracking.

 

  4             [Slide.]

 

  5             So, let's explore these healing dynamics

 

  6   and why one process may resolve faster and one

 

  7   takes longer to resolve, and what might be

 

  8   underlying risk factors that cause one person to

 

  9   heal at a different rate than another person.

 

 10             First, the erythema.  Erythema again is

 

 11   redness. Erythema is inflammation in the skin, and,

 

 12   of course, it's a response to the infection of the

 

 13   dermatophyte in the stratum corneum.  As the

 

 14   dermatophyte is eliminated erythema is improved.

 

 15             One of the speakers this morning showed

 

 16   the erythema going away, and it generally goes away

 

 17   fairly quickly, but now always.  Occasionally, you

 

 18   have erythema at the end of treatment, and I will

 

 19   address those points later.

 

 20             [Slide.]

 

 21             Scaling and hyperkeratosis is also caused

 

 22   by the dermatophyte living happily in the stratum

 

                                                               203

 

  1   corneum, but occasionally, scaling and

 

  2   hyperkeratosis may not completely resolve after the

 

  3   dermatophyte is eliminated.

 

  4             One, patients may have an anatomic

 

  5   occlusion, they may have a hammertoe, they may have

 

  6   toe overlap.  They may have arthritis where two

 

  7   toes are rubbing against each other, causing some

 

  8   friction or causing some scale or a callus from the

 

  9   anatomy of the patient or the deformity of the

 

 10   foot.

 

 11             We also may have pre-existing skin

 

 12   diseases, and one may have psoriasis.  Someone else

 

 13   may have atopic eczema, and as a sidebar, people

 

 14   who are atopic or have an atopic diaphysis have the

 

 15   highest rate of getting tinea pedis to begin with,

 

 16   and these people may also have underlying atopic

 

 17   dermatitis, which could be some reason why they may

 

 18   have some scale and hyperkeratosis.

 

 19             Some people I like to refer to also as

 

 20   fast healers.  Remember we have to wait until the

 

 21   skin turns over, which can take four weeks and some

 

 22   patients even longer.

 

                                                               204

 

  1             Other people are faster healers, and since

 

  2   we are arbitrarily assessing this data at one given

 

  3   point in time, it may vary from person to person,

 

  4   because we are all people, we are all different,

 

  5   and no two people do anything exactly the same.

 

  6             So, from my experience, residual scaling

 

  7   and hyperkeratosis is not uncommon after the

 

  8   elimination of the dermatophyte.  Most always it

 

  9   eventually goes away, but occasionally, you still

 

 10   have some that may be totally unrelated to the

 

 11   dermatophyte.

 

 12             It may be that they had a soft corn, it

 

 13   may be that they had a hammertoe, it may be that

 

 14   they have something else.  So, these studies may

 

 15   not take all this data into account, they are just

 

 16   taking in the dry data, scale, is there a flake, is

 

 17   there some redness, and we will come back to that

 

 18   point in a few moments.

 

 19             [Slide.]

 

 20             Next, fissures or cracking.  Again, this

 

 21   may occur due to the presence of a dermatophyte in

 

 22   the stratum corneum, although you can have fissures

 

                                                               205

 

  1   and cracking due to other reasons, too, if someone

 

  2   has a hammertoe or someone has a toe overlap or

 

  3   some other anatomical occlusion, they may have

 

  4   fissures for other reasons.

 

  5             But resolution of fissures generally is

 

  6   fairly reliable except some fissures are very deep,

 

  7   and then it may take longer for them to resolve, or

 

  8   someone may have other confounding factors that may

 

  9   delay healing, such as they have peripheral

 

 10   vascular disease, and so forth, and that is not all

 

 11   excluded in patient studies or in your real

 

 12   practice, of course.

 

 13             So, from my experience, occasionally, you

 

 14   see fissures and cracking after the elimination of

 

 15   the dermatophyte, but from my experience, it is

 

 16   much less common to see than simple scaling after

 

 17   the elimination of the dermatophyte.

 

 18             [Slide.]

 

 19             So, we have to have a system of evaluating

 

 20   all this in our practice, but more importantly,

 

 21   since the issues is studies, in our studies.

 

 22             Study methodology are twofold.  One, the

 

                                                               206

 

  1   microbiology parameters, microbiological

 

  2   parameters, and, two, clinical efficacy parameters.

 

  3             [Slide.]

 

  4             Well, what are microbiological parameters?

 

  5   We addressed this, let me recap.  First, we have

 

  6   the KOH.  A KOH shows the presence or absence of

 

  7   fungal elements.  It does not capture, however,

 

  8   whether the fungal elements are dead or whether

 

  9   they are alive.  You don't know.  You just know

 

 10   that the fungus is there or that it's not there.

 

 11   That is an important point, we will come back to

 

 12   that.

 

 13             We also a fungal culture which identifies

 

 14   the organism by the genus and by the species.  It

 

 15   also tells you whether there is viable fungi there.

 

 16   So, sometimes you can use the positive or negative

 

 17   fungal culture and correlate it with the KOH to see

 

 18   whether they are viable or nonviable, but again, we

 

 19   don't have a lot of data to look at that, but the

 

 20   main objective is mycological cure.

 

 21             Mycological cure, by the definition that

 

 22   we live by is negative KOH and negative culture. 

 

                                                               207

 

  1   In most studies, from looking at the data presented

 

  2   this morning, it appeared that more than half the

 

  3   people in the studies had a mycological cure of

 

  4   about 80 percent or higher.

 

  5             That doesn't surprise me, and I would

 

  6   predict that those who are not mycologically cured

 

  7   probably had some persistent scale, and the

 

  8   persistent scale had some nonviable fungal

 

  9   elements, and the nonviable fungal elements made

 

 10   the mycological cure falsely low.

 

 11             So, what I am getting at it is in my

 

 12   experience, I think we can cure a lot of patients

 

 13   with interdigital tinea pedis, it depends on how we

 

 14   define cure, and we are going to hit that again in

 

 15   just a moment.

 

 16             [Slide.]

 

 17             So, we have the microbiological

 

 18   parameters.  Now, let's look at the clinical

 

 19   efficacy parameters.  Here, we have two.  Complete

 

 20   cure, that means mycological cure plus absolutely

 

 21   no sign and absolutely no symptom.  Effective

 

 22   treatment.  Effective treatment is mycological

 

                                                               208

 

  1   cure, so negative KOH, negative culture, plus no

 

  2   more than mild signs or mild symptoms.

 

  3             Again, in a study, most studies are

 

  4   generally looking at this in a 4-point scale, zero

 

  5   being absent, 1 mild, 2 moderate, 3 severe.  So,

 

  6   when the patient or the subject was enrolled in the

 

  7   study, they were moderate to severe in one of the

 

  8   parameters, and at the end of the study they may

 

  9   end up as mild.

 

 10             That can be very frustrating to me as an

 

 11   investigator, especially when I have a patient who

 

 12   is totally clear clinically, not a flake to be

 

 13   found, not a fissure to be seen, no erythema

 

 14   lurking in the toe webs, yet, they murmur "but it

 

 15   itches" or "I think it itches." Then, I have to say

 

 16   perhaps mild itching, so they would be a failure,

 

 17   it can be very frustrating.

 

 18             It also might be frustrating if I see

 

 19   something, such as erythema, but my gut feeling is

 

 20   that the erythema or the flakes of scale I see, or

 

 21   a little callus I see is not due to the tinea

 

 22   pedis, but it is due to a toe overlap or due to an

 

                                                               209

 

  1   anatomic occlusion.

 

  2             Nonetheless, it is there, it may be better

 

  3   because we got rid of the dermatophyte, but the

 

  4   fact that it is there, I will have to tick "mild,"

 

  5   which will bring the whole results of the data

 

  6   down.  So, keep all that in mind.

 

  7             [Slide.]

 

  8             Which brings me to the point, when we say

 

  9   cure, what do we mean by cure, what is meaningful?

 

 10   How I do this in my practice and how I do this when

 

 11   I look at the data from a study, if I am evaluating

 

 12   a drug, what are my personal objectives?

 

 13             Well, objective number one is you want to

 

 14   eliminate the dermatophyte.  After all, it is an

 

 15   infection, and that is how we define these to begin

 

 16   with.  They are dermatophytosis, so you want to

 

 17   eliminate the dermatophyte. So, by the definition

 

 18   we are using, we would have to say mycological

 

 19   cure.

 

 20             Also, for practical purposes, no more than

 

 21   mild signs and symptoms, and I am going to stick

 

 22   with that, because there are frequently a patient

 

                                                               210

 

  1   at the point of time that the study ends, their

 

  2   symptoms are on the way down, and they went from

 

  3   severe to moderate, and now there is a flake of

 

  4   scale or a speck of erythema, and they are still

 

  5   improved, but not 100 percent, or they may have

 

  6   some underlying process that causes this.

 

  7             [Slide.]

 

  8             So, when I say "mild," the mild could be

 

  9   due to the fact that they have an underlying

 

 10   dermatosis, they have psoriasis which we are not

 

 11   capturing, they have eczema, they have xerosis.

 

 12             We talked about this morning that people

 

 13   who have dry feet, also often have fungal

 

 14   infections, but you can't say that everyone with a

 

 15   dry foot has fungal infections, and if you think

 

 16   that, we will look at everyone's feet here, we can

 

 17   do cultures and see how many of you have fungal

 

 18   infections if you have dry feet.  I doubt that we

 

 19   would correlate that with a very high figure.

 

 20             Also, keep in mind that treating tinea

 

 21   pedis with an antifungal cream will certainly not

 

 22   make the skin better than it was prior to the

 

                                                               211

 

  1   infection, it can't be done, so all we can do is

 

  2   restore the skin to the baseline status it was

 

  3   before the patient acquired the infection.

 

  4             [Slide.]

 

  5             So, what I think is the most meaningful

 

  6   datapoint that I like to hold my hat on is

 

  7   effective treatment.  Effective treatment means the

 

  8   dermatophyte is eliminated and we have improved the

 

  9   patient significantly, down to just a trivial

 

 10   point, which may be and probably is unrelated to

 

 11   the process, or if it is related, it is going down

 

 12   a slower slope than other patients.

 

 13             [Slide.]

 

 14             So, clinical insights that I have built up

 

 15   now. Current over-the-counter antifungal drugs, in

 

 16   my opinion, deliver very safe and effective

 

 17   treatment especially since we are treating an

 

 18   infection that is in the very superficial layers of

 

 19   the skin.  When you apply an antifungal to this

 

 20   area, you are getting it onto the infective

 

 21   organism and killing organism.

 

 22             In my opinion, the clinical meaningful

 

                                                               212

 

  1   endpoint is effective treatment.  Because of this,

 

  2   I don't think dose response studies are needed,

 

  3   because topical antifungals easily reach the

 

  4   dermatophytes in excess of the MICs.

 

  5             [Slide.]

 

  6             Likewise, as Dr. Ghannoum so eloquently

 

  7   pointed out today, there is really no concern about

 

  8   dermatophyte antifungal resistance, and even if

 

  9   there were organisms that had a borderline

 

 10   resistant issue, because you are applying it in

 

 11   such a high amount, it will readily exceed the MIC

 

 12   of the dermatophyte living in the very superficial

 

 13   layers of the skin.

 

 14             This is not the same situation as we have

 

 15   with oral drugs where you have to worry about them

 

 16   getting there in high enough numbers, and there are

 

 17   so many factors that can confound that from

 

 18   happening, whether the patient absorbed it

 

 19   correctly, whether there is any other process that

 

 20   might have impaired the drug from getting to the

 

 21   target point of infection.

 

 22             So, in my experience, when used as

 

                                                               213

 

  1   directed, topical antifungals are very effective at

 

  2   eliminating the fungus.

 

  3             [Slide.]

 

  4             There are a couple of other issues I want

 

  5   to address.  One came up this morning as secondary

 

  6   bacterial infections.  As we have discussed, there

 

  7   are rare reports of secondary bacterial infections,

 

  8   i.e., cellulitis associated with tinea pedis.

 

  9             In my 25 years of being out in the

 

 10   trenches, seeing patients, I have never seen a

 

 11   patient with interdigital tinea pedis or moccasin

 

 12   tinea pedis developing a bacterial cellulitis.  I

 

 13   have never seen it.  I know it has been reported, I

 

 14   am aware of the literature.

 

 15             The explanation for this the authors have

 

 16   postulated is that the presence of the dermatophyte

 

 17   damages the stratum corneum, causing loss of

 

 18   barrier function, resulting in microfissures or

 

 19   obvious fissures that serve as portals of entry for

 

 20   secondary bacterial infection.

 

 21             Having said that, it would make even more

 

 22   sense to state that prompt and effective treatment

 

                                                               214

 

  1   is clearly essential, and therefore,

 

  2   over-the-counter topical antifungals are important

 

  3   because they eliminate the dermatophyte to allow

 

  4   the skin to naturally replace itself and restore

 

  5   its barrier function.

 

  6             I will leave you back with Doug.

 

  7                        Doug Bierer, Ph.D.

 

  8             DR. BIERER:  I would like to provide some

 

  9   perspective on lack of efficacy reports that have

 

 10   been reported by FDA.

 

 11             [Slide.]

 

 12             FDA reported that 35 percent of all

 

 13   adverse events of topical antifungal agents were

 

 14   due to lack of efficacy. This is from their AERS

 

 15   database.  The database actually goes back in the

 

 16   late sixties and encompasses about 30 years.  It

 

 17   includes reports of both OTC, as well as Rx drugs.

 

 18             In those reports, it is unclear whether

 

 19   the reports of lack of efficacy were specifically

 

 20   related to tinea pedis or perhaps one of the other

 

 21   labeled indications, or actually may have been used

 

 22   for another disorder all together.

 

                                                               215

 

  1             In order to help put these lack of

 

  2   efficacy reports into perspective, CHPA looked at

 

  3   lack of efficacy reported for OTC topical

 

  4   antifungals related to the number of units sold.

 

  5             [Slide.]

 

  6             CHPA collected the number of lack of

 

  7   efficacy reports from seven OTC manufacturers, who

 

  8   actually distribute probably the vast majority of

 

  9   OTC antifungal products used to treat tinea pedis,

 

 10   and we looked at the years from 1999 to the year

 

 11   2003, over a four-year period.

 

 12             We saw or found that there was 1,468

 

 13   reports of lack of efficacy, but during that same

 

 14   period of time, greater than 180 million units were

 

 15   sold and used by consumers.  If you translate this

 

 16   out, this calculates into less than 9 lack of

 

 17   efficacy reports per million units sold.

 

 18             Even if these are underreported, as people

 

 19   have commented this morning, it still is a very low

 

 20   rate of lack of efficacy reports for such a drug.

 

 21             One of the other areas that we wanted to

 

 22   talk about was that we believe that some of the

 

                                                               216

 

  1   concerns raised by the FDA perhaps can be handled

 

  2   through enhanced labeling of OTS antifungal

 

  3   products, and I would like to take you through a

 

  4   couple of our suggestions that we have.

 

  5             We believe that these should be applied to

 

  6   not only OTC monograph products, but also OTC

 

  7   products which are regulated under new drug

 

  8   applications or NDA.

 

  9             [Slide.]

 

 10             As we talked a little bit earlier this

 

 11   morning, and I just mention lack of efficacy,

 

 12   actually could be due to some consumers stopping

 

 13   treatment prematurely, not completing the full

 

 14   course of therapy.

 

 15             FDA had suggested that we may want to look

 

 16   at different devices for showing consumers what

 

 17   could be expected, and one of the suggestions was

 

 18   perhaps looking at GRASE or tables on package

 

 19   labels.  We believe that these are quite confusing

 

 20   to consumers since most consumers cannot understand

 

 21   data or tables, and overwhelming consumers with

 

 22   complicated data should be avoided.  However, we

 

                                                               217

 

  1   believe that consumers do need simple and concise

 

  2   label statements of how to use the products in

 

  3   order to achieve the maximum benefit from the

 

  4   products.

 

  5             [Slide.]

 

  6             Therefore, we are proposing that we add

 

  7   the statement under directions for all OTC

 

  8   products, which is use daily as directed for the

 

  9   full treatment time even if symptoms improve.

 

 10             [Slide.]

 

 11             Also, along directions, the FDA asked

 

 12   whether labeling should convey lag time between the

 

 13   completion of treatment and the resolution of

 

 14   symptoms, and we believe it is also helpful to

 

 15   educate consumers on what can be expected under use

 

 16   conditions.

 

 17             [Slide.]

 

 18             Therefore, we are proposing to add another

 

 19   statement for directions for one-week use products,

 

 20   that symptoms may continue to improve after one

 

 21   week of treatment as the skin naturally replaces

 

 22   itself.

 

                                                               218

 

  1             As you heard this morning, the use of

 

  2   one-week products, there is an increase in efficacy

 

  3   and clinical cure, as well as effective treatment,

 

  4   as time progresses beyond the one week, so we

 

  5   believe this statement would be important for

 

  6   one-week products.

 

  7             [Slide.]

 

  8             Lastly, we believe that to address the

 

  9   FDA's concern about secondary bacterial infection,

 

 10   that is, cellulitis, we propose adding labeling

 

 11   information about when to see a doctor.

 

 12             [Slide.]

 

 13             We would propose to add a new statement,

 

 14   which is new symptoms develop or condition worsens,

 

 15   and this statement would be added after the phrase,

 

 16   "Stop use and ask a doctor if--the warning part,

 

 17   which is currently on OTC product labeling--so, the

 

 18   statement would read, "Stop use and ask a doctor

 

 19   if"--bullet point--"new symptoms develop or

 

 20   conditions worsen."

 

 21             [Slide.]

 

 22             This slide just reviews the three proposed

 

                                                               219

 

  1   label additions that we would recommend to enhance

 

  2   labeling for OTS drug products, and we believe that

 

  3   these will not only reinforce consumer compliance,

 

  4   but also further decrease the potential of serious

 

  5   adverse events.

 

  6             DR. ELEWSKI:  Let me conclude with some

 

  7   key points.

 

  8             [Slide.]

 

  9             First, clinical cure, as I mentioned, I

 

 10   feel should be defined as effective treatment.

 

 11   Dose response studies are not needed because

 

 12   topical antifungals easily reach dermatophytes in

 

 13   excess of MICs.

 

 14             Dermatophyte resistance is not a concern.

 

 15   The risk of secondary bacterial infections is very

 

 16   low.  OTC antifungals play an important role by

 

 17   restoring the barrier function of the skin and

 

 18   allowing the skin to naturally replace itself.

 

 19             [Slide.]

 

 20             The proposed enhanced labeling will

 

 21   reinforce consumer compliance and decrease

 

 22   potential serious adverse events.  Current OTC

 

                                                               220

 

  1   products are safe and provide effective treatment

 

  2   when used as directed.

 

  3             Now, we are going to take a few questions

 

  4   if you have any now.

 

  5             DR. CANTILENA:  Actually, I think we are

 

  6   going to hold questions, and we will have all three

 

  7   groups go ahead and speak, and then we will do

 

  8   questions at the end.

 

  9             DR. ELEWSKI:  Okay.

 

 10                         Schering-Plough

 

 11                        John Clayton, M.D.

 

 12             DR. CLAYTON:  Good afternoon.  I am John

 

 13   Clayton, Senior Vice President, Scientific and

 

 14   Regulatory Affairs for Schering-Plough HealthCare

 

 15   products.

 

 16             I think the conflict of interest is

 

 17   obvious.  My paycheck comes from there.

 

 18             I certainly welcome the opportunity to

 

 19   share with you Schering-Plough's experience and

 

 20   views over a number of years of marketing

 

 21   over-the-counter OTC products for treating topical

 

 22   fungal infections, as well as Rx products.

 

                                                               221

 

  1             [Slide.]

 

  2             Our agenda for the afternoon, for my

 

  3   presentation, is to share with you based on our

 

  4   marketing history, our clinical experience,

 

  5   consumer experience, some consumer research, our

 

  6   recommendations and conclusions that hopefully will

 

  7   be helpful to you in your deliberations.

 

  8             [Slide.]

 

  9             By way of background, Schering-Plough has

 

 10   been a leader in research and marketing of Rx and

 

 11   OTC topical antifungals for the treatment of tinea

 

 12   pedis for more than 40 years.

 

 13             [Slide.]

 

 14             We began marketing tolnaftate in the

 

 15   sixties and actually developed tolnaftate in this

 

 16   country, as well as clotrimazole in this country,

 

 17   for tinea pedis.

 

 18             Products currently that Schering-Plough

 

 19   markets OTC represent about 44 percent of the units

 

 20   sold in the U.S., and the brands include those

 

 21   listed on this slide, some of which you hopefully

 

 22   are familiar with, and the antifungal agents used

 

                                                               222

 

  1   in these products are betenafine hydrochloride,

 

  2   clotrimazole, tolnaftate, or miconazole nitrate.

 

  3   All of these ingredients have marketing history Rx

 

  4   and were approved under NDAs originally.

 

  5             [Slide.]

 

  6             In terms of clinical experience,

 

  7   obviously, the ages of these products is different,

 

  8   as was suggested in presentations this morning.

 

  9   Therefore, the clinical endpoints, the designs of

 

 10   clinical trials, while state of the art in their

 

 11   day, vary, but overall, the clinical trials through

 

 12   a variety of designs have demonstrated the safety

 

 13   and efficacy of these products at the current

 

 14   dosing levels.

 

 15             Even though the study endpoints have

 

 16   changed dramatically over these past four decades,

 

 17   significant clinical efficacy has consistently been

 

 18   demonstrated for all of these ingredients through

 

 19   various types of clinical trials.

 

 20             [Slide.]

 

 21             I certainly concur, the company certainly

 

 22   concurs with the presentation and recommendation of

 

                                                               223

 

  1   CHPA presented through Dr. Elewski, that complete

 

  2   cure endpoint definition is an unrealistic

 

  3   parameter of efficacy based on the natural course

 

  4   of healing.  That is, it truly understates the

 

  5   efficacy of these products.

 

  6             We believe that it is a more appropriate

 

  7   indicator, the effective treatment, which is

 

  8   defined as negative mycology, both culture and KOH,

 

  9   and minimal erythema and scaling is a more

 

 10   appropriate descriptor of efficacy.

 

 11             [Slide.]

 

 12             In our consumer experience, just looking

 

 13   at the data that we have collected over the past

 

 14   12, 13 years of more than 230 million units sold of

 

 15   our various antifungal ingredients, that extensive

 

 16   patient and consumer experience confirms that these

 

 17   products are very effective.

 

 18             In our experience, the complaint rates

 

 19   regarding lack of efficacy have been extremely low,

 

 20   2 per million calculating over the past 5 years,

 

 21   which I think is the most meaningful data that we

 

 22   have.

 

                                                               224

 

  1             The consumer letters that we received

 

  2   unsolicited, surprisingly enough, almost achieve

 

  3   the same level, indicating to us the success that

 

  4   they have had with a variety of products, anecdotal

 

  5   for certain, but the fact is the consumers appear

 

  6   to be satisfied with the products.

 

  7             [Slide.]

 

  8             One of the more quantitative and

 

  9   structured ways that we have used to achieve

 

 10   information about consumers that use these products

 

 11   is through a consumer tracking study.  We have

 

 12   conducting the study annually over the past 10

 

 13   years to get the views and practices that consumers

 

 14   will share with us.

 

 15             These are consumers that actually suffer

 

 16   athlete's foot, have suffered athlete's foot within

 

 17   the preceding 12 months.  The most recent tracking

 

 18   study that we completed was in October of last year

 

 19   that included 350 consumers between the ages of 18

 

 20   and 64 years of age.

 

 21             As I said, they reported they had suffered

 

 22   from athlete's foot within the previous 12 months,

 

                                                               225

 

  1   and distribution was 70 percent male and 30 percent

 

  2   female, which in the variety of studies we have

 

  3   done, this seems to be about the--I will say

 

  4   incidence, but in terms of usage of products to

 

  5   treat--it is about 70 percent male, 30 percent

 

  6   female.

 

  7             This particular research study was done by

 

  8   way of the internet.

 

  9             [Slide.]

 

 10             A number of interesting observations out

 

 11   of the study.  Consumers purchase the OTC topical

 

 12   antifungals driven by the need for symptom relief.

 

 13             Universally, consumers that suffer the

 

 14   itching an burning of athlete's foot will

 

 15   self-treat, 95 percent of the time they will seek

 

 16   some type of therapeutic agent to treat their

 

 17   condition.  Approximately, 80 percent purchase

 

 18   4-week products, and approximately 20 percent

 

 19   purchase products, I have less than or equal to

 

 20   4-week.

 

 21             As was noted this morning, one product has

 

 22   labeling for 1 week, another product has labeling

 

                                                               226

 

  1   for 1 or for 4 weeks, an optional dosing regimen,

 

  2   the difference being two times per day for the

 

  3   1-week treatment versus one time per day for the

 

  4   4-week treatment.

 

  5             Again, intense itching and burning are the

 

  6   primary drivers, and 69 percent rate the symptoms

 

  7   as bothersome or very bothersome.

 

  8             [Slide.]

 

  9             Consumers tell us that relief begins

 

 10   within a matter of a few days following initiation

 

 11   of treatment.  I am sure we are talking about the

 

 12   bothersome symptoms that drove them to buy the

 

 13   product in the first place, so 60 percent say that

 

 14   these products, in their opinion, provide fast

 

 15   relief of their symptoms.

 

 16             Consumers also tend to discontinue use of

 

 17   these products despite the labeling upon achieving

 

 18   relief of their symptoms.

 

 19             We found in our survey in September of

 

 20   last year that the average treatment period was 7.3

 

 21   days.

 

 22             [Slide.]

 

                                                               227

 

  1             You may say that probably has been

 

  2   influenced by newer products that offer alternative

 

  3   dosing regimens, but looking back at our 1997

 

  4   study, similar design, consumers reported an

 

  5   average treatment time of 8.8 days at that point in

 

  6   time, so none of the shorter course therapy

 

  7   products were labeled for shorter use back in 1997

 

  8   OTC.

 

  9             Interesting, too, is that only 6 percent

 

 10   report that they treat greater than 14 days, again

 

 11   driven by relief of symptoms, discontinuation of

 

 12   use of product.

 

 13             More than 50 percent treat 5 days or less

 

 14   on average.

 

 15             Despite that, the consumer satisfaction

 

 16   with OTC antifungals was extremely strong.

 

 17             One point that is not on target with the

 

 18   treatment time, but interesting, that I wanted to

 

 19   share with you, is that 42 percent of the

 

 20   individuals in our most recent study indicated that

 

 21   they are experiencing athlete's foot less often now

 

 22   than they were 2 years ago.

 

                                                               228

 

  1             We don't have a reason for that, we can

 

  2   speculate that it is a change in footwear,

 

  3   improvement of the hygiene, I am not sure what it

 

  4   might be, but it was interesting to note that they

 

  5   are complaining less frequently.

 

  6             [Slide.]

 

  7             Our conclusions from the consumer research

 

  8   data are that consumers are highly satisfied with

 

  9   the performance of currently marketed OTC products.

 

 10             Consumers consistently experience fast

 

 11   relief of symptoms, as was noted that more than 60

 

 12   percent have reported that.  Therefore, most

 

 13   consumers do not use the product for the entire

 

 14   label treatment period, yet, are driven by the

 

 15   symptom relief that they get from the products.

 

 16             [Slide.]

 

 17             As a result of this, while the information

 

 18   that we have on lack of efficacy in our experience

 

 19   is that it is reported infrequently, we still

 

 20   believe that based on the consumer research

 

 21   learnings, that there is a likelihood that we could

 

 22   improve the efficacy rate for consumers by

 

                                                               229

 

  1   reinforcing the need to apply these products

 

  2   throughout the entire directed labeled treatment

 

  3   period.

 

  4             We do think that therapeutic success can

 

  5   be enhanced, and similar to what CHPA presented, we

 

  6   recommend that the Direction Section of the label

 

  7   include a statement to remind the consumer to use

 

  8   daily, as directed, for the full treatment period

 

  9   even as their symptoms improve.

 

 10             [Slide.]

 

 11             Dr. Bisno gave us a lecture this morning

 

 12   and education on the complications of tinea pedis

 

 13   and particularly as it relates to cellulitis or the

 

 14   potential for cellulitis to develop.

 

 15             In our experience, it is extremely rare,

 

 16   and I won't rehash the discussion of the morning.

 

 17             [Slide.]

 

 18             Despite that, we believe that because of

 

 19   concerns of other infections that may occur either

 

 20   through improper usage of the product, that is,

 

 21   using the product for a short duration of period,

 

 22   or because they have mischaracterized their

 

                                                               230

 

  1   condition, that an additional warning statement

 

  2   should be added to products, that if there is no

 

  3   improvement, stop use and ask a doctor if there is

 

  4   no improvement within a matter of days, and I am

 

  5   not sure that 14 is the right number of days, but

 

  6   within some reasonable period of time, or if the

 

  7   condition worsens.

 

  8             [Slide.]

 

  9             Our conclusions are that the current

 

 10   products are very effective in treating tinea pedis

 

 11   as demonstrated through a variety of clinical

 

 12   trials and through our consumer satisfaction

 

 13   testing.

 

 14             Products are extremely safe based on

 

 15   extensive marketing history.

 

 16             We believe that the effective treatment is

 

 17   the appropriate clinical endpoint for making

 

 18   decisions about efficacy of product, and that we

 

 19   support the enhancement of existing product

 

 20   labeling to improve consumer compliance, as well as

 

 21   treatment success.

 

 22             Thanks very much.

 

                                                               231

 

  1             DR. CANTILENA:  Thank you.

 

  2             Our final presentation in the open public

 

  3   hearing is from Novartis.

 

  4                             Novartis

 

  5               Helmut H. Albrecht, M.D., M.S., FFPM

 

  6             DR. ALBRECHT:  Good afternoon, Dr.

 

  7   Cantilena, members of the Committee, Drs. Wilkin

 

  8   and Ganley, FDA staff.

 

  9             [Slide.]

 

 10             I am Dr. Helmut Albrecht, Vice President

 

 11   of Clinical and Medical Development at Novartis

 

 12   Consumer Health.

 

 13             As a leader and innovator in the topical

 

 14   antifungal category, we are here to discuss how

 

 15   terbinafine fits into today's dialogue,

 

 16   specifically, addressing the issues outlined by the

 

 17   Agency including efficacy, safety, and labeling.

 

 18             We have extensive experience in the

 

 19   category.  Novartis markets terbinafine in a

 

 20   variety of forms including an Rx table and topical

 

 21   OTC products introduced through an NDA.

 

 22             We also market monograph products in this

 

                                                               232

 

  1   category.  We understand the terbinafine compounds

 

  2   and how consumers use the product based on years of

 

  3   market availability and millions of usage

 

  4   occasions.

 

  5             We have heard what the FDA has to say and

 

  6   agree with much of it, an we will discuss our

 

  7   position on how antifungals can be used more

 

  8   appropriately by consumers to maximize their full

 

  9   potential.

 

 10             We look forward to the committee's input

 

 11   to help us enhance our label, to guide future

 

 12   development in the interests of improving public

 

 13   health.

 

 14             [Slide.]

 

 15             I will provide context and commentary for

 

 16   the committee's considerations.  First, we concur

 

 17   with the Agency that labeling could be enhanced to

 

 18   improve compliance.  This will optimize treatment

 

 19   benefits, reduce the incidence of lack of

 

 20   effectiveness reports, and minimize the possibility

 

 21   of adverse events.

 

 22             [Slide.]

 

                                                               233

 

  1             Next, we will show how our compound

 

  2   terbinafine offers unique properties that should be

 

  3   communicated to consumers through labeling, and we

 

  4   will comment on the need for appropriate clinical

 

  5   endpoints to guide product development, consumer

 

  6   expectations, and labeling.

 

  7             [Slide.]

 

  8             Here, we see a presentation of

 

  9   interdigital tinea pedis or athlete's foot as it is

 

 10   seen clinically with signs and symptoms.  Doctors

 

 11   and consumers may perceive this condition

 

 12   differently.  Doctors appreciate that it is an

 

 13   infectious disease, and they understand that some

 

 14   signs and symptoms may persist for weeks even after

 

 15   the causative fungus has been killed.

 

 16             In contrast, consumers have a different

 

 17   understanding of athlete's foot.  Our market

 

 18   research indicates that they start and stop

 

 19   treatment primarily based on the onset and

 

 20   resolution of the most troublesome symptoms,

 

 21   including itching and burning.  These symptoms

 

 22   often last for a week or less.

 

                                                               234

 

  1             [Slide.]

 

  2             On this slide, we show the natural history

 

  3   of the athlete's foot condition and its treatment.

 

  4   The mycology is shown in the green, symptoms shown

 

  5   in yellow, and signs as shown in red.

 

  6             As you can see, the signs of the

 

  7   condition, such as mild erythema and scaling, can

 

  8   often persist for sometime beyond resolution of the

 

  9   symptoms and after the fungus has been eliminated.

 

 10             The actual repair and healing of the skin

 

 11   progresses at its own rate, and there is no need

 

 12   for further treatment.

 

 13             This healing process reflects the time it

 

 14   takes for the skin to heal and it is influenced by

 

 15   several factors including individual skin types,

 

 16   foot condition, and healing rates.

 

 17             As you would agree, the primary goal of

 

 18   therapy is to effectively eliminate the fungus.

 

 19   Once the fungus is eliminated, there is nothing

 

 20   more you can do with an antifungal product.

 

 21             We conducted a market research study

 

 22   involving more than 300 consumers.  Our findings

 

                                                               235

 

  1   demonstrate that consumers initiate treatment based

 

  2   on symptoms, such as itching and burning, and

 

  3   discontinue treatment based on resolution of these

 

  4   symptoms, which commonly resolve within one week or

 

  5   less.

 

  6             If a consumer treats for only 1 week, even

 

  7   if the product is recommended for 4 weeks, this has

 

  8   significant implications for those products that

 

  9   require 4 weeks of treatment.

 

 10             These findings provide a rationale for our

 

 11   belief that effective treatment is the appropriate

 

 12   clinical endpoint for guiding consumer expectations

 

 13   and labeling.

 

 14             Effective treatment reflects resolution of

 

 15   both mycology, here in the green, and symptoms,

 

 16   here in the yellow.

 

 17             [Slide.]

 

 18             Now, I would like to turn your attention

 

 19   to terbinafine, which we market under the brand

 

 20   name Lamisil AT.  Terbinafine is a synthetic

 

 21   antifungal of the allylamine class.  It has broad

 

 22   spectrum fungicidal activity including the

 

                                                               236

 

  1   dermatophytes that cause the athlete's foot.

 

  2             This property is based on the compound's

 

  3   unique mechanism of action which involves specific

 

  4   inhibition of squalene epoxidase, a key enzyme in

 

  5   ergosterol biosynthesis of fungi.

 

  6             As such, the fungicidal activity of

 

  7   terbinafine is distinct from the fungistatic

 

  8   activity of the azole compounds in this category.

 

  9             Terbinafine offers proven efficacy with

 

 10   only 1 week of treatment, with no need for

 

 11   additional therapy. Terbinafine was introduced in

 

 12   1992 and switched to OTC status in 1999.

 

 13             Since then, there have been more than 200

 

 14   million exposures to the compound with no

 

 15   identification of safety issues, trends, or

 

 16   development of significant persistence.

 

 17             It is worth noting that terbinafine is the

 

 18   only active ingredient in the Lamisil AT line, and

 

 19   therefore has consistent labeling and dosing

 

 20   instructions, reducing the likelihood for consumer

 

 21   confusion.

 

 22             [Slide.]

 

                                                               237

 

  1             Let us now focus on the efficacy of

 

  2   terbinafine. This morning, we heard a lot about the

 

  3   clinical effectiveness from pooled data.  Please

 

  4   allow me to show you the actual efficacy results

 

  5   from the terbinafine pivotal studies for the cream

 

  6   product.

 

  7             [Slide.]

 

  8             First, I show in vitro and in vivo

 

  9   evidence of the activity of terbinafine where it is

 

 10   needed to kill the fungus.  Minimum inhibitory

 

 11   concentrations or MIC values show a high degree of

 

 12   antifungal activity at very low concentrations,

 

 13   providing antidermatophyte potential that is 100

 

 14   times more effective than Butenafine and 1,000-fold

 

 15   more potent that clotrimazole.

 

 16             In contrast to what you may have heard

 

 17   this morning, terbinafine does indeed reach the

 

 18   site where it is needed.  After 1 week of topical

 

 19   application, concentrations in the skin are 1,000

 

 20   times the MIC.  Seven days post-therapy,

 

 21   concentrations in the skin are still 100 times the

 

 22   MIC.  In fact, therapeutic values remain in the

 

                                                               238

 

  1   skin 5 weeks post-dosing.

 

  2             [Slide.]

 

  3             Terbinafine has been extensively studied

 

  4   and safety and efficacy have been clearly

 

  5   demonstrated in 15 well-controlled clinical

 

  6   studies.  This shows from a representative pivotal

 

  7   study in tinea pedis from the NDA filing for the

 

  8   OTC switch of Lamisil AT 1 percent cream.

 

  9             The y axis shows for each of the three

 

 10   clinical endpoints the percentage of subjects who

 

 11   successfully achieved them.  The red bars represent

 

 12   terbinafine and the green bars represent placebo.

 

 13             The two columns on the left show the

 

 14   result of mycological cure.  This is, of course,

 

 15   the prerequisite for the other endpoints -

 

 16   effective treatment and complete cure. So,

 

 17   effective treatment results are shown in the

 

 18   middle, and the bars on the right show complete

 

 19   cure.

 

 20             It is important to note that all three

 

 21   endpoints represent the same patient experience.

 

 22   The differences in the values simply represent the

 

                                                               239

 

  1   different clinical parameters.

 

  2             As mentioned previously, complete cure is

 

  3   heavily weighted by signs of the condition, and

 

  4   therefore is always found at a lower rate.

 

  5             These next two slides represent data from

 

  6   one of our studies comparing terbinafine and

 

  7   clotrimazole at 6 weeks post-baseline.

 

  8             [Slide.]

 

  9             We are showing you 1-week data because

 

 10   this is how we understand consumers to use these

 

 11   products.  As you can see, at this point in time,

 

 12   terbinafine is highly effective and far superior to

 

 13   clotrimazole on each of the three endpoints.

 

 14             [Slide.]

 

 15             These are results from the same study

 

 16   showing efficacy at 6 weeks post-baseline following

 

 17   4 weeks of treatment with the two products.  You

 

 18   can see that 4 weeks of treatment with terbinafine

 

 19   produces no additional benefit over the 1-week data

 

 20   shown in the last slide.

 

 21             After 1 or 4 weeks of treatment,

 

 22   terbinafine has essentially equivalent efficacy for

 

                                                               240

 

  1   all three endpoints.  This is not the case with

 

  2   clotrimazole even if it is used for the full 4

 

  3   weeks as it is currently labeled.

 

  4             [Slide.]

 

  5             This slide demonstrates the impact of

 

  6   these different treatment outcomes at 12 weeks.  As

 

  7   you can see, only 9 percent of patients go on to

 

  8   have relapse on terbinafine with 1 week of

 

  9   treatment, and 11 percent with 4 weeks of

 

 10   treatment, compared to higher rates with

 

 11   clotrimazole of 47 and 30 percent, respectively.

 

 12             This reflects the potency and sensitivity

 

 13   of terbinafine.

 

 14             [Slide.]

 

 15             This slide shows the same data just viewed

 

 16   now in a line format to allow us to look at the

 

 17   time course of the effect on mycology over the 12

 

 18   weeks evaluation.

 

 19             As you can see, the red lines which

 

 20   represent terbinafine treatment, there is no

 

 21   difference between the 1 week and 4 week treatment.

 

 22   There is, in contrast, clotrimazole, in the yellow,

 

                                                               241

 

  1   where the 4-week treatment shows a remarkable

 

  2   difference from the 1-week treatment, highlighting

 

  3   the potential impact on treatment outcomes in those

 

  4   who do not complete the 4-week treatment course.

 

  5             [Slide.]

 

  6             This shows the same depiction for signs

 

  7   and symptoms for the 12-week assessment period.

 

  8   This slide also serves as a nice overview of the

 

  9   effectiveness of terbinafine.  As you can see, it

 

 10   produced comparable efficacy at 1 and 4 weeks.

 

 11             Within days of initiating treatment, signs

 

 12   and symptoms are reduced.  However, after about 6

 

 13   weeks, you can see a plateau in the effect,

 

 14   demonstrating that some signs persist over an

 

 15   extended period of time.

 

 16             The clotrimazole data demonstrate that

 

 17   when used for a full 4 weeks course, favorable

 

 18   resolution of signs and symptoms comparable to

 

 19   terbinafine can be achieved.  However, when used

 

 20   for only 1 week, as consumers often do, the results

 

 21   are significantly less favorable.

 

 22             This confirms what Dr. Elewski presented

 

                                                               242

 

  1   earlier from the clinical experience in her

 

  2   patients.

 

  3             Now, in response to FDA's questions, I

 

  4   would like to present our perspective on new

 

  5   product development requirements.

 

  6             [Slide.]

 

  7             There are two different types of

 

  8   development approaches in this category involving

 

  9   either new chemical entity or an NDA line extension

 

 10   of a currently available compound.

 

 11             All new developments, whether NCEs or line

 

 12   extensions, should require a statistically

 

 13   significant separation from placebo using the

 

 14   complete cure endpoint to demonstrate efficacy as

 

 15   required for Rx drugs, where NCE studies may also

 

 16   be required to define the appropriate dose.

 

 17             With respect to line extensions, where the

 

 18   dose of the active has already been effectively

 

 19   established, the dermal pharmacokinetics and MIC

 

 20   values for the new formulation of the known drug

 

 21   should guide dose decisionmaking.

 

 22             Based on this approach, line extensions

 

                                                               243

 

  1   would require clinical evaluations to establish the

 

  2   appropriate frequency and duration, but would not

 

  3   necessitate dose ranging studies.

 

  4             [Slide.]

 

  5             Having established the effectiveness of

 

  6   terbinafine and provided our perspective on new

 

  7   product development, I would like to spend a few

 

  8   moments of my presentation responding to the

 

  9   questions regarding safety and labeling raised by

 

 10   the Agency.

 

 11             [Slide.]

 

 12             Starting with the lack of effectiveness or

 

 13   LOE reports, the Agency has noted that there has

 

 14   been an increasing number of these reports in their

 

 15   AERS database. In fact, overall, the number of

 

 16   adverse reports we receive for topical Lamisil is

 

 17   quite small.

 

 18             LOE reports are captured as part of the

 

 19   adverse event reporting.  As you see in the middle

 

 20   row at the bottom of this chart, it represents the

 

 21   absolute number of LOE reports received for topical

 

 22   Lamisil.

 

                                                               244

 

  1             Below that, we see the number of units

 

  2   sold during the same time frame.  Consequently, the

 

  3   graph gives you the ratio of these numbers and

 

  4   demonstrates a declining rate of LOE reports as a

 

  5   percentage of product purchases since the launch of

 

  6   the OTC product.

 

  7             [Slide.]

 

  8             In the interest of understanding whether

 

  9   effectiveness has changed over time, we compared

 

 10   studies conducted over the last decade and found no

 

 11   difference in efficacy.

 

 12             Other analyses have confirmed that the

 

 13   species of dermatophytes in our studies that cause

 

 14   athlete's foot are the same over time.  They

 

 15   continue to be fully susceptible to terbinafine.

 

 16             [Slide.]

 

 17             The Agency also raised the questions of

 

 18   whether the risk of cellulitis is increased in

 

 19   inadequately treated tinea pedis.  It is well

 

 20   understood that cellulitis is rare, and is not

 

 21   related to the drug per se.  In fact, it could even

 

 22   be misdiagnosed, as we heard this morning.

 

                                                               245

 

  1             In the AERS database, a review of all 15

 

  2   topical antifungals, there were only cases of

 

  3   collection since 1965. Since 1993, cases have been

 

  4   reported in connection with Lamisil.  The

 

  5   relationship between cellulitis and drug treatment

 

  6   in these cases is unclear.

 

  7             There also does not appear to be an

 

  8   increase in cellulitis reports over time.  However,

 

  9   inadequately treated tinea pedis may make

 

 10   individuals more prone to this infection.

 

 11             The data indicate that certain

 

 12   subpopulations, such as people with diabetes, may

 

 13   be at the higher risk of cellulitis, but that the

 

 14   risk may actually be reduced by effective

 

 15   antifungal treatment.

 

 16             Our recommended label changes would

 

 17   include a warning for people with diabetes and

 

 18   other identified risks.

 

 19             [Slide.]

 

 20             Regarding other labeling changes, we have

 

 21   given great consideration to the issues raised by

 

 22   the FDA, and are pleased to share our labeling

 

                                                               246

 

  1   recommendations, which are intended to optimize the

 

  2   consumer benefit with terbinafine, and what do we

 

  3   know about the patient experience.

 

  4             We know they are equally satisfied whether

 

  5   they achieve the effective treatment or complete

 

  6   cure endpoints.

 

  7             [Slide.]

 

  8             As you can see in this chart, the

 

  9   comparison evaluates patient global assessment

 

 10   scores from the analysis of one of our clinical

 

 11   trials.  Patients who achieve either effective

 

 12   treatment or complete cure were selected and had

 

 13   equivalent findings on the global assessment scale.

 

 14             Based on clinical and consumer experience,

 

 15   we conclude that effective treatment should be the

 

 16   basis for setting consumer expectations for product

 

 17   performance, and therefore be reflected in

 

 18   labeling.

 

 19             [Slide.]

 

 20             If this committee recommends that new

 

 21   label be developed for NDA products to set consumer

 

 22   expectations about treatment outcomes, we recommend

 

                                                               247

 

  1   that effective treatment be the guide.  These

 

  2   improvements will set appropriate expectations,

 

  3   enhance compliance, optimize treatment outcomes,

 

  4   and provide stronger safety guidance.

 

  5             Consequently, monograph products should

 

  6   add similar language indicating the required

 

  7   duration of treatment and indicate if no reliable

 

  8   clinical data are available.  We would like to take

 

  9   you through our current thinking on propose

 

 10   labeling changes for the class using terbinafine as

 

 11   an example.

 

 12             We agree that there is potential confusing

 

 13   language in the current PDP or primary display

 

 14   panel of the packages.

 

 15             [Slide.]

 

 16             We recommend removing "Cures most

 

 17   athlete's foot" and replacing that language with

 

 18   "Athlete's foot treatment."

 

 19             To enhance compliance, we also recommend

 

 20   making treatment duration prominent in this primary

 

 21   display panel. For example, we would replace

 

 22   current language with information that helps

 

                                                               248

 

  1   consumers understand they are treating an

 

  2   infection, and for the full course of treatment.

 

  3             This is the most important language to

 

  4   communicate in the label.  All products in this

 

  5   category should clearly delineate the required

 

  6   duration of treatment.

 

  7             In the case of Lamisil, the statement

 

  8   would be, "Must be used twice daily for full 7 days

 

  9   to eliminate fungal infection."

 

 10             We also recommend moving the language on

 

 11   "Relieves itching and burning" to the Drug Facts.

 

 12             [Slide.]

 

 13             Here, we remind the consumer about

 

 14   completing the full course of treatment even if

 

 15   symptoms resolve.  What we want to do is help

 

 16   consumers manage the expectations toward treating

 

 17   symptoms and signs.

 

 18             This copy may read, "Many get relief from

 

 19   their symptoms (itching and burning) after 1 week

 

 20   of treatment.  Signs such as redness will last

 

 21   longer until the outer layer of skin naturally

 

 22   replaces itself."

 

                                                               249

 

  1             Additionally, we recommend strengthening

 

  2   the warnings specific to diabetics.  For example,

 

  3   that language would read, "Stop use and ask a

 

  4   doctor if condition worsens or new symptoms

 

  5   develop; this is especially important if you have

 

  6   diabetes."

 

  7             In short, these changes will improve

 

  8   health outcomes for the millions of consumers with

 

  9   athlete's foot who count on these safe and

 

 10   effective treatments.

 

 11             We intend to test, refine, and implement

 

 12   enhanced labeling that will more clearly guide

 

 13   those who use our antifungal products, so that

 

 14   their expectations are well met and their outcomes

 

 15   improved.

 

 16             [Slide.]

 

 17             In conclusion, we have provided data from

 

 18   a variety of sources that confirm the safety,

 

 19   effectiveness, and unique benefits of terbinafine

 

 20   when used for 1 week with no evidence of increased

 

 21   lack of effectiveness or resistance development.

 

 22             While we recognize complete cure as the

 

                                                               250

 

  1   appropriate endpoint for the approval of OTS

 

  2   topical antifungals, effective treatment is the

 

  3   most meaningful endpoint for communicating efficacy

 

  4   information in labeling.

 

  5             We have provided commentary on how future

 

  6   products might be developed and have highlighted

 

  7   the rationale by which new chemical entities should

 

  8   be held to a higher standard than line extensions

 

  9   based on separation from placebo.

 

 10             Finally, we share the goal of improving

 

 11   consumer health outcomes.  We have presented our

 

 12   proposed labeling and delineated its clear purpose.

 

 13             We thank the committee for your time and

 

 14   interest and look forward to your input and

 

 15   guidance, as well, to further collaboration with

 

 16   FDA to bring label improvements that maximize the

 

 17   safety and effectiveness of these important

 

 18   therapies.

 

 19             I will be glad to address any questions

 

 20   you may have.

 

 21             Thank you very much.

 

 22             DR. CANTILENA:  Thank you, Dr. Albrecht.

 

                                                               251

 

  1             I will actually ask all the speakers from

 

  2   the open public hearing to come up to the podium

 

  3   and we will open this up to questions from the

 

  4   committee members.  You can just identify who you

 

  5   are asking, if you know, and we will start with Dr.

 

  6   Fincham.

 

  7             DR. FINCHAM:  I have a question for Dr.

 

  8   Albrecht. You presented data from two studies,

 

  9   2506-01 and 2508-01.  In the 2506-01, you listed

 

 10   the sample size as 67.  Was that in both treatment

 

 11   arms or was that total patients?

 

 12             DR. ALBRECHT:  No, that is total, that is

 

 13   total patients, one of our pivotal studies in the

 

 14   NDA.

 

 15             DR. FINCHAM:  So, approximately 35 in

 

 16   each.

 

 17             DR. ALBRECHT:  Yes.

 

 18             DR. FINCHAM:  In the second study, on one

 

 19   slide, you said the sample size was 97.

 

 20             DR. ALBRECHT:  Yes.

 

 21             DR. FINCHAM:  And in the other slide it

 

 22   was listed as 193.

 

                                                               252

 

  1             DR. ALBRECHT:  Yes.  Actually, the total

 

  2   size is 193.  In fact, these data were presented

 

  3   this morning by the FDA, as well.  The 97 relates

 

  4   to two treatment groups I showed in that chart,

 

  5   which is the 1 week and the 4 week, so we have

 

  6   broken that up.  It is 97 for the 1 week and 96 for

 

  7   the 4 weeks, so it adds up to the 193.  That was

 

  8   the total study size, 4 treatment legs, 1 week

 

  9   terbinafine, 1 week clotrimazole, 4 weeks

 

 10   clotrimazole, and 4 weeks terbinafine.

 

 11             DR. FINCHAM:  Just a follow-up question,

 

 12   if I might, sir.  How were the subjects chosen to

 

 13   be in each of those arms?

 

 14             DR. ALBRECHT:  They were randomly assigned

 

 15   to the treatments.

 

 16             DR. CANTILENA:  Other questions on the

 

 17   committee?  Dr. Davidoff.

 

 18             DR. DAVIDOFF:  I have a comment and a

 

 19   question.

 

 20             The comment relates to the apparent close

 

 21   tie between changes in symptoms, or appearance of

 

 22   symptoms, or disappearance of symptoms, to where

 

                                                               253

 

  1   the people start or stop therapy, because I was

 

  2   noticing, looking back at the data that Dr. Fritsch

 

  3   presented this morning, that the vehicle actually

 

  4   in the first week appears to be responsible for

 

  5   eliminating the symptom of pruritus--that is page

 

  6   12 of her slides--and for a sizable portion of the

 

  7   relief of pruritus even in the 4-week treatment

 

  8   with Drug Product F.

 

  9             I suppose that argues for being especially

 

 10   cautious about having patients stop treatment

 

 11   prematurely, because the treatment decision may be

 

 12   based on something that has nothing to do with the

 

 13   active drug.  That was just really a comment, and I

 

 14   would be curious whether you have any thoughts on

 

 15   that.

 

 16             The question had to do with the proposed

 

 17   statement of encouraging patients to be sure to

 

 18   take the full number of prescribed days of

 

 19   treatment, which I think everybody in medicine

 

 20   would agree with it in general that undertreatment

 

 21   and partial treatment is a bad thing particularly

 

 22   in light of potential emergence of resistant

 

                                                               254

 

  1   strains in bacteriological infections.

 

  2             However, it seems to me that it is quite

 

  3   possible, given some other data, that even a

 

  4   shorter period of treatment than 7 days might

 

  5   actually be as for, say, terbinafine, may be as

 

  6   effective as 7 days.

 

  7             My question is, are there data on that,

 

  8   because the drug apparently is there in such large

 

  9   quantities and persists even after you stop using

 

 10   it, that it is possible the organism is effectively

 

 11   eliminated on Day 2, so it would be a little hard

 

 12   to justify that statement, if that is the case.

 

 13             DR. ALBRECHT:  Thank you for the question.

 

 14   Perhaps to the first question you had, which was,

 

 15   of course, the drug product works as a composite.

 

 16   It is the drug in the composition and the vehicle.

 

 17   Of course, if you have a very good emollient

 

 18   vehicle, it will help to heal the condition.

 

 19             In the case of our product, it is very

 

 20   clear that terbinafine is such powerful fungicidal

 

 21   agent that it certainly kills the fungus, and then

 

 22   is symptoms persist, that is just the dynamics of

 

                                                               255

 

  1   the disease, as I showed.

 

  2             Now, in response to your other question,

 

  3   we actually have clinical data from controlled

 

  4   studies that show that terbinafine is effective in

 

  5   eradicating the fungal disease and eliminating the

 

  6   symptoms after 5 days.  We have the studies both

 

  7   with 7 days and 5 days in the same study leg.

 

  8             There also is, it's not on the market,

 

  9   terbinafine Rx derm gel preparation, which is

 

 10   effective both in 7 days and 5 days with a single

 

 11   day application.

 

 12             So, again, I think the potency of the

 

 13   antifungal compound is extremely important.

 

 14             DR. DAVIDOFF:  So, then, it isn't entirely

 

 15   justified to recommend treatment for the full 7

 

 16   days on the basis of the data.

 

 17             DR. ALBRECHT:  Well, we have a labeling

 

 18   for 7 days, we have not pursued a shorter treatment

 

 19   period, but I think if your patient should tell you

 

 20   they only treated for 6 days, you should probably

 

 21   feel quite comfortable that at least the fungus is

 

 22   being killed.

 

                                                               256

 

  1             DR. CANTILENA:  We have a comment over

 

  2   here from Dr. Wilkin.

 

  3             DR. WILKIN:  I would be interested if you

 

  4   are aware of any literature that speaks to

 

  5   allylamines, and I am actually blocking which ones

 

  6   were tested, but I thought they had modest

 

  7   cyclooxygenase inhibitor reactivity, some

 

  8   anti-inflammatory activity.

 

  9             Dr. Elewski seems to know that part.

 

 10             DR. ELEWSKI:  I know that.  There was a

 

 11   study done by I believe Ted Rosen in Texas, and he

 

 12   looked at that in sunburns. I think he actually did

 

 13   a study where he burned red skin from a sunburn to

 

 14   see what gets rid of the erythema the fastest, and

 

 15   judging what gets rid of erythema from a sunburn,

 

 16   he was looking at an allylamine with a trade name

 

 17   Naftifine.  It actually was a fairly good

 

 18   eliminator of inflammation.

 

 19             Consequently, some other drugs have been

 

 20   look at it this same fashion, Ciclopirox, which was

 

 21   mentioned this morning, is one of the more common

 

 22   prescription products, and so forth.

 

                                                               257

 

  1             So, I don't think it is a function of

 

  2   allylamines only, because Ciclopirox had it, and

 

  3   ketoconazole, I think had something similar, but it

 

  4   was done in a different way, but the paper was Ted

 

  5   Rosen, and it was looking at burns, if that helps.

 

  6             DR. WILKIN:  But the moiety we are talking

 

  7   about now is an allylamine.

 

  8             DR. ELEWSKI:  Right, Naftifine is an

 

  9   allylamine.

 

 10             DR. WILKIN:  And also terbinafine.

 

 11             DR. ELEWSKI:  Right.

 

 12             DR. CANTILENA:  Dr. Katz.

 

 13             DR. KATZ:  I have a question for Dr.

 

 14   Clayton concerning the consumer research data that

 

 15   you referred to, done on internet.

 

 16             How did you locate those patients in the

 

 17   first place and what was the percent of people who

 

 18   responded to that survey?

 

 19             DR. CLAYTON:  The patients or the

 

 20   consumers are identified through screeners of

 

 21   symptoms that they complain of, so it is done

 

 22   through a variety of signs.

 

                                                               258

 

  1             DR. KATZ:  How do you get the names to

 

  2   contact them on the internet?

 

  3             DR. CLAYTON:  I can't tell you.  A firm is

 

  4   employed that is skilled at surveying by internet.

 

  5             DR. KATZ:  Do you know the percentage of

 

  6   response?

 

  7             DR. CLAYTON:  I don't know the percentage

 

  8   of response.

 

  9             DR. KATZ:  We need to know.  Provides fast

 

 10   relief, 60 percent of the respondents, so how do we

 

 11   know that is not 6 percent of the respondents, the

 

 12   others didn't bother responding?

 

 13             DR. CLAYTON:  These are 350 that actually

 

 14   completed the survey.

 

 15             DR. KATZ:  But maybe 3,000 were surveyed.

 

 16   I mean we have no idea of this data that is being

 

 17   presented.

 

 18             DR. CLAYTON:  I apologize for the fact

 

 19   that it wasn't complete.  This survey that I

 

 20   reported today is very consistent with the others

 

 21   we have done for the past 10 years.  Some of them

 

 22   have been one by mail panels, some of them have

 

                                                               259

 

  1   been done by internet.

 

  2             This particular most recent one was done

 

  3   that way, but it is done through a statistical

 

  4   model that is used to validate the representation.

 

  5   I apologize for not having that information for you

 

  6   today.

 

  7             DR. GANLEY:  Could I comment on that, too?

 

  8             DR. CANTILENA:  Go ahead.

 

  9             DR. GANLEY:  We have seen some of these

 

 10   before, and there are internet sites where you can

 

 11   sign up and fill out a questionnaire and give some

 

 12   history about yourself. They create a database.

 

 13             For example, if you have a history of

 

 14   athlete's foot, they may ask you that question, and

 

 15   then when someone comes in for a survey, they will

 

 16   send out to all the respondents, you know, they may

 

 17   have several hundred thousand respondents and

 

 18   10,000 or 50,000 say that they have a history of

 

 19   athlete's foot, and then they will go out and send

 

 20   e-mails to all of those people, asking them if they

 

 21   are interested in participating in a survey.

 

 22             A certain percentage will come back and

 

                                                               260

 

  1   say yes. Now, the one thing about these sites is

 

  2   that you collect points by the more surveys that

 

  3   you fill out, and if you collect enough points, you

 

  4   will get some type of gift.

 

  5             DR. KATZ:  That is the point of my

 

  6   question.

 

  7             DR. GANLEY:  John, you can correct me if I

 

  8   am wrong.

 

  9             DR. CLAYTON:  As Dr. Ganley said, some are

 

 10   that way.  I, unfortunately don't have that

 

 11   information today. Again, it has been done by a

 

 12   variety of different methods over these 10 years,

 

 13   the data have been extremely consistent throughout

 

 14   except for the trends that we have noted.

 

 15             DR. KATZ:  But that type of survey would

 

 16   be highly questionable as far as the validity of

 

 17   who is responding to the internet and getting

 

 18   points and getting prizes for responding.  I think

 

 19   you would have to agree that the scientific

 

 20   validity of such a survey would be subject to

 

 21   question.

 

 22             DR. CLAYTON:  There have been standards

 

                                                               261

 

  1   set for these types of surveys as a general

 

  2   statement.  I am not addressing all that are out on

 

  3   the internet, but particularly the firms that we

 

  4   employ to do these types of things, they are

 

  5   validated against a certain model.  Unfortunately,

 

  6   as I said, that was done by a market research

 

  7   group, and I apologize for not having that

 

  8   information.

 

  9             DR. CANTILENA:  I think we can move on.

 

 10             Dr. Ringel.

 

 11             DR. RINGEL:  I think this question is best

 

 12   addressed to Dr. Elewski because she has had so

 

 13   much experience, breadth of experience with many

 

 14   different products.

 

 15             We have heard that most cases of tinea

 

 16   pedis, in fact, are moccasin style tinea pedis,

 

 17   whereas, I believe most of the studies have been

 

 18   done with interdigital tinea pedis.

 

 19             I was wondering if you or the companies

 

 20   that you have consulted for have data about the

 

 21   cure rates, mycological and clinical, for patients

 

 22   both with moccasin style and/or interdigital,

 

                                                               262

 

  1   first, and secondly, with patients who have

 

  2   onychomycosis along with their interdigital tinea

 

  3   pedis since probably those are the majority of

 

  4   patients who are going to be treated.

 

  5             DR. ELEWSKI:  The most common type of

 

  6   tinea pedis that we see is the interdigital.  The

 

  7   interdigital is by far the most common, much more

 

  8   common than moccasin.  The interdigital is when the

 

  9   toe webs, you know, that we went over, the web

 

 10   spaces are infected, and the prime organism is

 

 11   Trichophyton rubrum.

 

 12             By the time someone has actually gone on

 

 13   to get the moccasin type tinea pedis, many of these

 

 14   people, if not all, have some form of onychomycosis

 

 15   by that point, so treatment with a topical

 

 16   antifungal poses some challenges because if you use

 

 17   a topical antifungal for moccasin, you probably

 

 18   could eventually eradicate the dermatophyte from

 

 19   the bottom of the foot, but the problem is you

 

 20   still have dermatophytosis in the nail, which will

 

 21   eventually--what I teach our residents are the

 

 22   fungi are greedy and they want to continue to grow,

 

                                                               263

 

  1   and if you get rid of it from the bottom of the

 

  2   foot, the plantar surface, it may eventually come

 

  3   back from the nail.

 

  4             So, unless you eradicate the fungus in the

 

  5   nail, then, you probably will have recurrence down

 

  6   the road, but interdigital tinea pedis can occur

 

  7   without onychomycosis, in fact, it generally does

 

  8   especially in the epidemics that you see from

 

  9   swimming pools, gyms, and health spas, and so

 

 10   forth.

 

 11             The interdigital, simple and complicated,

 

 12   is a simple scaling process, and these people don't

 

 13   have onychomycosis.

 

 14             DR. RINGEL:  Perhaps someone at the FDA

 

 15   could help me.  I believe in the package that we

 

 16   got before the meeting, moccasin style tinea pedis

 

 17   was about 50 percent, isn't that correct?

 

 18             At any rate, do you have data for

 

 19   clearance of moccasin style tinea pedis?

 

 20             DR. ELEWSKI:  Well, for moccasin--the

 

 21   antifungals we are talking about now, that are OTC,

 

 22   are for interdigital tinea pedis--for moccasin

 

                                                               264

 

  1   tinea pedis, there have been studies looking at it

 

  2   for topical antifungals, and it has to be done

 

  3   longer.

 

  4             For example, and I could probably defer to

 

  5   Novartis, because there has been a study looking at

 

  6   it, and it is 1 week for interdigital, I understand

 

  7   it would it would be 4 weeks for moccasin tinea

 

  8   pedis.

 

  9             DR. ALBRECHT:  It's 2 weeks.

 

 10             DR. ELEWSKI:  Oh, it's 2 weeks.

 

 11             DR. ALBRECHT:  The Lamisil AT cream is

 

 12   labeled for 2 weeks of treatment for moccasin.

 

 13             DR. RINGEL:  So, do you think that should

 

 14   be on the labeling what kind of tinea pedis is

 

 15   being treated?

 

 16             DR. ALBRECHT:  It is on the labeling.  If

 

 17   you look at our labeling, in fact, there is even

 

 18   images for interdigital foot as opposed to another

 

 19   image for the sides of the foot, which indicates to

 

 20   the consumer the plantar form.  So, there are two

 

 21   indications on the label, and they are differently

 

 22   instructed in terms of duration of treatment and

 

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  1   the imagery, how to apply the product.

 

  2             DR. WHITMORE:  I don't think we saw

 

  3   efficacy data on that, and I think Dr. Ringel and I

 

  4   would also like to know the effectiveness, the

 

  5   efficacy of the study with the plantar for 2 weeks

 

  6   as indicated on the label.

 

  7             DR. ALBRECHT:  Right.  Again, the meeting

 

  8   was focused on interdigital, so I didn't put the

 

  9   data into my presentation.  Do we have them handy?

 

 10             DR. CANTILENA:  You could have life-line,

 

 11   if you would like, and call home, or we can poll

 

 12   the audience, that's right.

 

 13             [Laughter.]

 

 14             DR. CANTILENA:  Dr. Whitmore.

 

 15             DR. WHITMORE:  Are there different studies

 

 16   done with each of the different vehicles, for

 

 17   instance, Lotramin Ultra Cream versus Lotramin

 

 18   Antifungal Cream and also with Lamisil Spray versus

 

 19   Cream?  Is there a superior vehicle that produces

 

 20   better clearance, or why the different vehicles?

 

 21             DR. ALBRECHT:  Different vehicles because

 

 22   the consumers actually like variety.  In fact,

 

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  1   consumers are very form loyal, if consumers like a

 

  2   cream or consumers like a spray or a powder, so we

 

  3   do separate studies on the cream, and we have

 

  4   separate studies in our solution, and the efficacy

 

  5   of both vehicles is quite comparable.

 

  6             DR. WHITMORE:  Is the same true for

 

  7   Lotramin Ultra Cream?

 

  8             DR. CLAYTON:  Actually, Lotramin Ultra

 

  9   Cream is only in cream form, so it is the only

 

 10   dosage form, but comparative studies against other

 

 11   active ingredients, I don't believe they have been

 

 12   done.  There may be a few out there, but not

 

 13   pivotal type, large-scale studies.

 

 14             DR. WHITMORE:  Do you use anything to

 

 15   direct consumers to which they should purchase?

 

 16             DR. CLAYTON:  Other than through

 

 17   advertising, not directly.  I mean the labeling

 

 18   certainly describes the treatment regimens

 

 19   specifically, but only through those means of

 

 20   communication.

 

 21             DR. CANTILENA:  Thank you.

 

 22             Dr. Benowitz.

 

                                                               267

 

  1             DR. BENOWITZ:  I have two questions.  Dr.

 

  2   Elewski would probably be the one to address them.

 

  3             The first is you made the point that you

 

  4   think effective therapy is equivalent to cure by

 

  5   the criteria we heard this morning.  I am just

 

  6   wondering, do you know of any data on relapse using

 

  7   those two criteria, or may recurrence or long-term

 

  8   outcomes?

 

  9             DR. ELEWSKI:  I don't have data on that,

 

 10   but let me expound a little bit on what you said

 

 11   for effective therapy, because one thing I didn't

 

 12   use as an analogy is acne.  You know, it is hard to

 

 13   evaluate skin studies, and if you are treating, for

 

 14   example, something like acne, what do you say is

 

 15   the endpoint, is it getting rid of the comedones,

 

 16   is it getting rid of the pustules, is it getting

 

 17   rid of the papules or nodules or cysts, of is it

 

 18   getting rid of the scarring or the oil?

 

 19             So, at the end of the study, if you still

 

 20   have scarring or you still have oil, does that mean

 

 21   you still have acne?  No.  Likewise, that is what I

 

 22   was getting at for effective treatment, if you have

 

                                                               268

 

  1   a little bit of erythema, a little it of scale that

 

  2   may be unrelated, it could be effective treatment.

 

  3             As for data, probably the best study was

 

  4   the study that was alluded to this morning looking

 

  5   at Lamisil/Terbinafine 1 week versus 4 weeks, and

 

  6   looked at it after--I wrote this many years ago, so

 

  7   it is hard to remember--I think it was 48 percent

 

  8   in those who used it for a month, and it was 42

 

  9   percent in those who used it for a week, had no

 

 10   recurrence at 1 year or longer.

 

 11             Of those that recurred, one-third actually

 

 12   had a new organism, implying that they didn't

 

 13   really recur, they got a new infection.  So, that

 

 14   is probably the best study looking at that, that I

 

 15   know of, unless any of the industry colleagues want

 

 16   to add to that.

 

 17             DR. BENOWITZ:  I was just trying to be

 

 18   sure that the finding of mild symptoms really means

 

 19   the same thing as a cure in terms of recurrence

 

 20   rates, because the efficacy or efficient, whatever

 

 21   the term is, shows about 80 percent outcome for

 

 22   that endpoint, but yet there is about a 40 percent

 

                                                               269

 

  1   recurrence rate.

 

  2             I am just trying to figure out can we

 

  3   really be sure that what you are saying in terms of

 

  4   effective outcome is the same as cure.

 

  5             DR. ELEWSKI:  The issue, I think, is the

 

  6   word "recurrence," because how do you define

 

  7   recurrence?  Is it recurrence meaning you never got

 

  8   rid of the infection in the first place, so the

 

  9   infection recurred?  Or is recurrence that they got

 

 10   rid of the infection, but they put their feet back

 

 11   in their fungal-ridden shoes, as someone mentioned

 

 12   already?  You have fungus in your shoes, as Dr.

 

 13   Wilkin mentioned, and they got a new infection.

 

 14             So, it is very hard to sort this out.  I

 

 15   know Dr. Ghannoum and I at one point were looking

 

 16   at doing molecular strain types on initial

 

 17   infections to see if someone got a new infection,

 

 18   which we could call a recurrence, if you wish,

 

 19   whether it was really a recurrence or whether it

 

 20   was a new infection.

 

 21             You could do this if you found the

 

 22   molecular strain of infection A, and then six

 

                                                               270

 

  1   months down the road, they get a new infection,

 

  2   what is the molecular strain type of that new

 

  3   infection, you know, looking at the DNA pattern of

 

  4   the organism.

 

  5             We have never done that.  I don't know if

 

  6   you have.

 

  7             DR. GHANNOUM:  Actually, you know, we were

 

  8   trying to do that.  At that time, there was no

 

  9   method which allows differentiation of different

 

 10   strains, that allows you to differentiate rubrum

 

 11   from mentagrophytes, but not between rubrum.

 

 12             Now, the good news is there is a method

 

 13   that allows people to differentiate between two

 

 14   different strains for T. rubrum, for example, or

 

 15   mentagrophytes, and I think maybe pretty soon we

 

 16   will be able to have some sequential isolates to

 

 17   follow that.

 

 18             DR. BENOWITZ:  I understand that.  That is

 

 19   not really my point.  I think there are probably no

 

 20   data.

 

 21             My point is just however you look at

 

 22   recurrence, do we know it is the same for someone

 

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  1   who has a complete cure by the definition we heard

 

  2   this morning, versus effective treatment.

 

  3             DR. ELEWSKI:  I can tell you from my own

 

  4   practice, from my own patients, when I have a

 

  5   patient and they finish their treatment, and I see

 

  6   them a month later, and the majority of their

 

  7   symptoms and signs are resolved, and they may have

 

  8   just a wee it of something left, and I follow them

 

  9   again, for other reasons, they come in for problem

 

 10   A or B or C down the road, they generally are still

 

 11   free of fungus.

 

 12             Some of them will go on to get something

 

 13   new.  I am particularly interested in this, so I

 

 14   like to do cultures.  I am out there doing cultures

 

 15   where many people don't.  Often it is a different

 

 16   organism.  I just like to do that for academic

 

 17   interest, but I have never published that.

 

 18             No, there is no data that I am aware of.

 

 19             DR. BENOWITZ:  The second question that I

 

 20   had is you made a statement and supplied some

 

 21   evidence for why you thought there was no need to

 

 22   do dose responses.

 

                                                               272

 

  1             My question is, why was the particular

 

  2   dose chosen, has been chosen for the various drug,

 

  3   and without doing a dose response, how can you be

 

  4   sure that you don't need to do a dose response?

 

  5             DR. ELEWSKI:  I think I should defer that

 

  6   to the companies who have the drugs.

 

  7             Do you want to comment on that?

 

  8             DR. ALBRECHT:  I can offer comment.  I

 

  9   think I showed the data that we, based on the MIC

 

 10   values, and then based on the availability of the

 

 11   drug in the skin, it was determined that we had an

 

 12   effective dose at a low level, and therefore, no

 

 13   safety issue involved, pursued that further for

 

 14   clinical development.

 

 15             DR. CLAYTON:  I would give a similar

 

 16   response except that there are also some studies

 

 17   that have been done with some of the drugs using

 

 18   guinea pig models, infected guinea pig models to

 

 19   determine various concentrations, and differences

 

 20   in outcomes on those.

 

 21             I am not aware of many, if any, clinical

 

 22   trials that are comparing true dose response.

 

                                                               273

 

  1             DR. ELEWSKI:  The objective is to exceed

 

  2   the MIC of the fungus and eradicate the organism.

 

  3   I think we are doing that with the antifungals

 

  4   available for superficial cutaneous fungal

 

  5   infections, which is the issue on the table.

 

  6             DR. BENOWITZ:  So, can we be as sure for

 

  7   concentrations in the skin?  I know for blood it's

 

  8   simpler because there is organism in the blood and

 

  9   we get a concentration of an antibiotic in the

 

 10   blood, and we can sort of make sense out of the

 

 11   MIC, but can we extrapolate that to skin

 

 12   concentrations versus MIC acting on fungus in the

 

 13   skin?

 

 14             DR. ELEWSKI:  I can't really comment on

 

 15   that.  I don't know if anyone else wants to.

 

 16             DR. CANTILENA:  Okay.  No one is going to

 

 17   move on that.  Is there a comment?  You had your

 

 18   hand up, Dr. Wilkin.

 

 19             DR. WILKIN:  I think Dr. Benowitz asked a

 

 20   really key question, and that is what is the gold

 

 21   standard for cure.  I think that is what you were

 

 22   going after.  Dr. Elewski has obviously thought a

 

                                                               274

 

  1   lot about this, and many of the things that you

 

  2   have thought about, our dermatology group at FDA,

 

  3   you know, I have to say that we think in many of

 

  4   the details along the same line.  I think that may

 

  5   be a general dermatology perspective.

 

  6             One of the difficulties that we have had

 

  7   to wrestle with is since we are looking at just the

 

  8   three things, one is the KOH, that is, you scrape

 

  9   and you look and see if there is any evidence of

 

 10   the hyphae present.

 

 11             There is an enormous sampling error

 

 12   difficulty.  One of the exercises that a first year

 

 13   resident gets to do, or a fourth year medical

 

 14   student rotating on Dermatology, is you have them

 

 15   scrape the foot and do a KOH.  They can't find it

 

 16   the first time, and you have them do it again, and

 

 17   they can't find it.

 

 18             Finally, on the third time, they may

 

 19   locate it. So, it's not the easiest thing to do

 

 20   even in the hands of a skilled investigator,

 

 21   sometimes there is one small area.  So, I think

 

 22   there are enormous sampling errors with the KOH.

 

                                                               275

 

  1             The culture may be the same.  We do

 

  2   actually have some information that helps us

 

  3   understand the culture.  The entry criteria for the

 

  4   kinds of studies that we are discussing today are

 

  5   patients who have a positive KOH, and they look to

 

  6   the clinician as though they have the presentation

 

  7   of tinea pedis.  That is what gets the patient into

 

  8   the study.

 

  9             So, that patient would be in the

 

 10   intent-to-treat group.  They also get a culture at

 

 11   baseline, and then three weeks later, either a

 

 12   dermatophyte grows out or it doesn't, and it

 

 13   doesn't grow out one-third of the time, so the MITT

 

 14   group is typically on the order of 65 percent of

 

 15   the ITT group.

 

 16             That tells me that there is that same

 

 17   problem with the culture, is that when it is

 

 18   negative, it may have less informative value, that

 

 19   there can be enormous sampling errors.

 

 20             Nonetheless, we are willing to take

 

 21   mycological negativity, if you will, negative KOH,

 

 22   negative culture, and then look at the skin signs,

 

                                                               276

 

  1   and I think as Dr. Elewski has pointed out, the

 

  2   skin has a very limited repertoire in response to

 

  3   any kind of noxious agent, be it atopic dermatitis,

 

  4   contact dermatitis, or tinea pedis, or the

 

  5   dermatophyte.

 

  6             I mean it can scale, it can get red.  It

 

  7   doesn't really have many other things in its

 

  8   vocabulary.  So, there is some confusion when you

 

  9   get down to the 1-plus erythema and 1-plus scale.

 

 10   It is probably true that some of those patients

 

 11   represent a cure and some of them don't. I think it

 

 12   may go both ways.

 

 13             It may be too high a hurdle on the foot to

 

 14   actually demand zero clinical signs and symptoms,

 

 15   but we like looking at that because it is such a

 

 16   pristine group.  I mean it's a nice comparator from

 

 17   one product to the next, especially when we are

 

 18   comparing against the placebo, so we didn't really

 

 19   prepare that part for the discussion today, but I

 

 20   am glad Dr. Benowitz brought it up.

 

 21             There is no gold standard.  It would

 

 22   really require people who got new shoes, maybe went

 

                                                               277

 

  1   to the International Space Station where there is

 

  2   no dermatophytes on the floor, and they were

 

  3   watched over an entire year to see whether or not

 

  4   the fungus came back.  So, that is a little on the

 

  5   epistemology, if you will, of what we really do

 

  6   know.

 

  7             The second part, I would like to say is

 

  8   about do antifungals get to the site of action.  I

 

  9   think it is true that you can scrape skin, you can

 

 10   lift it off with tape strips, and you can find that

 

 11   the active is there, but we all know that it needs

 

 12   to be in solution before it is really going to be

 

 13   active.

 

 14             The other thing is Robert Jackson has got

 

 15   a really nice paper, and Dr. Elewski probably knows

 

 16   the exact citation, but it is the one where

 

 17   dermatophytes move in a centrifugal manner, I mean

 

 18   they move out, so that the leading edge, when you

 

 19   were looking at the very nice picture of between

 

 20   the fourth and fifth toe, that center part that

 

 21   everyone was focused on, that is probably

 

 22   gram-negative bacteria in that location.

 

                                                               278

 

  1             The actual dermatophyte is out in what

 

  2   looks like normal-appearing skin out at the edge,

 

  3   and I think it is really very difficult to get

 

  4   these large chemicals to that location down through

 

  5   that very thick stratum corneum, so I don't think

 

  6   we have seen at FDA really good data to tell us

 

  7   that these products are in solution at the site of

 

  8   action, at that location, and it is a 1 to 1

 

  9   relationship.

 

 10             I guess I will stop at that.

 

 11             DR. CANTILENA:  Thank you.

 

 12             Did you have a comment on this question,

 

 13   Dr. Ghannoum?

 

 14             DR. GHANNOUM:  Which question?

 

 15             DR. CANTILENA:  On the comment that was

 

 16   raised over here by Dr. Benowitz.

 

 17             DR. GHANNOUM:  I just wanted to comment

 

 18   about a couple of things.  Number one is about how

 

 19   really do we determine the vehicle or the dose.  A

 

 20   lot of the time, I know our Center gets studies in

 

 21   guinea pig model, which was mentioned, and that

 

 22   guinea pig model we look at different vehicles and

 

                                                               279

 

  1   say which one, let's say, caused this erythema, and

 

  2   the same applies for the doses.  We really do,

 

  3   let's say, three, four doses, and then select the

 

  4   best one.

 

  5             I think industry at that time, then, they

 

  6   take it, that's one thing.

 

  7             I want also to comment about the

 

  8   International Space Station.  In actual fact, there

 

  9   is Trichophyton there, they found.

 

 10             [Laughter.]

 

 11             DR. GHANNOUM:  There was a study, and it

 

 12   was there.  So, I don't know where it came from,

 

 13   but it was there.

 

 14             The last point is about the calcofluor and

 

 15   the KOH, the difficulty in that.  I think really it

 

 16   is very important to use, not just regular KOH, use

 

 17   the calcofluor, because you can improve the

 

 18   sensitivity because this dye is specific for it,

 

 19   and I think a lot of the studies, like from 53

 

 20   percent, you can improve it up to 80 percent.

 

 21             DR. CANTILENA:  Thank you.

 

 22             Dr. Wilkerson.

 

                                                               280

 

  1             DR. WILKERSON:  Dr. Elewski, one question.

 

  2   There has been a lot of talk over the years about

 

  3   yeast and bacteria, and I haven't heard much about

 

  4   that today.  Some of these compounds are more

 

  5   effective from what I understand from what people

 

  6   say, which isn't always true.

 

  7             Overall, do yeast and gram-negative

 

  8   bacteria, one thing and another, play, and how

 

  9   important is it that the agents that you are

 

 10   treating with have activity against those also?

 

 11             DR. ELEWSKI:  That would be called, if you

 

 12   had a yeast or bacteria in the toe web, we could

 

 13   call that toe-web intertrigo.  It could have

 

 14   started with a dermatophyte.  I think one of the

 

 15   speakers talked about how Dr. Layden and Kligman

 

 16   described this, and they described it as a syndrome

 

 17   of dermatophytosis complex, where the dermatophyte,

 

 18   which is able to digest the keratin, damages the

 

 19   keratin, destroys the barrier function, and allow

 

 20   bacteria to enter.

 

 21             Then, you may get a weeping, macerated toe

 

 22   web in that scenario.  I actually did a study

 

                                                               281

 

  1   looking at this, and we found that topical azole

 

  2   family category, and we were using Econazole cream

 

  3   as an example, and we published this and found that

 

  4   it had a lot of antibacterial activity, because we

 

  5   culture people beforehand and treated them with

 

  6   Econazole, and they did very well.

 

  7             We can extrapolate from that and from

 

  8   others who have written about this that the azole

 

  9   family Econazole, clotrimazole, and so forth, have

 

 10   some antibacterial activity, and also anti-yeast

 

 11   activity.

 

 12             Now, candida can also be a pathogen in the

 

 13   toe web, but it is extremely rare, and it generally

 

 14   would be a secondary problem, and probably I would

 

 15   think if it is there, it probably came riding on

 

 16   the back of a dermatophyte, so if you killed the

 

 17   dermatophyte, then, you would eradicate everything

 

 18   that was there because of the dermatophyte, and the

 

 19   same thing you could also say with this

 

 20   dermatophytosis complex.  If you kill the

 

 21   dermatophyte, well, the dermatophyte was the way

 

 22   that the bacteria could get a hold in the foot, so

 

                                                               282

 

  1   if you kill it, there is nothing left for the

 

  2   bacteria to do but leave.

 

  3             DR. WILKERSON:  Well, I think where this

 

  4   is important is particularly when we are talking

 

  5   about diabetics and other immunocompromised

 

  6   situations where it may be more important.  My

 

  7   understanding is that allylamines do not have much

 

  8   of this activity towards yeast, and I don't know

 

  9   what their activity towards bacteria is.

 

 10             DR. ELEWSKI:  The allylamines have less

 

 11   activity for yeast and less activity for bacteria

 

 12   than the azoles, however, we are talking about now

 

 13   a topical antifungal, so if you were to take a

 

 14   drug, such as oral terbinafine orally, it is not

 

 15   going to be very effective for cutaneous candida,

 

 16   again because terbinafine would have to get

 

 17   absorbed, get into the skin, and it wouldn't get

 

 18   into the skin in high enough concentration to kill

 

 19   Candida albicans.

 

 20             It might kill Candida parapsilosis, but

 

 21   not Candida albicans, but applying it topically, it

 

 22   is a very effective drug for Candida.

 

                                                               283

 

  1             Another example could be another yeast

 

  2   Pityrosporon.  Terbinafine doesn't get into the

 

  3   skin in high enough concentrations orally to kill

 

  4   Pityrosporon, but you can apply it topically to

 

  5   kill Pityrosporon, because it is exceeding the

 

  6   yeast.

 

  7             So, when using these drugs topically, they

 

  8   generally, because you are applying to the skin in

 

  9   high enough levels, are going to exceed the MICs of

 

 10   the dermatophytes, of Candida, and of some, but not

 

 11   all, bacteria.

 

 12             The bacteria that I still see a problem in

 

 13   my patients who have bacterial infections, some of

 

 14   which are diabetic, most of whom, though, have an

 

 15   anatomical occlusion causing a deformity, which

 

 16   leads to maceration because of the deformity, and

 

 17   they may have pseudomonas, and that can be a

 

 18   problem.

 

 19             I have seen a few, a handful of patients

 

 20   with chronic pseudomonas in the toe web, that the

 

 21   only thing that I have been able to do to eradicate

 

 22   that is topical gentamicin, garamycin product or

 

                                                               284

 

  1   oral products that are appropriate, but that is

 

  2   very, very rare, but nonetheless, I have seen.

 

  3             DR. CANTILENA:  Thank you.

 

  4             DR. WILKERSON:  One other part of my

 

  5   question was to the Schering-Plough

 

  6   representatives.  My understanding is Lotramin

 

  7   Ultra is a different compound than Lotramin AF, is

 

  8   that correct?

 

  9             DR. CLAYTON:  Yes, Lotramin Ultra uses

 

 10   butenafine hydrochloride, whereas, Lotramin AF is

 

 11   clotrimazole.

 

 12             DR. WILKERSON:  Outside of playing on

 

 13   brand names, don't you consider that to be really

 

 14   confusing to consumers?

 

 15             DR. CLAYTON:  We have tried to communicate

 

 16   the difference.  We have tried to communicate it

 

 17   both through packaging and advertising, and we have

 

 18   been challenged by Dr. Ganley and his Division to

 

 19   test this with consumers, which we have done

 

 20   through actual label comprehension and

 

 21   understanding, but we have tried to make them

 

 22   happy, quite different in appearance and the

 

                                                               285

 

  1   communication piece also.

 

  2             DR. WILKERSON:  It was obviously done to

 

  3   play off of your brand name, correct?

 

  4             DR. CLAYTON:  It was done to establish

 

  5   credibility that existed in the marketplace, but

 

  6   there was the full intent to make sure that

 

  7   consumers could distinguish between the two.

 

  8             DR. CANTILENA:  That was a very good

 

  9   answer, by the way.

 

 10             Dr. Fincham.

 

 11             DR. FINCHAM:  I have a question for Doug

 

 12   Bierer.

 

 13             You mentioned in one of your slides, three

 

 14   hoped-for additions to labeling, and you mentioned

 

 15   a hope for increase in compliance.  I was just

 

 16   curious from your data, what is the baseline rate

 

 17   of compliance and what do you hope to gain as far

 

 18   as an increase in compliance by your proposal?

 

 19             DR. BIERER:  I don't actually have data on

 

 20   the baseline for compliance with these products.

 

 21   That would depend upon the individual product.  We

 

 22   don't collect that as an association.  I think you

 

                                                               286

 

  1   would have to talk with the individual companies.

 

  2             But I hope that we would see consumers

 

  3   understanding from this proposed labeling, which I

 

  4   think you have heard from both companies that they

 

  5   would understand that they should complete the full

 

  6   course of therapy even if their symptoms improve.

 

  7   I think that is the message that we want to

 

  8   communicate to consumers.

 

  9             DR. FINCHAM:  But nowhere did I hear

 

 10   anybody talk about specific compliance rates,

 

 11   unless I missed it.

 

 12             DR. BIERER:  No.

 

 13             DR. CLAYTON:  The only thing we had was

 

 14   consumer survey, which indicated that they were

 

 15   using it on average 7.3 days, and a high percentage

 

 16   was using it less--

 

 17             DR. FINCHAM:  I guess I am talking about

 

 18   both duration, as well as intensity, and nobody

 

 19   talked about specific intensity, just the duration.

 

 20             DR. CLAYTON:  You mean numbers of

 

 21   applications per day?  Some of the products are

 

 22   once-a-day application, some of them are twice a

 

                                                               287

 

  1   day.

 

  2             DR. CANTILENA:  Final question.  Dr. Wood.

 

  3             DR. WOOD:  I have two comments rather than

 

  4   questions.  The first one is the techniques, the

 

  5   laboratory techniques that are used to establish

 

  6   the diagnosis.  We are here to give advice, and it

 

  7   seems to me that the techniques that are being used

 

  8   are antiquated.

 

  9              We no longer use cultures to identify

 

 10   tuberculosis for lots of good reasons.  There are

 

 11   much better molecular biology techniques that could

 

 12   be used to identify these organisms.  The fact that

 

 13   we are still using KOH seems to me just

 

 14   mind-boggling, so I would recommend that if we are

 

 15   going to start thinking about how we identify the

 

 16   organisms in the future, we ought to use the 21st

 

 17   century techniques, and not techniques from I guess

 

 18   almost the 19th century.

 

 19             The second part is I think it shouldn't go

 

 20   unchallenged that concentrations in skin are

 

 21   necessarily higher by topical administration than

 

 22   by systemic administration, and I haven't heard

 

                                                               288

 

  1   data to support that, nor have I heard data that

 

  2   say what these concentrations need to be at the

 

  3   site that kills the organism, because presumably,

 

  4   the site that kills the organism is not necessarily

 

  5   the one that you are sampling from when you scrape

 

  6   the skin.

 

  7             So, I think we need to be careful about

 

  8   that.  I am particularly concerned with the way

 

  9   that has been offered given that the data seem to

 

 10   suggest that systemic administration is at least,

 

 11   and probably substantially more, effective in terms

 

 12   of a cure rate than topical administration, so the

 

 13   assumption that the topical administration gives

 

 14   you higher concentrations and, hence, greater

 

 15   efficacy, doesn't seem to be borne out by the

 

 16   facts.

 

 17             DR. CANTILENA:  Any comments from the

 

 18   speakers to Dr. Wood?

 

 19             DR. ELEWSKI:  I don't have a comment on

 

 20   that, but we did do once a tape stripping study

 

 21   with an antifungal called Econazole, and did find

 

 22   that it was viable in the skin doing it

 

                                                               289

 

  1   sequentially over a long period of time after

 

  2   someone applied it and tape stripping it off to see

 

  3   if you could still get fungus.

 

  4             It was an in vivo kind of test, but I am

 

  5   not aware of any other data on that.

 

  6             DR. ALBRECHT:  I might just add to the

 

  7   study I referred to in my presentation.  We did a

 

  8   skin stripping study using the nesmith [ph] method,

 

  9   and five weeks after initiation of treatment, you

 

 10   could still find drug at effective levels, you

 

 11   know, representing superpotent MIC values, if you

 

 12   will.  I don't know whether that satisfied you.

 

 13             DR. WOOD:  Oral administration?

 

 14             DR. ALBRECHT:  We haven't done oral

 

 15   administration.

 

 16             DR. CANTILENA:  Dr. Ganley has one comment

 

 17   and then we will go to a break.

 

 18             DR. GANLEY:  I just wanted to follow up on

 

 19   something that Dr. Benowitz asked, and I am going

 

 20   to direct it to Dr. Elewski, because you had made

 

 21   the recommendation that there not be dose response

 

 22   studies done.

 

                                                               290

 

  1             I think from a regulatory point of view, I

 

  2   think when we look at the data for the negative

 

  3   mycology, that Dr. Fritsch reported on today, it

 

  4   was her Slide 15, if you look at the negative

 

  5   mycology, at the primary timepoint, it runs from 55

 

  6   percent to 88 percent.

 

  7             If you look at her Slide 17, where you

 

  8   actually look at effective treatment, the effective

 

  9   treatment is 38 to 69 percent.  So, it seems that

 

 10   there is a lot of room for improvement there.

 

 11             In a slide that Dr. Albrecht showed, which

 

 12   was his Slide 13, which showed that there is a

 

 13   1-week treatment of clotrimazole and a 4-week

 

 14   treatment of clotrimazole, there seemed to be

 

 15   difference.  It may not have been powered to show a

 

 16   difference, there seems to be a difference on the

 

 17   treatment in obtaining a negative mycology.

 

 18             So, I would like some information on how

 

 19   you could recommend that there not be a dose

 

 20   response, or that we shouldn't request that because

 

 21   our situation is we have folks coming in wanting to

 

 22   do 3-day treatments and 1-day treatments just to

 

                                                               291

 

  1   establish that they beat placebo.  It seems that if

 

  2   you come in with the right chemical, you can beat

 

  3   placebo, but then that may not be the best

 

  4   treatment for someone.

 

  5             It would be concentration or numbers of

 

  6   applications per day or duration.  Your statement

 

  7   is a very important statement if that is your

 

  8   position, and I would like to understand, because

 

  9   in my discussions with industry, when I have asked

 

 10   for data on a study where it has looked at multiple

 

 11   different regimens or doses within the same study,

 

 12   there is not much data.

 

 13             I mean it is very important from a

 

 14   regulatory point of view as to what the hurdle is

 

 15   that someone has to get over, because otherwise you

 

 16   will see 3-day and 1-day treatment simply because

 

 17   they have beaten placebo.

 

 18             DR. ELEWSKI:  I guess I am not totally

 

 19   sure what you want, but I know with terbinafine,

 

 20   there have been data showing that 1 week of

 

 21   treatment may be as effective as 4 weeks of

 

 22   treatment for tinea pedis, so that dose response

 

                                                               292

 

  1   has already been done.

 

  2             DR. GANLEY:  Within the same study.

 

  3             DR. ELEWSKI:  Within the same study.

 

  4             DR. GANLEY:  But I am thinking as a

 

  5   blanket statement, you know, you are saying that

 

  6   there is not a need for it, and that has a profound

 

  7   impact.

 

  8             DR. ELEWSKI:  I guess I was getting at

 

  9   that we have drugs that are effective, that are

 

 10   working to kill the dermatophyte, and I wasn't sure

 

 11   that further gathering more data is going to help

 

 12   the patient.

 

 13             DR. GANLEY:  But if someone comes in a 70

 

 14   percent mycologic cure rate and an effective

 

 15   treatment rate of 50 percent, there is a lot of

 

 16   room there for improvement, it seems.  I mean your

 

 17   blanket statement is--

 

 18             DR. ELEWSKI:  I don't have her slides in

 

 19   front of me, but 70 percent mycological cure, it

 

 20   probably isn't higher because there is some

 

 21   persistent scale there, which is causing the KOH to

 

 22   be positive.  I think that is part of the problem

 

                                                               293

 

  1   with that.

 

  2             DR. ALBRECHT:  May I comment on that?

 

  3             DR. CANTILENA:  Yes, one quick comment,

 

  4   please.

 

  5             DR. ALBRECHT:  I think Dr. Elewski made

 

  6   the point 1 and 4 weeks, there is no difference,

 

  7   established dose differences, there is lack of dose

 

  8   differences for this compound.

 

  9             Another study that we have done, and I

 

 10   can't say a whole lot, because it's a developmental

 

 11   project, but we have actually done a study, a

 

 12   properly designed, adequately well controlled,

 

 13   randomized, placebo-controlled study with three

 

 14   different concentrations, 1, 5, and 10 percent for

 

 15   a proper treatment course of tinea pedis.  We did

 

 16   not find any difference in the response.

 

 17             So, again, I think dose ranging doesn't

 

 18   seem, with these kind of compounds, doesn't seem to

 

 19   really gain a whole lot once you have established

 

 20   enough drug in the skin.  That is really the point

 

 21   I was trying to make before.

 

 22             DR. GANLEY:  The other question I have for

 

                                                               294

 

  1   you, Dr. Albrecht, is you achieve approximately, I

 

  2   think 88 percent negative mycologic cultures, so

 

  3   that seems to suggest that the 12 percent or so

 

  4   would have had positive cultures.

 

  5             DR. ALBRECHT:  Not so, Dr. Ganley, because

 

  6   mind you, mycological response is the combination

 

  7   of culture negative and KOH negative, and I think

 

  8   we just discussed that KOH is a very fickle, if I

 

  9   may so, kind of instrument, so we may have had--I

 

 10   don't know the number right now--but we may have

 

 11   had 95 percent negative cultures, but the people

 

 12   failed because the KOH was positive, and that just

 

 13   means nonviable structures may have been found in

 

 14   the skin.

 

 15             DR. GANLEY:  So, you have 100 percent of

 

 16   the cultures are negative, is that what you are

 

 17   saying?

 

 18             DR. ALBRECHT:  I am not saying that, and I

 

 19   would have to look that up, but I submit to you,

 

 20   and I think even as we heard earlier from the FDA

 

 21   statistician, that a number of cases fail based on

 

 22   positive KOH.

 

                                                               295

 

  1             DR. GANLEY:  My question is has anyone

 

  2   ever looked at those where the culture has failed

 

  3   to see, are those the MICs for the organism growing

 

  4   there different from what we have seen throughout

 

  5   today, is it something that that is a resistant

 

  6   organism, or it just turns out that this is a

 

  7   compliance issue possibly with the individual.

 

  8             I am directing it, are there outlier

 

  9   organisms there that require higher MICs.

 

 10             DR. ALBRECHT:  I can't speak to that, but

 

 11   may be Dr. Ghannoum or Dr. Elewski.

 

 12             DR. ELEWSKI:  Dr. Ghannoum and I did a

 

 13   study two years ago looking at onychomycosis.  It

 

 14   was a huge study to see--and we did MICs on the

 

 15   organism against all the antifungals, and there was

 

 16   really no issue of resistance including people who

 

 17   failed, which made you wonder, and this data has

 

 18   been published, what does failure mean and why does

 

 19   someone fail.  It's a very complicated process.  It

 

 20   may be compliance issues, it may be the extent of

 

 21   the infection, and it may very likely be the

 

 22   patient's immune system may be doing something.

 

                                                               296

 

  1             DR. CANTILENA:  Are there questions for

 

  2   the speakers?  We had a show of hands over here,

 

  3   Dr. Benowitz, Dr. Whitmore, and Dr. Wilkin.  Are

 

  4   they for the speakers or are they general comments?

 

  5             DR. WILKIN:  Mine is actually just a

 

  6   response to Dr. Wood's query this morning on the

 

  7   effectiveness of systemic agents.

 

  8             DR. CANTILENA:  How about if we hold that

 

  9   until after the break.

 

 10             Dr. Benowitz, do you have a comment or a

 

 11   question?

 

 12             DR. BENOWITZ:  I wanted to ask Dr.

 

 13   Ghannoum, who made the comment that he had done

 

 14   some animal studies on dose response, which I think

 

 15   would be quite interesting to know what the nature

 

 16   of the dose response is, do they really flatten out

 

 17   and do they flatten out at the same concentrations

 

 18   as these products are used clinically in people.

 

 19             DR. GHANNOUM:  We have an animal model

 

 20   which is coming out, also published, for

 

 21   dermatophytosis, and we use this model for

 

 22   different biotech companies, as well as pharma, to

 

                                                               297

 

  1   look at the different concentration.  Once you see

 

  2   something works in OIC, then, we say, look, does it

 

  3   work in vivo.  So, we move into this animal model

 

  4   and to find the appropriate concentration, we

 

  5   always use at least three different groups, 1, 5,

 

  6   and, let's say, 10 percent.

 

  7             When we look at that model, we look at

 

  8   efficacy as well as is there a clinical, let's say,

 

  9   redness to see whether there is irritation with

 

 10   higher concentrations and whatever.

 

 11             Based on this, you will recommend or you

 

 12   call and suggest to the manufacturer, look, this is

 

 13   the concentration which is efficacious, as well as

 

 14   we don't see redness, scaling, and this sort of

 

 15   thing in that animal model.

 

 16             Then, the manufacturer will sometimes take

 

 17   that concentration and try other vehicles because

 

 18   again to know, to improve it, will it improve or

 

 19   not, and then after that, they plan their clinical

 

 20   trial.

 

 21             We found, at least with Lamisil, I know at

 

 22   an early time when they were trying to test it,

 

                                                               298

 

  1   that 1, 5, and 10, there is really no difference, I

 

  2   mean they reached the maximum with 1, at least in

 

  3   that class of compounds.

 

  4             DR. WOOD:  What about duration of effect?

 

  5             DR. GHANNOUM:  Because the animal model

 

  6   itself, it is really self-healing, so you have only

 

  7   about 10 days where you can look, and we look only

 

  8   a 1-week treatment, but in that 1-week treatment,

 

  9   we compare once a day or twice a day, but only 1

 

 10   week, and then we do after that, 9 days, we do the

 

 11   evaluation.

 

 12             DR. CANTILENA:  Dr. Whitmore, did you have

 

 13   a question or a comment?

 

 14             DR. WHITMORE:  Are we going to be talking

 

 15   about the consumer educational brochure for

 

 16   patients in the packaging?

 

 17             DR. CANTILENA:  Yes, that will be actually

 

 18   part of our discussion at the end of the day on

 

 19   labeling.

 

 20             Any more questions or comments?

 

 21             Let's go ahead and take a 15-minute break

 

 22   and return at 3:05.

 

                                                               299

 

  1             [Break.]

 

  2                       Committee Discussion

 

  3             DR. CANTILENA:  The plan for the rest of

 

  4   this afternoon and possibly tomorrow morning,

 

  5   depending on time, is to discuss the issues before

 

  6   the committee.  They are outlined for you, some in

 

  7   the form of questions, in the handout that you were

 

  8   given.

 

  9             What I have done on this PowerPoint is to

 

 10   sort of partition our discussion, if you will, so

 

 11   that we are on track, by topic.  We are first going

 

 12   to talk about the issues that actually come up in

 

 13   Questions 4 and 5 with microbiology.

 

 14             We will have that discussion, we will

 

 15   focus on those issues, and then we will actually go

 

 16   through Questions 4 and 5.  After that, drug

 

 17   development issues will be discussed, you know,

 

 18   dose response issues, lowest acceptable cure rate,

 

 19   et cetera, as outlined.

 

 20             For that discussion, we will answer

 

 21   Question 2, and we will give our comments as

 

 22   requested in Issue No. 1, so we will comment on

 

                                                               300

 

  1   Issue 1 and answer yes/no Question 2 under drug

 

  2   development, under the broad category of drug

 

  3   development.

 

  4             Finally, under labeling issues, we will

 

  5   talk about the existing label and then the possible

 

  6   modifications or additions, deletions to the future

 

  7   labels.  In that discussion, we will answer

 

  8   Question 6, as well as Questions 3(a) and 3(b).

 

  9             So, that is the plan.  If you can click on

 

 10   Clinical Microbiology, what I would like to do is

 

 11   try to focus the discussion sort of as requested by

 

 12   FDA, drug resistance issues and also the use of

 

 13   MICs in drug development.

 

 14             I will just start by saying that what I

 

 15   heard this morning and also this afternoon was

 

 16   resistance is really a rare finding and does not

 

 17   seem to be an issue.  What I thought possibly for

 

 18   MICs, and I would obviously love to hear

 

 19   everybody's comment on this, is that perhaps in the

 

 20   case of treatment failures, that could be part of

 

 21   the drug application file.

 

 22             So, those are sort of my initial thoughts,

 

                                                               301

 

  1   but I would like to open it up to the committee,

 

  2   again sort of in this topic, and let's hear what

 

  3   you all think about this, clinical microbiology

 

  4   issues as they relate to Items 4 and 5.

 

  5             General discussion.  One is we ran out of

 

  6   coffee and people are sagging, or the other is that

 

  7   there are no issue.

 

  8             Go ahead, Dr. Wilkerson.

 

  9             DR. WILKERSON:  To assume that drug

 

 10   resistance is not going to occur, or is going to

 

 11   occur infrequently is probably relatively naive.  I

 

 12   think part of the problem is we don't look for it,

 

 13   we don't have laboratory methods at least on a

 

 14   clinical level to evaluate for drug resistance.

 

 15             If someone is treated with a topical or

 

 16   oral course of antifungal, and it doesn't work, the

 

 17   decision of the clinician is to just move forward

 

 18   generally with another drug or tell the patient to

 

 19   live with it.

 

 20             So, I am not sure that we don't have drug

 

 21   resistance here already.  It may be just the fact

 

 22   that we don't recognize it because we don't have

 

                                                               302

 

  1   any means for screening for it like we do bacterial

 

  2   resistance, and we don't look for it.  The

 

  3   techniques that were described this morning aren't

 

  4   available on a clinical basis for general use.

 

  5             As far as the MICs, I am assuming we are

 

  6   talking about new drugs, new chemical compounds.  I

 

  7   mean I would think that would be essential for any

 

  8   NDA type of application, that we need to know the

 

  9   pharmacology, we need to know when we put it into a

 

 10   particular vehicle or incipient, does it, in fact,

 

 11   deliver the compound, or does it sit there, you

 

 12   know, what are the pharmacodynamics that drive the

 

 13   compound out of the incipient and into the target

 

 14   organism or cell.

 

 15             Just assuming that a 1 percent

 

 16   concentration does this and that we can strip it

 

 17   off the tape later, you know, for all we know, you

 

 18   know, the compound is sitting on top of the stratum

 

 19   corneum and doing absolutely nothing, yet, by the

 

 20   crude tape stripping methods that we use to

 

 21   evaluate this, one thing and another, it would

 

 22   still show up in the chemical analysis.

 

                                                               303

 

  1             I think, going forward, you know, since

 

  2   these techniques are available, these are things

 

  3   that should be looked at for new compounds, new

 

  4   applications.

 

  5             DR. CANTILENA:  Thank you.

 

  6             Any other comments in general?  Dr.

 

  7   Benowitz.

 

  8             DR. BENOWITZ:  It seems to me we still

 

  9   have a lot to learn about mechanisms of fungal

 

 10   resistance.  It looked pretty convincing from what

 

 11   I heard today that there is not much of a problem

 

 12   with the current drugs, and the question is with

 

 13   new drugs, would resistance be different.  We need

 

 14   to know more about how the fungus works.

 

 15             I think laboratory in the U.S., like is

 

 16   being done now, should follow this, but I don't

 

 17   know yet that it needs to be done as part of every

 

 18   new drug evaluation.  It is just a big vacuum in

 

 19   terms of mechanisms.

 

 20             DR. CANTILENA:  Dr. Ghannoum.

 

 21             DR. GHANNOUM:  Just a comment about this

 

 22   number.  I think I agree with you if we think

 

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  1   resistance is not going to develop, it's not right,

 

  2   which could be rare I agree, because we already saw

 

  3   at least one patient, which is very well

 

  4   characterized, so I think it will happen.

 

  5             The fact that the method is just

 

  6   developed, we have the paper coming out in July

 

  7   issue of Journal of Clinical Microbiology, and the

 

  8   method will be adopted and available to the other

 

  9   laboratories in January of 2005.  So, we are there

 

 10   as far as availability.

 

 11             As far as measuring the MIC, from the

 

 12   clinical point of view, I think if we look at how

 

 13   we use MICs in the systemic agents, where we have

 

 14   methods available, what we do, we don't do it

 

 15   routinely, we do it for patients who fail therapy,

 

 16   and then you do it, and they say, okay, this is

 

 17   resistant, so you can switch drugs.

 

 18             That is well documented and it is one of

 

 19   the IDSA guidelines, Infectious Disease Society of

 

 20   America, that it should be for those who fail

 

 21   therapy.

 

 22             Now, as far as part of drug development, I

 

                                                               305

 

  1   think it is very important that we have a baseline,

 

  2   I mean otherwise how are you going to know whether

 

  3   a drug works, not work, and once you have that

 

  4   available, it is going to help you in the long run

 

  5   whether there will be a change in MIC or not as you

 

  6   are monitoring patients, so that is what I can say.

 

  7             DR. CANTILENA:  Thank you.

 

  8             Other comments?  Okay.  If there are no

 

  9   objections and no further discussion on this topic,

 

 10   why don't we actually go to Question 4.

 

 11             Given the efficacy rates observed in the

 

 12   clinical trials, should antifungal drug resistance

 

 13   be a concern?

 

 14             Actually, what I would like to do, Dr.

 

 15   Ganley and Dr. Wilkin, if this is acceptable, is to

 

 16   do this as a yes/no vote and then ask the

 

 17   individual to say what the concern is, so that you

 

 18   will know what is going on.

 

 19             Why don't we start voting over on this

 

 20   side.  Actually, before we start the voting, I

 

 21   would like to ask the non-voting members if they

 

 22   would like to comment on Question 4, first of all,

 

                                                               306

 

  1   so I don't omit that as I have done in the past.

 

  2             So, I will start over here, Mr. Kresel,

 

  3   and then Dr. Alfano.

 

  4             MR. KRESEL:  Based on the data that we saw

 

  5   this morning, I agree, as a microbiologist, that

 

  6   ultimately, you will see some resistance, but based

 

  7   on the tons of these products literally that are

 

  8   used every year, and for the number of years they

 

  9   have been used, I don't see that it creates a

 

 10   concern, the difference between whether it will

 

 11   happen and whether it's a concern.

 

 12             So, yes, I agree it will happen, but, no,

 

 13   I don't think it is really a concern at this point.

 

 14             DR. CANTILENA:  Dr. Alfano.

 

 15             DR. ALFANO:  I agree that I don't think it

 

 16   is a concern.  It is difficult when the efficacy

 

 17   rates are linked to resistance, because in this

 

 18   particular condition, as we have heard, the

 

 19   efficacy can be playing off of other parameters,

 

 20   i.e., the anatomical deformities, and so forth,

 

 21   that exist, but I didn't hear any data of any

 

 22   significance that drug resistance is a problem.

 

                                                               307

 

  1             DR. CANTILENA:  Thank you.

 

  2             Why don't we continue here and we will

 

  3   just go around this way.

 

  4             Dr. Ten Have.

 

  5             DR. TEN HAVE:  You want a yes/no to what

 

  6   question?

 

  7             DR. CANTILENA:  Question No. 4, yes/no,

 

  8   and if you are concerned, if you can explain your

 

  9   concerns.

 

 10             DR. TEN HAVE:  Given I have no knowledge

 

 11   in this area, I am going to approach it from a

 

 12   slightly different point of view.  I agree that the

 

 13   efficacy rates probably could be higher, but, of

 

 14   course, there are other reasons in addition to the

 

 15   other parameters that Dr. Alfano just mentioned.

 

 16             We haven't really looked at other factors,

 

 17   such as non-adherence, which could be a big factor

 

 18   in the lack of efficacy, if there is a lack of

 

 19   efficacy, so I would say given my lack of knowledge

 

 20   in this area, no.

 

 21             DR. CANTILENA:  Thank you.

 

 22             Dr. Wood.

 

                                                               308

 

  1             DR. WOOD:  No, but, of course, our tense

 

  2   is in some way future tense, and there is no way of

 

  3   telling that for drugs that are under development

 

  4   or might appear in the future.

 

  5             DR. CANTILENA:  We are not going to let

 

  6   you two vote.

 

  7             Dr. Bisno.

 

  8             DR. BISNO:  No.  In a word.

 

  9             DR. CANTILENA:  That was Dr. Bisno.  In a

 

 10   word, he said no.

 

 11             Yes, Dr. Ghannoum.

 

 12             DR. GHANNOUM:  No.

 

 13             DR. CANTILENA:  Dr. Katz.

 

 14             DR. KATZ:  No.

 

 15             DR. SCHMIDT:  No.

 

 16             DR. CANTILENA:  That was Dr. Schmidt.

 

 17             Dr. Davidoff.

 

 18             DR. DAVIDOFF:  I am not entirely clear

 

 19   what we are voting on, because it seems to me there

 

 20   are two concerns.  One of them is a biological

 

 21   concern, and the other one is a regulatory concern,

 

 22   and I am not sure which one this is really

 

                                                               309

 

  1   referring to.

 

  2             DR. CANTILENA:  You can answer it actually

 

  3   both ways.

 

  4             DR. DAVIDOFF:  I think that there is a

 

  5   biological concern.  I mean it took many years

 

  6   before the pneumococcus became resistant to

 

  7   penicillin, 30, 40 years of exposure.  So, I think

 

  8   that there could very well be biological and

 

  9   clinical concerns over time for resistance with

 

 10   these organisms, so I would vote yes, that is a

 

 11   clinical concern.

 

 12             Is it a regulatory concern?  I would say

 

 13   no.

 

 14             DR. CANTILENA:  Thank you.

 

 15             Dr. Whitmore.

 

 16             DR. WHITMORE:  No.

 

 17             DR. CANTILENA:  Dr. Fincham.

 

 18             DR. FINCHAM:  It is difficult to answer

 

 19   yes or no, everybody knows that, but I think it is

 

 20   a concern.  I guess my concern relates to I don't

 

 21   think we really know, as Dr. Benowitz pointed out,

 

 22   a lot about a lot of things here, one of which is

 

                                                               310

 

  1   how many of these infections, so to speak, are

 

  2   repeat infections, multiple, multiple, multiple

 

  3   cases, time after time after time, and is that due

 

  4   to non-adherence, is it due to misunderstanding of

 

  5   what the drug is, is it related to something else.

 

  6             So, I think it is a concern.

 

  7             DR. CANTILENA:  Dr. Ringel.

 

  8             DR. RINGEL:  Basically, no for now, yes

 

  9   for eventually.  I do think that it would make

 

 10   sense for new NDAs to include minimal inhibitory

 

 11   concentrations because you really don't know how to

 

 12   interpret the future if you don't know what is

 

 13   there in the present.

 

 14             DR. CANTILENA:  That is actually Question

 

 15   5, so you will have an opportunity to say that

 

 16   again in a minute.

 

 17             Dr. Lam.

 

 18             DR. LAM:  I agree.  Right now based on the

 

 19   data that has been presented today, I don't think

 

 20   it is a concern at this moment, but we know fungus

 

 21   are pretty smart and it may be a concern down the

 

 22   road.

 

                                                               311

 

  1             DR. CANTILENA:  Dr. Patten.

 

  2             DR. PATTEN:  I join Dr. Davidoff in a

 

  3   split vote.  I will vote no from a regulatory point

 

  4   of view, but yes in terms of the future.  I mean

 

  5   theoretically, yes, it is going to happen.  Fungi

 

  6   have been around for a long time, undergoing

 

  7   natural selective pressures, no reason to think

 

  8   they won't respond to this.

 

  9             DR. CANTILENA:  Dr. Wilkerson.

 

 10             DR. WILKERSON:  As far as for the present,

 

 11   no, but looking forward, so we don't get the

 

 12   flesh-eating Tinea rubrum, and be blamed 15 years

 

 13   from now that we didn't stop the epidemic when we

 

 14   could have, I think we need to be aware and

 

 15   monitoring for that, but it is not an issue with

 

 16   the current drugs.

 

 17             DR. CANTILENA:  Dr. Raimer.

 

 18             DR. RAIMER:  I agree, no for now, but

 

 19   possibly yes in the future.

 

 20             DR. CANTILENA:  Dr. Epps.

 

 21             DR. EPPS:  I concur on no at this time.  I

 

 22   guess a comment about some of my patients. 

 

                                                               312

 

  1   Certainly, a lot of them, as a subspecialist, have

 

  2   already used products when they come, and I

 

  3   certainly have faith that quite a few of them are

 

  4   compliant.  As a parent who applies medication to

 

  5   their child, I think a lot of them do.  I guess the

 

  6   difficulty is proving the resistance.

 

  7             DR. CANTILENA:  Dr. Clapp.

 

  8             DR. CLAPP:  No for now, yes for a concern

 

  9   for the future.

 

 10             DR. CANTILENA:  Dr. Benowitz.

 

 11             DR. BENOWITZ:  I sort of have a split

 

 12   vote, but my concern is actually regulatory for new

 

 13   drugs.  I would say no for the current classes of

 

 14   antifungal drugs because resistance is rare, but I

 

 15   think when there are new drugs that come out, there

 

 16   are going to be new mechanisms of resistance, and I

 

 17   think that we should look at the potential for

 

 18   developing resistance when there are new classes of

 

 19   drugs that are introduced.

 

 20             DR. CANTILENA:  Thank you.

 

 21             Ms. Knudson.

 

 22             MS. KNUDSON:  My vote is exactly the same,

 

                                                               313

 

  1   no for right now, but yes for the future.

 

  2             DR. CANTILENA:  Thank you.

 

  3             My vote is from a regulatory standpoint,

 

  4   no, at this time; from a clinical standpoint, yes.

 

  5             Now that we have given you all those

 

  6   options, Dornette is going to give us the vote

 

  7   tally.

 

  8             LCDR SPELL-LeSANE:  18 no and 1 yes.

 

  9             DR. CANTILENA:  With all the

 

 10   qualifications that are fortunately on the

 

 11   transcript.  Okay.  Very good.

 

 12             Let's go to Question 5.  Should antifungal

 

 13   MICs be determined for clinical isolates during

 

 14   drug development and submitted with the NDA?

 

 15             I think we have some of your answers, but

 

 16   we have to have anyway for the transcript, so let's

 

 17   start on this side over here.

 

 18             Ms. Knudson.

 

 19             MS. KNUDSON:  I will have to pass.  I

 

 20   can't answer that.

 

 21             DR. CANTILENA:  Okay.  Dr. Benowitz.

 

 22             DR. BENOWITZ:  I would say yes, now that

 

                                                               314

 

  1   we can do this, I don't see any reason why we

 

  2   shouldn't do it, and it might be very informative.

 

  3   I would say yes.

 

  4             DR. CANTILENA:  Dr. Clapp.

 

  5             DR. CLAPP:  I would say.  I think that

 

  6   helps address our concern about the resistance for

 

  7   the future drugs.

 

  8             DR. CANTILENA:  Dr. Epps.

 

  9             DR. EPPS:  I certainly think it could be

 

 10   helpful and informative.  I have met some

 

 11   infectious disease people who wonder about MICs and

 

 12   the relevance, and that sort of thing, but perhaps

 

 13   it would help us look forward to know with more

 

 14   data what is pertinent and whether it's relevant.

 

 15             DR. CANTILENA:  Dr. Raimer.

 

 16             DR. RAIMER:  Yes.

 

 17             DR. CANTILENA:  Dr. Wilkerson.

 

 18             DR. WILKERSON:  I am assuming this was

 

 19   referring to in vitro or in vivo MICs?

 

 20             DR. CANTILENA:  In vitro on the isolates.

 

 21             DR. WILKERSON:  In vitro?

 

 22             DR. CANTILENA:  On the isolates.

 

                                                               315

 

  1             DR. WILKERSON:  I think it is part of an

 

  2   investigative process, it is absolutely essential.

 

  3             DR. CANTILENA:  Dr. Patten.

 

  4             DR. PATTEN:  I vote yes.

 

  5             DR. CANTILENA:  Dr. Lam.

 

  6             DR. LAM:  Yes, and it would allow us to

 

  7   learn more about may drug resistance and fungal

 

  8   resistance, and help us to devise strategies to

 

  9   prevent them down the road.

 

 10             DR. CANTILENA:  Thank you.

 

 11             Dr. Ringel.

 

 12             DR. RINGEL:  Yes.

 

 13             DR. CANTILENA:  Dr. Fincham.

 

 14             DR. FINCHAM:  Yes.

 

 15             DR. CANTILENA:  Dr. Whitmore.

 

 16             DR. WHITMORE:  Yes.

 

 17             DR. CANTILENA:  Dr. Davidoff.

 

 18             DR. DAVIDOFF:  Yes, although I assume that

 

 19   it's not just the drug developers who are going to

 

 20   be studying MICs, it's clearly a wider problem.

 

 21             DR. SCHMIDT:  Yes.

 

 22             DR. CANTILENA:  That was Dr. Schmidt.

 

                                                               316

 

  1             Dr. Katz is yes?

 

  2             DR. KATZ:  Yes.

 

  3             DR. CANTILENA:  Dr. Ghannoum, yes.

 

  4             Dr. Bisno?

 

  5             DR. BISNO:  First, to go back to 4 for

 

  6   just a second, we didn't discuss really in any

 

  7   detail what the reasons are for the lower efficacy

 

  8   rates when using drugs that are obviously very

 

  9   potent.

 

 10             Some things came up about hammertoes and

 

 11   local factors and everything, but it seems to me

 

 12   that there needs to be more emphasis on what the

 

 13   factors are that make failure when you are using

 

 14   highly potent drugs, because if we don't identify

 

 15   those, then, we are going to be doomed to wasting

 

 16   all these drugs, because we will be doomed to fail.

 

 17             So, I would like to see more interest in

 

 18   that anyway.

 

 19             Now, to go on to 5, yes, it is true that,

 

 20   as an infectious disease person, we do believe in

 

 21   MICs, but we don't believe in them absolutely, but

 

 22   I think the fact is that if someone presented an

 

                                                               317

 

  1   NDA that showed a tremendous clinical potency for a

 

  2   particular drug against particular isolates, and

 

  3   yet it was resistant by MICs, we would all scratch

 

  4   our heads and have to go back to the drawing boards

 

  5   a bit, so I definitely think this should be part of

 

  6   drug development and submitted with the NDA.

 

  7             DR. CANTILENA:  Thank you.

 

  8             Dr. Wood.

 

  9             DR. WOOD:  Yes.

 

 10             DR. CANTILENA:  Dr. Ten Have.

 

 11             DR. TEN HAVE:  Yes.

 

 12             DR. CANTILENA:  Comments from Dr. Alfano

 

 13   and Mr. Kresel.

 

 14             MR. KRESEL:  I agree and I think in order

 

 15   for that to be meaningful, you would also want to

 

 16   do MICs on clinical failures, because you want to

 

 17   see if there has been any change in the MIC.  If

 

 18   you start out susceptible and end up resistant,

 

 19   which is highly unlikely given the data that we saw

 

 20   today, but nevertheless, an MIC at the beginning

 

 21   and a failure at the end is really not very

 

 22   compelling data.

 

                                                               318

 

  1             DR. CANTILENA:  Thank you.

 

  2             I also vote yes.  I think it would be

 

  3   especially helpful in explaining treatment failures

 

  4   if they should occur.

 

  5             I am sorry, have you commented?  I thought

 

  6   you passed, Dr. Alfano.

 

  7             DR. ALFANO:  Pass.

 

  8             DR. CANTILENA:  So, you did pass.

 

  9             DR. ALFANO:  Yes.

 

 10             DR. CANTILENA:  You have sensitized me now

 

 11   forever for skipping you, so I am going to ask you

 

 12   at least five times every vote.

 

 13             We will go to the next slide which changes

 

 14   topics now.  Now, we are actually specifically

 

 15   talking about drug development.  Basically, I would

 

 16   like to center the initial discussion on, first,

 

 17   Question 2, which has to do with drug response.

 

 18             Dose response studies are not conducted in

 

 19   the development programs of antifungal products for

 

 20   the treatment of tinea pedis.  Given the efficacy

 

 21   of products currently marketed, should they include

 

 22   dose response, you know, specifically, they

 

                                                               319

 

  1   evaluate safety and efficacy at different

 

  2   concentrations, dosing durations, and dosing

 

  3   frequencies?

 

  4             Let's initially sort of focus our

 

  5   discussion, if you will, on the whole issue of

 

  6   including exposure response type of information in

 

  7   drug development for new antifungals for this

 

  8   indication.

 

  9             I guess we will just open up the floor.

 

 10             Dr. Wilkin.

 

 11             DR. WILKIN:  Would you still want the

 

 12   efficacy information on the systemic agent that Dr.

 

 13   Wood requested?

 

 14             DR. CANTILENA:  Yes, we do.  We have to

 

 15   have that because that was a homework assignment

 

 16   that we gave you.

 

 17             DR. WILKIN:  That was a homework

 

 18   assignment.  The systemic antifungals are in a

 

 19   different division, so it took us a few moments to

 

 20   find out, and I will describe--and this ought to be

 

 21   available through Freedom of Information, and I

 

 22   assume this is so old, this is the ketoconazole

 

                                                               320

 

  1   oral.

 

  2             Protocol 009, patients were eligible if

 

  3   they had dermatophyte infections:  one, which had

 

  4   been resistant to prior topical antifungals; two,

 

  5   if topical treatment were contraindicated due to

 

  6   the extent of the fungal infection; three, if the

 

  7   infection had failed to respond or had recurred

 

  8   after griseofulvin therapy; or, four, if patients

 

  9   requiring griseofulvin could not tolerate the drug.

 

 10   So, those are the entry criteria.

 

 11             There were 47 evaluable subjects.  There

 

 12   were 3 separate study centers.  The patients who

 

 13   were in the negative KOH and culture group, that

 

 14   was 70 percent.  We call that the mycologically

 

 15   negative.  You have also earlier heard the phrase

 

 16   "mycological cure."

 

 17             Then, the clinical and mycological cure

 

 18   was 62 percent, and that is above, well above

 

 19   actually, the rates that we saw in the topicals

 

 20   earlier.

 

 21             DR. CANTILENA:  And that was what dose of

 

 22   ketoconazole, and how long was the treatment?

 

                                                               321

 

  1             DR. WILKIN:  Patients were treated with

 

  2   either 200 or 400 milligrams a day for a minimum of

 

  3   28 days and a maximum of 60 days.

 

  4             DR. WOOD:  Just for clarification, that

 

  5   would be the equivalent of Slide 19 in Dr.

 

  6   Fritsch's presentation, is that what we are saying?

 

  7   The clinical and mycological cure would be the

 

  8   equivalent of a complete cure on her slide, is that

 

  9   right?

 

 10             DR. WILKIN:  No, this is an older review,

 

 11   and it is really not that clear whether this would

 

 12   fit most with effective treatment and allow for

 

 13   some or not, because they say global clinical

 

 14   assessment was recorded as cured, markedly

 

 15   improved, moderately or slightly improved,

 

 16   unchanged, or deteriorated, and, as healed, mild,

 

 17   residual lesion or considerable residual lesion,

 

 18   unchanged or deteriorated in 9, and 9 is the one we

 

 19   are talking about.

 

 20             So, it is not quite clear as I read this

 

 21   whether it fits with one or the other.

 

 22             DR. WOOD:  But the 62 percent is that

 

                                                               322

 

  1   clinical endpoint plus mycological cure?

 

  2             DR. WILKIN:  Exactly so.

 

  3             DR. CANTILENA:  Thank you.  That was the

 

  4   fastest Freedom of Information response I have ever

 

  5   heard of.  Same day service.  Thank you very much.

 

  6             Comments, concerns looking at dose

 

  7   response, safety and efficacy at various sort of

 

  8   exposure responses for drug development of future

 

  9   agents?  Dr. Katz.

 

 10             DR. KATZ:  I am a bit confused.  Are we

 

 11   talking about issues for the committee now?

 

 12             DR. CANTILENA:  Yes, this is sort of like

 

 13   Issue No. 2 for the committee as it relates to drug

 

 14   development programs.

 

 15             Should sponsors be doing exposure response

 

 16   for dried development for new products for

 

 17   over-the-counter?  I think you have heard earlier

 

 18   about the exposures in either changing the

 

 19   concentrations or the application frequency or the

 

 20   length of application, and that is really what we

 

 21   are talking about.

 

 22             Comment, Dr. Whitmore?

 

                                                               323

 

  1             DR. WHITMORE:  I guess we can't ask

 

  2   Novartis to do this, so this would of their own

 

  3   accord.  It would be nice, as has been said here,

 

  4   to know if 3 days of therapy is the same as 7 days

 

  5   of therapy, but for future companies coming forth

 

  6   with the antifungals, it would be nice to have

 

  7   comparator days of dosing.

 

  8             I think, more importantly, at least with

 

  9   the antifungal chemicals that we know of right now,

 

 10   in that the MICs are such that you are going to be

 

 11   killing them, you are above the MIC and everything

 

 12   else, but with those drugs, as far as different

 

 13   dosing regimens, if they could come up with a

 

 14   dosing regimen that has whatever acceptable percent

 

 15   clearance, we are talking about 70 or 80 percent or

 

 16   whatever of clearance, and then have a level of

 

 17   dosing somewhere below that where it's a lesser

 

 18   clearance rate.

 

 19             Thus, to kind of restate that, when they

 

 20   are doing studies, come up with a dose response

 

 21   based on the number of days of dosing, so we know

 

 22   we are at the minimum number of days to get 80

 

                                                               324

 

  1   percent clearance or whatever.

 

  2             DR. CANTILENA:  Very good.

 

  3             Dr. Schmidt.

 

  4             DR. SCHMIDT:  Don't the drug companies do

 

  5   this already?  I mean this seems awful simple, you

 

  6   know, that even before they would even approach or

 

  7   when they come to the committee or the FDA, they

 

  8   would have some evaluation of, say, different

 

  9   concentrations or some idea of the dosing and

 

 10   dosing frequencies.

 

 11             Maybe I just don't understand how we are

 

 12   supposed to present this to them.  This just seems

 

 13   like it's a given.

 

 14             DR. WHITMORE:  Can I just say it's kind of

 

 15   a new area because we have just gotten down to 7

 

 16   days of dosing, and we have never talked about

 

 17   anything less than that to clear up tinea pedis, so

 

 18   that is kind of a new thing as far as asking drug

 

 19   companies to look at 2 days and 3 days.

 

 20             DR. CANTILENA:  I think I could say that I

 

 21   have heard that in terms of dose response, there

 

 22   are some companies that had animal data that we

 

                                                               325

 

  1   have heard about, but I think what I have heard

 

  2   from FDA is in terms of clinical studies, you know,

 

  3   it's almost unheard of.

 

  4             So, it isn't available from the actual

 

  5   studies, and they are asking us if we think it is a

 

  6   good idea for that to be included in the NDA.

 

  7             DR. SCHMIDT:  Well, I think definitely, it

 

  8   is a good idea, but it just seems like a no-brainer

 

  9   in the sense that the people would do it from the

 

 10   start to present that data.  It is just a point of

 

 11   order of how these studies are done, but no, I

 

 12   agree definitely we should.

 

 13             DR. CANTILENA:  Comments from FDA to help

 

 14   clarify the issue?

 

 15             DR. WILKIN:  If I could just make a

 

 16   comment on the guinea pig model, I mean that is one

 

 17   where, quite literally, you have to hurry up and

 

 18   treat it before it goes away.  I mean it is going

 

 19   to go away on its own, so there are limited days.

 

 20   I am not sure that the skin of the guinea pig

 

 21   really reflects the skin between the toes or on the

 

 22   plantar surface of the foot.  So, there are many

 

                                                               326

 

  1   relevant aspects of that model that really would be

 

  2   dissimilar and maybe not predictive.

 

  3             DR. GHANNOUM:  If I might comment on this.

 

  4   I agree with you, we are not guinea pigs, so we are

 

  5   not going to have the same data you will see in a

 

  6   patient exactly, but I can tell you from our

 

  7   experience with all the different classes of

 

  8   compounds that are now, whether topical or oral,

 

  9   that the guinea pig can predict whether the drug

 

 10   works or not.

 

 11             You can see, for example, we have--not to

 

 12   bias, to be on anybody's side--but we have a

 

 13   positive control in the guinea pig, and it works

 

 14   beautifully, and when you compare it to other

 

 15   drugs, which does not work as well, although it is

 

 16   marketed, you will see the same.

 

 17             I agree with you, the caveats which you

 

 18   mentioned are very important, because if you leave

 

 19   it up to 17 days, then, it is not good, but if you

 

 20   have that window of 9 days to do the whole

 

 21   experiment, then, I think it's predictive. The

 

 22   drugs that have been approved were tested in this

 

                                                               327

 

  1   in the preclinical setting, and I really believe it

 

  2   is a very useful way to tell you whether, when you

 

  3   move from the in vitro to the in vivo, that things

 

  4   are going to work, number one, and number two, you

 

  5   can see the dosing also predictive, but eventually,

 

  6   you have to go into patients obviously.

 

  7             DR. CANTILENA:  Dr. Wilkin.

 

  8             DR. WILKIN:  Dr. Ganley earlier mentioned

 

  9   the "cures most" and the thinking that went into

 

 10   those words and how the original hope was that most

 

 11   would qualify the cure in a positive direction.

 

 12   Perhaps one of the unintended consequences of that

 

 13   is it is actually this incentivized competition for

 

 14   more effective products.

 

 15             If that is going to be on the labeling for

 

 16   virtually all these over-the-counter topical

 

 17   antifungals, then, when the marketing groups at the

 

 18   different industries try to decide whether there is

 

 19   a place where they can make a profit with the new

 

 20   medication, and incidentally, that is how we get

 

 21   all the new and important drugs that are helpful to

 

 22   the public health, is someone, somewhere is going

 

                                                               328

 

  1   to make some money.

 

  2             I mean that is the American way, and I

 

  3   think it has a lot of positive aspects to it, so I

 

  4   am certainly not going to give any negative side.

 

  5             But the one place that currently I think,

 

  6   if they look at these products and look at the

 

  7   labeling, is make it quicker, make it less time.

 

  8             I walked by the microwave the other day.

 

  9   We have a microwave at FDA out at the corporate,

 

 10   and I was going in there to do something, and

 

 11   someone was standing by the microwave going "hurry

 

 12   up, hurry up," and I think that is one of the great

 

 13   things that patients want with products also, is

 

 14   they want something that is faster.

 

 15             So, that is where the incentive today is,

 

 16   and maybe part of this plays into the labeling,

 

 17   maybe it cures most.  If that gets modified, we can

 

 18   then encourage sort of moving towards higher

 

 19   concentrations, maybe somewhat longer durations in

 

 20   an effort to get better efficacy.

 

 21             DR. CANTILENA:  Thank you.

 

 22             Dr. Wood.

 

                                                               329

 

  1             DR. WOOD:  Seeing that just came up, the

 

  2   most again, I don't think the Agency should allow

 

  3   labels that say "most," unless it is based on

 

  4   comparison.  "Most" is a word that has a clear

 

  5   meaning.  It means that it cures more than any

 

  6   other something.  You know, it is not more, it is

 

  7   not a comparison, it is most, so it implies that

 

  8   this is better than anything else, and that is

 

  9   clearly not true, so it shouldn't be on the label.

 

 10             But that wasn't what I wanted to say.  It

 

 11   seems to me that you should insist on exposure

 

 12   response, and that is better I think than dose

 

 13   response, because my fear would be that somebody

 

 14   will do a study that beats placebo with one dose,

 

 15   and that doesn't mean that 7 days wouldn't have

 

 16   cured a lot more people.

 

 17             Consumers will assume that the drug has

 

 18   been evaluated in a way that tested it and gave

 

 19   them the most--I will use that word--effective

 

 20   therapy, and not just any old therapy.

 

 21             So, I think there is a real need to ensure

 

 22   that exposure is evaluated, to make sure that you

 

                                                               330

 

  1   are not forced constantly into the least effective

 

  2   dose, even if it only cures, you know, fill in the

 

  3   percentage.

 

  4             So, I think it is absolutely essentially

 

  5   that you know where you are on the exposure

 

  6   response, not the dose response, and that you have

 

  7   some understanding that you are at the plateau

 

  8   level of what is being produced and before you

 

  9   approve it.

 

 10             DR. CANTILENA:  Yes, Dr. Ten Have.

 

 11             DR. TEN HAVE:  Following up on Dr. Wood's

 

 12   comment, and I think I am interpreting it

 

 13   correctly, but correct me if I am wrong, so with

 

 14   exposure, you are talking about duration times

 

 15   dose, the total.

 

 16             DR. WOOD:  Correct, or some combination,

 

 17   yes, and it might be number of times per day or

 

 18   some variable.

 

 19             DR. TEN HAVE:  So, following up on that

 

 20   comment and also Dr. Wilkin's comment about

 

 21   increasing dose, but shortening the duration, it

 

 22   seems to me that the companies are interested in

 

                                                               331

 

  1   shortening duration, but not necessarily increasing

 

  2   dose, and I may have that wrong, too, but

 

  3   increasing dose obviously increases efficacy, but

 

  4   may work against safety, so you have two competing

 

  5   criteria there.

 

  6             I presume that the interest in increasing

 

  7   dose is to get at the non-responders.  I know in

 

  8   other areas of medicine, there is sort of a

 

  9   stepped-up approach where if you don't respond at a

 

 10   certain dose, you step up the dose if you don't

 

 11   respond, so you can get a higher response rate for

 

 12   the non-responders.

 

 13             I am wondering if that is feasible in this

 

 14   situation, or is it just not clinically feasible?

 

 15             DR. CANTILENA:  Dr Whitmore.

 

 16             DR. WHITMORE:  Pass.

 

 17             DR. CANTILENA:  Mr. Kresel.

 

 18             MR. KRESEL:  I was just going to comment

 

 19   on the classic anti-infective drug development

 

 20   paradigm as it relates to this, because what we

 

 21   usually look at as we are determining the dose is

 

 22   the half-life, the area under the curve, MICs when

 

                                                               332

 

  1   they are available, bioavailability of the

 

  2   formulation, and tolerability to the patient.

 

  3             So, I think that there is not likely to be

 

  4   the need to test multiple concentrations when you

 

  5   have done that preliminary work.  Then, you get to

 

  6   dosing frequency, and dosing frequency has a very

 

  7   limited number of options, as I think somebody

 

  8   commented on earlier.

 

  9             You can do once a day, you can do twice a

 

 10   day, patients are going to carry their medication

 

 11   with them to work and take their shoes and socks

 

 12   off in the middle of the day and do another dose.

 

 13             So, you can dose something three times a

 

 14   day, and you can get labeling for three times a

 

 15   day, but you won't get any compliance to three

 

 16   times a day, so that it becomes kind of a moot

 

 17   point.

 

 18             So, I think dosing duration becomes the

 

 19   one that probably ought to be thought about, and I

 

 20   think that FDA probably should determine what the

 

 21   "gold standard" is.  That is, if four weeks is the

 

 22   gold standard, then, people should have to compare

 

                                                               333

 

  1   to four weeks, are you better than or worse than

 

  2   four weeks, or as good as four weeks, you know, are

 

  3   you as good at three days as you are at four weeks,

 

  4   or if the gold standard is one week, then, the

 

  5   comparison should be that, but I don't know that

 

  6   there is a lot of value to be gained at looking at

 

  7   multiple concentrations if the preclinical work is

 

  8   done adequately, and certainly I don't think dosing

 

  9   frequency helps.

 

 10             DR. CANTILENA:  Dr. Davidoff.

 

 11             DR. DAVIDOFF:  I agree with and extend a

 

 12   little bit what has just been said.  It seems to me

 

 13   that the assumption that has been expressed a

 

 14   number of times is that the concentrations that are

 

 15   generally implemented are high enough, so that they

 

 16   are essentially nuking the bugs in terms of the

 

 17   concentration.

 

 18             The issue, though, does seem to be

 

 19   primarily duration of exposure.  Judging from the

 

 20   data on clotrimazole, there was a fairly clear

 

 21   difference between one week and four weeks of

 

 22   exposure, minimal or maybe zero difference between

 

                                                               334

 

  1   one and four weeks for terbinafine, so I think it

 

  2   is not a fair assumption that one week is as good

 

  3   as four weeks for all drugs, and it does seem

 

  4   entirely reasonable to look for exposure-response

 

  5   relationship.

 

  6             Otherwise, both the committees, the

 

  7   Agency, and clinicians are essentially flying

 

  8   blind, and five years from now or 10 years from

 

  9   now, they will still be in the dark as to how to

 

 10   make the decisions if they don't have the data.

 

 11             DR. CANTILENA:  Dr. Lam.

 

 12             DR. LAM:  I actually concur with Dr.

 

 13   Schmidt in that I thought dose-response studies are

 

 14   given in drug development, and I was surprised to

 

 15   see that this group of drugs is not required to do

 

 16   that.

 

 17             Given the difference in response rate

 

 18   between one-week regimen and four-week regimen, I

 

 19   would imagine that there has to be some sort of an

 

 20   exposure-response relationship, and I would like to

 

 21   kind of turn the question into the opposite

 

 22   direction in terms of is there any historical

 

                                                               335

 

  1   reason or scientific reason that this group of

 

  2   drugs should be exempt from doing that.

 

  3             DR. CANTILENA:  Historically, you heard

 

  4   sort of how they got here, but I think in terms of

 

  5   the Rx to OTC switches, I don't have that history.

 

  6             Would you like to comment on that, Dr.

 

  7   Wilkin?

 

  8             DR. WILKIN:  Well, actually, requesting

 

  9   dose-response studies, you know, the Code of

 

 10   Federal Regulations is pretty good in giving us

 

 11   information on how to seek efficacy and safety

 

 12   information, but it is somewhat edentulous when it

 

 13   comes to going after dose ranging, and there is a

 

 14   ICHE.4 document that talks about dose ranging and

 

 15   exposure response, and interestingly enough, the

 

 16   last part of that is devoted to Phase IV dose

 

 17   ranging.

 

 18             When I first heard that, I thought, you

 

 19   know, that might be some regulatory humor, but it

 

 20   really does exist, you know, that you can look for

 

 21   this after something has already been approved, and

 

 22   generally, that is in the circumstance of where

 

                                                               336

 

  1   there is a safety issue and one might be trying to

 

  2   find a lower dose that might be just as effective.

 

  3             But, no, we really are often at the mercy

 

  4   of the sponsors to whether they find it something

 

  5   that they want to do.

 

  6             DR. CANTILENA:  Dr. Ringel.

 

  7             DR. RINGEL:  Many of these antifungals

 

  8   have been around, I don't know, I can't imagine,

 

  9   probably since the turn of the century, 1920, some

 

 10   of the older ones like heliprogen [ph], I think it

 

 11   is high time that we stop testing these drugs

 

 12   against placebo and start testing them against the

 

 13   known drugs, the drugs that we have that we know

 

 14   work, that at least another monograph system have

 

 15   been approved since 1982.

 

 16             If you think about it, the competition

 

 17   right now is how infrequent and how short a

 

 18   duration can you give these medications and still

 

 19   have them work.  Theoretically, you could have a

 

 20   drug that has a very steep response curve, so that

 

 21   you could get a maximal response in a very short

 

 22   duration, but the ultimate cure rate could still be

 

                                                               337

 

  1   very low.

 

  2             I mean you could get to a 20 percent cure

 

  3   rate very quickly, but maybe all you will get is a

 

  4   20 percent cure rate, and if you are only going to

 

  5   test them against placebos, you may actually be

 

  6   approving drugs that are less efficacious than the

 

  7   ones that are already out there.

 

  8             So, I think at this point, you know, 2004,

 

  9   I think it's time that we stop testing against

 

 10   placebo and start testing against known agents.

 

 11             DR. CANTILENA:  Thank you.

 

 12             Dr. Katz.

 

 13             DR. KATZ:  The point of necessity of new

 

 14   drugs getting dose-response studies, as brought out

 

 15   by Mr. Kresel's comment of comparing to gold

 

 16   standard, the problem is we have no gold standard.

 

 17   I mean our gold standard is, over placebo, 30

 

 18   percent efficacy, or if you see Dr. Fritsch's page

 

 19   9, page 10 cure rates of 20 percent over placebo,

 

 20   so we do need dose response.

 

 21             There may be drugs that we know with the

 

 22   oral antifungals, they can use one week a month and

 

                                                               338

 

  1   get equal effect, so it may be topical preparations

 

  2   would be in development that have to be used much

 

  3   less frequently or better cure rates if they use

 

  4   more frequently, so dose response I think would be

 

  5   very important because we have no gold standard.

 

  6             DR. CANTILENA:  Thank you.

 

  7             Dr. Wilkerson.

 

  8             DR. WILKERSON:  I just wanted to say I did

 

  9   my homework before I came, and went to the grocery

 

 10   store, you know, a drugstore, and looked at the

 

 11   over-the-counter antifungal products that were

 

 12   there.  Even as someone who I think is relatively

 

 13   sophisticated as far as these things, I was

 

 14   confused by everything that was out there.

 

 15             I thought part of the gist or thrust to

 

 16   this was to maybe bring some comparative value for

 

 17   the consumer to the table, such that the consumer

 

 18   could be guided on something beyond packaging and

 

 19   advertising claims as to which agent to pick,

 

 20   because when you go in there to look, I like the

 

 21   question a while ago, even using the same brand

 

 22   name, you are talking about two totally different

 

                                                               339

 

  1   antifungal agents, it is very, very confusing.

 

  2             My recommendation would be a simple analog

 

  3   scale, much like what we have done with the

 

  4   psoriasis drugs with the biologic compounds, is

 

  5   that we set a minimal efficacy level and allow that

 

  6   to be used as the standard, whatever it be, 60

 

  7   percent or whatever, so that consumers can actually

 

  8   compare between different products.

 

  9             If I pay X dollars for this, I will get

 

 10   this level of potential cure versus paying $3.00

 

 11   for this generic that will give me this potential

 

 12   level of cure.

 

 13             I think there has to be some, you know,

 

 14   and even amongst physicians, most physicians'

 

 15   choices are based upon who the last rep was that

 

 16   was in their office, that they remember their name.

 

 17   There is very little science that goes into picking

 

 18   these antifungals on the consumer or on the

 

 19   physician level.

 

 20             As far as the basic pharmacology, to me,

 

 21   this is just a slam dunk.  I mean if you are going

 

 22   to put a drug on the market, you need to know the

 

                                                               340

 

  1   pharmacology of it.

 

  2             DR. CANTILENA:  Dr. Benowitz.

 

  3             DR. BENOWITZ:  I would say first that I am

 

  4   sympathetic to the idea that if you have a good

 

  5   animal model, and you know pharmacokinetics and

 

  6   mechanism of action, that you can simplify the

 

  7   process and reduce the need to do dose response

 

  8   studies.

 

  9             However, I don't think we are there, but I

 

 10   think we should try to get there.  So, some of the

 

 11   things that I would suggest, for example, is that

 

 12   guinea pig data really be analyzed in a systematic

 

 13   way and brought to FDA to see how predictive it

 

 14   really is based on what we know from a whole

 

 15   variety of current agents, and see how good that

 

 16   test is.

 

 17             I think we need PK data including things

 

 18   like both concentrations in skin and also

 

 19   persistence.  It was of interest to me that

 

 20   terbinafine, I guess is the one persistent in the

 

 21   skin for up to 5 weeks after the end of

 

 22   administration.  I think that is what I heard, and

 

                                                               341

 

  1   other drugs don't do that, and that obviously is a

 

  2   key factor when you are dosing something, how long

 

  3   it stays in the skin.

 

  4             It is going to influence what level you

 

  5   build up.  So, I think it's a potential in the

 

  6   future, if we really got good PK data, good skin

 

  7   concentration data, good persistence data, and good

 

  8   animal model, but until we do that, I think we need

 

  9   to have dose response data.

 

 10             DR. CANTILENA:  Dr. Wood.

 

 11             DR. WOOD:  Could I just add to Neal's

 

 12   comment, and I think we need to be pretty careful

 

 13   of the animal model.  The animal model, from what I

 

 14   have heard, is, by definition, fundamentally

 

 15   different from the human model.

 

 16             The animal model is self-curing, the human

 

 17   model is not, so mechanisms of action that might be

 

 18   effective in the animal model, that would

 

 19   accelerate the self-cure, and would probably not be

 

 20   effective in humans, so I think the confidence in

 

 21   the animal model is, from what I have heard,

 

 22   grossly overstated right now.

 

                                                               342

 

  1             We know that it does not reproduce what we

 

  2   see in humans, and that is something we need to be

 

  3   careful about.

 

  4             DR. CANTILENA:  Dr. Davidoff.

 

  5             DR. DAVIDOFF:  That really needs a point

 

  6   of clarification, and that is, are we talking about

 

  7   clinical dose ranging studies or animal dose

 

  8   ranging studies, or both.

 

  9             DR. CANTILENA:  Clinical.

 

 10             DR. DAVIDOFF:  Okay.

 

 11             DR. CANTILENA:  Dr. Bisno.

 

 12             DR. BISNO:  Help me out as a

 

 13   non-dermatologist, because I am not sure what we

 

 14   are talking about in terms of the endpoints here.

 

 15   Are we talking about negative mycology, effective

 

 16   treatment, or complete cure?

 

 17             Particularly, I don't understand complete

 

 18   cure when you have eradicated the fungus, you have

 

 19   effectively improved the patient's symptomatology,

 

 20   and there is a tremendous gap between that and

 

 21   complete cure, what is in that area, are those just

 

 22   some residual scaling and flaking, and things like

 

                                                               343

 

  1   that, that are maybe of no clinical significance at

 

  2   all.

 

  3             So, if some of my dermatologic colleagues,

 

  4   who understand this a lot better than I, can

 

  5   explain what that big gap is and is it worthwhile

 

  6   to shoot for complete cure when even the best stuff

 

  7   that we have now is getting 20 percent cure, and we

 

  8   seem to be curing it mycologically and in terms of

 

  9   symptomatology, is that a reasonable standard to

 

 10   set.

 

 11             DR. CANTILENA:  Comments from the

 

 12   dermatologists?

 

 13             DR. KATZ:  Well, simply the difference

 

 14   there is clinically improved, in plain English,

 

 15   improved, or completely clear, and improved is very

 

 16   subjective and it is less of an endpoint, because

 

 17   it is subject to the investigator, who may be

 

 18   biased since he is doing the study for the drug

 

 19   company, and it is compared to placebo, which is a

 

 20   necessity, but in plain English, what they call

 

 21   "effective" is improved, which is important, and it

 

 22   may be important enough to some people.

 

                                                               344

 

  1             In fact, in real life, I check patients

 

  2   back, and, well, how is that doing, that topical

 

  3   treatment doing, oh, that is fine, that cleared me

 

  4   up, and to go along with what Dr. Elewski said, I

 

  5   said, well, let's have a look, and you look and

 

  6   it's 50 percent better.  I wouldn't have thought it

 

  7   was that great.  So, that is the difference.

 

  8             DR. CANTILENA:  Dr. Schmidt.

 

  9             DR. SCHMIDT:  I think that these funguses

 

 10   itch like the devil, and they are almost like an

 

 11   insect bite, like a mosquito bite, and most people,

 

 12   and I think these medications work very, very well

 

 13   and very, very fast for the most part, and most of

 

 14   my patients, I don't want to see them back and look

 

 15   at their feet again.

 

 16             So, what I do is I usually tell them to

 

 17   use one of these things, and when I see them again,

 

 18   what they do is use it for four or five days and

 

 19   then they stop, but I don't even wish to cure them,

 

 20   I don't think I can.  I think that every six

 

 21   months, or when it gets hot every summer, I tell

 

 22   them you are going to have to use this stuff again.

 

                                                               345

 

  1             So, I think it's a pipedream, you know,

 

  2   that basically, at least in Houston and the Gulf

 

  3   Coast, you know, maybe up here in Yankeeland, you

 

  4   know, that you are going to do it, but I don't

 

  5   think so down where we come from.

 

  6             DR. CANTILENA:  Thanks for clarifying

 

  7   that.

 

  8             DR. GHANNOUM:   I just would like to

 

  9   clarify something of the animal model and put it

 

 10   into perspective.  I think what our colleague said

 

 11   is very true.  It is a good idea to bring all the

 

 12   data together and see how predictive is this model,

 

 13   number one.

 

 14             Number two is this is not a model which is

 

 15   going to replace any clinical data.  It is a part

 

 16   of the puzzle.  A lot of the time, in the

 

 17   preclinical stage, you take a compound, you test it

 

 18   in vitro.  It works great.

 

 19             You go move into the animal model, whether

 

 20   it is for systemic infections or whether it is

 

 21   superficial infections, and the drug does not do

 

 22   anything.  So, I think it is a method of another

 

                                                               346

 

  1   stage for screening of the compound to determine

 

  2   whether it works or not.

 

  3             Now, once that is clarified, and then also

 

  4   it is going to help the manufacturers to test a

 

  5   number of things, to allow them to have some basis

 

  6   for moving into humans. Once they move into humans,

 

  7   obviously, they have to look at, you know, again, a

 

  8   lot of the drugs fail once you move from animals to

 

  9   human, so that is really where I would like to

 

 10   clarify.

 

 11             DR. CANTILENA:  All right.  Dr. Epps.

 

 12             DR. EPPS:  I think it would be useful, not

 

 13   only for dose response, but also for efficacy, to

 

 14   have that kind of information.  I like the

 

 15   head-to-head studies, I think that is interesting

 

 16   to compare drugs.  I agree there is no real

 

 17   standard, and I think individual response can vary.

 

 18             As far as guinea pigs, you know, we are

 

 19   not talking about IV or oral medication, we are

 

 20   talking about cream on feet, and I think it is

 

 21   pretty straightforward and easy.  Obviously, we go

 

 22   through the phases that we should, but I think the

 

                                                               347

 

  1   hazards are fewer when we are talking about feet.

 

  2             DR. CANTILENA:  Comments?  Over here, Dr.

 

  3   Alfano.

 

  4             DR. ALFANO:  I think Dr. Bisno hit on one

 

  5   of the key issues, maybe the pivotal issue, and

 

  6   that is what are we expecting in complete cure.  I

 

  7   think it is, in some ways artificial and

 

  8   potentially misleading.

 

  9             As I think through OTC categories and try

 

 10   to design what would be a complete cure, you think

 

 11   of acne, you think of psoriasis, gingivitis,

 

 12   dandruff.  You know, for the most part, we don't

 

 13   achieve complete cures in any of those conditions--

 

 14             DR. CANTILENA:  How about headache?

 

 15             DR. ALFANO:  --whether they are managed Rx

 

 16   or OTC.  So, it seems to be an artificial

 

 17   constraint that is compromised, his point about,

 

 18   you know, if the symptoms are mitigated and the

 

 19   organism is gone, what are we talking about.

 

 20             I think there should be a more appropriate

 

 21   way to view how we see this category going forward.

 

 22             The second comment I had is actually a

 

                                                               348

 

  1   question to the dermatologists.  I mean is there

 

  2   something in between an animal model and to full in

 

  3   vivo use studies.  I am thinking going back to the

 

  4   Layden chambers or even organ culture in which skin

 

  5   can be obtained in cultured foreskin, for example,

 

  6   which would be perhaps a more relevant model and

 

  7   allow for some of the type of analysis that FDA is

 

  8   looking for to help with the dose ranging, and so

 

  9   forth.

 

 10             I haven't heard it mentioned at all today,

 

 11   and I don't know if it has fallen into disfavor or

 

 12   whatever, but there was a time when I mean you can

 

 13   do permeability studies and find out about dermis

 

 14   penetration.

 

 15             I know, for example, a cadaver skin

 

 16   actually behaves very much like live human skin, so

 

 17   there do seem to be other mechanisms that could be

 

 18   brought to bear on this problem.

 

 19             DR. CANTILENA:  Any comments from the

 

 20   dermatologists?  Dr. Wilkin, do you have any

 

 21   experience with those other models?

 

 22             DR. WILKIN:  I think this bears on the

 

                                                               349

 

  1   notion of bioavailability for topical products and

 

  2   bioequivalence.  When one is doing a comparison of

 

  3   bioavailability of, say, a new product versus a

 

  4   reference listed product in the setting of a 505(j)

 

  5   Ananda [ph], a generic, or perhaps a 505(b)(2), the

 

  6   relevant part of our regs is 320.24(b)(4), which

 

  7   says that it is a topical trial, that is, it is a

 

  8   regular clinical trial, and you look at regular

 

  9   clinical endpoints.

 

 10             The rationale for why that is different

 

 11   from the drugs that are given systemically is there

 

 12   you have systemically, you have the blood, which

 

 13   may not be perfectly mixed, but is, if you will,

 

 14   well mixed, and it's in equilibrium at some point

 

 15   with the organ site.

 

 16             There is no comparable sampling site, no

 

 17   compartment, if you will, in the skin, and often

 

 18   the way the drug is extracted from different levels

 

 19   in the stratum corneum, it is not even clear

 

 20   whether it was in solution at the time it was

 

 21   extracted, and we know that drugs are not active

 

 22   unless they actually are in solution.

 

                                                               350

 

  1             So, we haven't figured out a really good

 

  2   way, but when we do, that is going to dramatically

 

  3   lower the current burden that is out there right

 

  4   now for all the generic topical drug products.  So,

 

  5   we are keen on hearing a good way to approach that.

 

  6             DR. CANTILENA:  Thank you.

 

  7             Mr. Kresel.

 

  8             MR. KRESEL:  I just wanted to comment on

 

  9   Dr. Katz's comment about bias, because for one

 

 10   thing, we really don't encourage bias, we are quite

 

 11   adamant about not wanting bias, and there really

 

 12   isn't an incentive on the part of an investigator

 

 13   to be biased, financially or otherwise, since they

 

 14   get paid whether the study fails or not.

 

 15             However, it is one of the reasons why we

 

 16   do placebo-controlled studies, because they are

 

 17   double-blind and placebo controlled, and if

 

 18   everybody gets better, then, in fact, you didn't

 

 19   beat placebo and your drug just failed.

 

 20             So, I think it is one of the reasons why

 

 21   we don't like to introduce active controls, because

 

 22   if, in fact, your control is active and everybody

 

                                                               351

 

  1   gets better, then, your drug does get approved.

 

  2             DR. KATZ:  I didn't mean that in a

 

  3   pejorative way. We are all biased.  I just mean

 

  4   that in a normal way, that is why we have placebos

 

  5   in the first place.

 

  6             DR. KRESEL:  If everybody gets better,

 

  7   then, you didn't beat placebo, your study fails

 

  8   anyway, your product doesn't get approved.

 

  9             DR. KATZ:  I understand that, but that is

 

 10   why we have placebos in the first place, and my

 

 11   comment was only in response to the fact that this

 

 12   intermediate state of effective can mean different

 

 13   things to different people, so if we have placebos,

 

 14   like we do, we can see the true effectiveness of

 

 15   the medication.  I was just meaning that in

 

 16   contrast to complete cure.  I didn't mean it in a

 

 17   negative manner.

 

 18             DR. CANTILENA:  Yes.

 

 19             DR. WILKIN:  I was going to make a comment

 

 20   about the active comparator.  There is also a

 

 21   document signed by President Clinton, Vice

 

 22   President Gore, 1997.  It is called Reinventing

 

                                                               352

 

  1   Government.

 

  2             There is a section regarding drugs. On

 

  3   page 27 of that, it points out those circumstances

 

  4   where we would use an active comparator, and that

 

  5   would be for indications which are severely

 

  6   debilitating or life-threatening.  So, that would

 

  7   be the setting.

 

  8             In other settings, it is clear-cut.  It

 

  9   said generally in other settings, an active

 

 10   comparator would not have to be in the mix.

 

 11             DR. CANTILENA:  And that is on what page

 

 12   again?  No.  All right.  It's very impressive.

 

 13             Why don't we go to Item No. 2 then, Issue

 

 14   2, in the form of a question for the committee

 

 15   then, under Clinical Efficacy.

 

 16             Given the efficacy of products currently

 

 17   marketed, should topical antifungal drug

 

 18   development programs for tinea pedis evaluate

 

 19   safety and efficacy at different concentrations,

 

 20   dosing durations, and dosing frequencies?

 

 21             Basically, exposure, you know, response,

 

 22   which is what we have been talking about.

 

                                                               353

 

  1             We will start over here if non-voting

 

  2   members would like to comment, and then we will

 

  3   head around, and if you can justify your answer or

 

  4   just yes or no, and I voted that way because, that

 

  5   would be fine.

 

  6             MR. KRESEL:  In order to be consistent

 

  7   with what I have said before, dosing duration I

 

  8   think is the one area that we could probably look

 

  9   at and get some data that would be useful to

 

 10   clinicians, so I would vote yes for dosing

 

 11   duration, but not dosing frequency or dosing

 

 12   concentration.

 

 13             DR. CANTILENA:  Dr. Alfano.

 

 14             DR. ALFANO:  I don't vote.  I would

 

 15   certainly agree with the comment, and I am glad Dr.

 

 16   Wilkin clarified, because I was sitting here all

 

 17   morning wondering why FDA can't get this

 

 18   information that they are asking for.

 

 19             Many years ago, when I used to be in the

 

 20   industry, it seemed to me FDA got whatever they

 

 21   wanted, so I now understand why some of this data

 

 22   is not available to you.

 

                                                               354

 

  1             DR. CANTILENA:  Dr Ten Have.

 

  2             DR. TEN HAVE:  Yes, especially with

 

  3   respect to non-responders.

 

  4             DR. CANTILENA:  Dr. Wood.

 

  5             DR. WOOD:  Yes.

 

  6             DR. CANTILENA:  Dr. Bisno.

 

  7             DR. BISNO:  Yes.

 

  8             DR. CANTILENA:  Dr. Ghannoum.

 

  9             DR. GHANNOUM:  I agree with dose duration.

 

 10             DR. CANTILENA:  Dr. Katz.

 

 11             DR. KATZ:  Yes.

 

 12             DR. CANTILENA:  Dr. Schmidt.

 

 13             DR. SCHMIDT:  Yes with the dose duration.

 

 14             DR. CANTILENA:  Dr. Davidoff.

 

 15             DR. DAVIDOFF:  Also yes, and also with the

 

 16   main focus on duration.

 

 17             DR. CANTILENA:  Dr. Whitmore.

 

 18             DR. WHITMORE:  Yes with the dose duration

 

 19   and frequency, and with regard to concentrations,

 

 20   if we are requiring MICs to be done, I guess we

 

 21   don't need the different concentrations, like, for

 

 22   instance, if something like tea tree oil gets

 

                                                               355

 

  1   proposed for a treatment, I think in that case, you

 

  2   would need if they came up with it, I don't know,

 

  3   but I think with products that are not established

 

  4   antifungal chemicals like the current ones we have,

 

  5   you would need different testing with different

 

  6   concentrations.

 

  7             DR. CANTILENA:  Thank you.

 

  8             Dr. Fincham.

 

  9             DR. FINCHAM:  Yes for all, and while I

 

 10   have the mike, it's a naive question or statement,

 

 11   but when you talk about these FDA regulations, and

 

 12   you throw out these numbers and the letters, I

 

 13   don't have a clue what you are talking about.  You

 

 14   are intimately involved with this on a day-to-day

 

 15   basis, but if you could just give us a simple

 

 16   explanation of what those are, it would help me

 

 17   immensely, and thank you very much for allowing me

 

 18   to say that.

 

 19             DR. CANTILENA:  Well, actually, you didn't

 

 20   ask me if you could say that.

 

 21             [Laughter.]

 

 22             DR. CANTILENA:  That was actually in the

 

                                                               356

 

  1   orientation packet that you got for the advisory

 

  2   committee, it's all the regulations and all the

 

  3   numbers.

 

  4             DR. WHITMORE:  I think all the numbers

 

  5   were just citations of the locations.  They don't

 

  6   mean anything to us, but they are just citations of

 

  7   where this is.

 

  8             DR. FINCHAM:  My comment still stands.

 

  9             DR. WILKIN:  I may have said CFR.  It is

 

 10   true, we tend to talk in a lot of alphabets.  Code

 

 11   of Federal Regulations is basically what Congress

 

 12   has given us, how to actually interpret the '38

 

 13   Act, and it does have a lot of interesting nuggets.

 

 14             It is available electronically on the FDA

 

 15   web site.  If you jot those down or I could mention

 

 16   them to you afterwards, there are some good places

 

 17   to look, because the exact wording is pivotal to

 

 18   industry.  I know they really read those lines very

 

 19   carefully, and we do, as well, and they have

 

 20   enormous constraints ultimately on the information

 

 21   set that comes into FDA, so they are not trivial.

 

 22             ICH, I may not have mentioned that, I

 

                                                               357

 

  1   think it is International Conference on

 

  2   Harmonisation.  It is Harmonisation with an "s" at

 

  3   the end, so it's not totally harmonized with

 

  4   American English, but it is Japan and Europe, and I

 

  5   think Canada is involved, and it involved

 

  6   academics, government regulators, and industry all

 

  7   coming to the table and deciding what were some of

 

  8   the common ways that everyone can look at it in

 

  9   different geographic regions with the idea that

 

 10   someday we might be able to have NDAs that are

 

 11   submitted simultaneously in different countries, so

 

 12   I think it is a positive sort of step, and I

 

 13   apologize.

 

 14             DR. CANTILENA:  Dr. Ringel.

 

 15             DR. RINGEL:  I would say yes.  Just one

 

 16   further comment that if, in fact, we can't get an

 

 17   active control group when doing these studies, I

 

 18   would think that at the very least we should be

 

 19   able to have some minimal standard of efficacy.

 

 20   Perhaps that would be allowed by the regulations.

 

 21   I think it's CFR 43.154.

 

 22             [Laughter.]

 

                                                               358

 

  1             DR. CANTILENA:  I think you just quoted

 

  2   the Drug Enforcement Agency, but I am not sure.

 

  3             Dr. Lam.

 

  4             DR. LAM:  Yes for duration and frequency.

 

  5             DR. CANTILENA:  Dr. Patten.

 

  6             DR. PATTEN:  Yes for all three.

 

  7             DR. CANTILENA:  Dr. Wilkerson.

 

  8             DR. WILKERSON:  Yes.

 

  9             DR. CANTILENA:  For all three?

 

 10             DR. WILKERSON:  For all three.

 

 11             DR. CANTILENA:  Dr. Raimer.

 

 12             DR. RAIMER:  I wouldn't care too much

 

 13   about concentrations as long as we had good,

 

 14   reliable MICs.  I think dosing duration is very

 

 15   important.  Dosing frequencies, I agree, it is

 

 16   probably going to be once or twice a day unless the

 

 17   company wanted to go for something like once a week

 

 18   for a month or thought they had something they

 

 19   could market.  I don't think it matters whether you

 

 20   put it on once or twice a day to most patients.

 

 21             DR. CANTILENA:  Dr. Epps.

 

 22             DR. EPPS:  Yes for all three, and I guess

 

                                                               359

 

  1   as a point of information, and thanks to CDER,

 

  2   under Tab 6 are some of the CFR and definitions.

 

  3             DR. CANTILENA:  Dr. Clapp.

 

  4             DR. CLAPP:  Yes for all, but my concern is

 

  5   about standardization of efficacy.

 

  6             DR. CANTILENA:  Dr. Benowitz.

 

  7             DR. BENOWITZ:  Yes for all three, but I

 

  8   would just emphasize that the concentration issue,

 

  9   which many members felt did not have to be tested,

 

 10   I think in theory, that could be defended, but I am

 

 11   not convinced that the data presented to date

 

 12   adequately defend not testing different

 

 13   concentrations.

 

 14             I think it is possible, but I don't think

 

 15   it is done, and I think it is the obligation of a

 

 16   sponsor to do that before we accept not testing

 

 17   different doses.

 

 18             DR. CANTILENA:  Thank you.

 

 19             Ms. Knudson.

 

 20             MS. KNUDSON:  I will say yes to all three,

 

 21   and I would like to say that as a consumer, I would

 

 22   certainly like to see comparative trials done, and

 

                                                               360

 

  1   I don't care whether a tube of this medication only

 

  2   cost $8.00, to some people, that is really a very

 

  3   important figure.

 

  4             DR. CANTILENA:  Thank you.

 

  5             My vote is yes to all three.  I think

 

  6   exposure response is important, and it just

 

  7   improves the overall use of the product.

 

  8             The tally, please?

 

  9             LCDR SPELL-LeSANE:  To Question No. 2, 19

 

 10   yes, all yes, no "no."

 

 11             DR. CANTILENA:  Thank you.

 

 12             I think really what I would like to do is

 

 13   you didn't ask us a question per se for clinical

 

 14   efficacy, lowest acceptable rate of care, so what I

 

 15   would like to do is just open this for discussion

 

 16   and see if we can drive toward a consensus.  If

 

 17   not, then, we can do a vote on this, but this would

 

 18   be Item No. 1, where we are looking for the lowest

 

 19   acceptable rate of cure, clinically meaningful, for

 

 20   a topical OTC drug product for the treatment of

 

 21   tinea pedis, using the complete clinical and

 

 22   mycological clearance as definition of "cure."

 

                                                               361

 

  1             Really, what is the lowest that you would

 

  2   be comfortable with for a cure rate, you have

 

  3   something that is effective.

 

  4             I will just open it up for discussion.

 

  5             Dr. Lam.

 

  6             DR. LAM:  Are we lumping 1-week regimen

 

  7   and 4-week regimen together into our consideration

 

  8   and deliberation?

 

  9             DR. CANTILENA:  I was, but we will ask Dr.

 

 10   Ganley or Dr. Wilkin, can we lump the 1- and the

 

 11   4-week for acceptable cure rate?  Are you looking

 

 12   for a cure rate irregardless of duration of

 

 13   treatment?  Yes, okay, so we are lumping.

 

 14             So, what is a number that meets your

 

 15   definition of an acceptable cure rate in this

 

 16   setting?  Dr. Wood.

 

 17             DR. WOOD:  I am not going to give you a

 

 18   number, but let me raise an issue that came up from

 

 19   the homework.

 

 20             It seems to me that if you are a consumer

 

 21   and you are about to make the decision as to

 

 22   whether you should buy a product to treat some

 

                                                               362

 

  1   disease, you want to know what the likelihood that

 

  2   you are going to respond is, but you also want to

 

  3   know what other options are out there.

 

  4             Now, in an Rx situation, you expect your

 

  5   physician to do that, you expect your physician to

 

  6   look at you, make the diagnosis, and decide what

 

  7   the optimal therapy is.

 

  8             In an over-the-counter situation, it seems

 

  9   to me that the consumer ought to have information

 

 10   on the cure rates which are substantially higher,

 

 11   and with systemic therapy that are available with

 

 12   these.

 

 13             I think that should be in the package

 

 14   labeling, because that seems to me a critical piece

 

 15   of information that people ought to know.

 

 16             Somebody said a minute ago, you know, if

 

 17   you are buying $8.00 tubes of something, and you

 

 18   are getting nowhere, for many patients, the

 

 19   decision to go to a dermatologist would be a huge

 

 20   decision for them, and their loins would be girded

 

 21   if they knew that there was a likelihood that the

 

 22   doctor could provide the therapy that would be more

 

                                                               363

 

  1   effective.

 

  2             DR. CANTILENA:  Dr. Bisno.

 

  3             DR. BISNO:  Again, i want to make sure

 

  4   that I understand what we are discussing here.  Are

 

  5   we discussing the complete cure for which the

 

  6   general data are about 20 percent, because it says

 

  7   "complete clinical and mycologic cure," so you are

 

  8   asking what is the lowest acceptable rate for

 

  9   complete cure in which the general data are about

 

 10   20 percent?

 

 11             DR. CANTILENA:  I think that is what they

 

 12   are asking, yes.

 

 13             DR. BISNO:  I am a little bit blown away

 

 14   by that, because the only colleagues I have that

 

 15   think that 20 percent is a great rate are my

 

 16   oncologic colleagues, who really have to deal with

 

 17   some very, very life-threatening infections.

 

 18             If the best we can do is 20 percent, I am

 

 19   not sure that we should be sitting around here in

 

 20   this room, I am not sure what we are accomplishing.

 

 21   My personal view, and again I am reluctant to

 

 22   express this, since I don't have the requisite

 

                                                               364

 

  1   dermatologic expertise, but I do see a lot of

 

  2   inflammatory conditions and I know that after you

 

  3   have cured the infection, and after you have

 

  4   eradicated the organism, it takes a long time for

 

  5   the physical manifestations of inflammation to go

 

  6   away.

 

  7             Therefore, I wonder, you know, if somebody

 

  8   came up with something that was a combination of

 

  9   terbinafine and then used the last week, steroids,

 

 10   that he might really get a much higher clinical

 

 11   cure rate because would inflammation would subside

 

 12   and it would look great, but I am not sure it is

 

 13   something we would want to be doing on a routine

 

 14   basis, maybe we would.

 

 15             Anyway, I just have difficulty with

 

 16   setting a lowest acceptable range for complete cure

 

 17   when we know that the bar right now is set at only

 

 18   20 percent, and is it possible that we can talk

 

 19   about lowest acceptable cure rate for mycologically

 

 20   and symptomatically improved, or is that not an

 

 21   acceptable thing to be discussing?

 

 22             DR. CANTILENA:  I will ask Dr. Wilkin

 

                                                               365

 

  1   because it's advice for him and Dr. Ganley.

 

  2             DR. WILKIN:  I think it can be approached

 

  3   in multiple ways.  The truth is that we do not know

 

  4   which patients who are effective treatment meaning

 

  5   KOH-negative and culture-negative, but having a

 

  6   1-plus erythema or 1-plus scale, or maybe both of

 

  7   those, how many of those really that scale and

 

  8   erythema is due to residual tinea and how much is

 

  9   due to some other condition, maybe just inadequate

 

 10   epidermal turnover.

 

 11             Our thought was that while it may be

 

 12   conservative, and I think it is conservative,

 

 13   looking at the complete cure population, it still

 

 14   may not be complete cure, because there may be some

 

 15   KOH's that they couldn't find it, and some cultures

 

 16   that they couldn't find it, so people still get

 

 17   into the complete cure, and still have--I mean

 

 18   these are all very imperfect ways of looking at it,

 

 19   but I think Dr. Bisno makes an important point.

 

 20   You probably wouldn't want to be going for 100

 

 21   percent.

 

 22             I think that is the essential point, is

 

                                                               366

 

  1   100 percent is not the target, because it is

 

  2   probably going to be hard to get there.  Another

 

  3   example of what you are describing is if you look 3

 

  4   weeks after treating a pneumonia, at the chest

 

  5   x-ray, you would still see, you know, maybe what it

 

  6   looked like at the beginning.

 

  7             So, I think that is the way it is with the

 

  8   foot, the epidermis is not going to turn over, but

 

  9   the idea of the complete cure at least is something

 

 10   that is--it is somewhat artificial, but it is a

 

 11   very clear endpoint.

 

 12             DR. BISNO:  First of all, just finding

 

 13   mycologic elements, again, I mean the clinical

 

 14   situation may have been completely resolved, but,

 

 15   you know, fungi are universal and it may be

 

 16   difficult to completely eradicate even if you have

 

 17   eradicated a clinical--but I am getting beyond my

 

 18   own area of expertise by far.

 

 19             But what I am saying is if we set 25

 

 20   percent or 30 percent as an acceptable cure rate,

 

 21   then, we don't have anything on the market right

 

 22   now that meets our executive cure rate, is that

 

                                                               367

 

  1   correct?

 

  2             DR. WILKIN:  Well, you have Dr. Fritsch's

 

  3   example. What page is that on?

 

  4             DR. CANTILENA:  It's Tab 4, page 2, for

 

  5   the complete cure rates.

 

  6             DR. WILKIN:  The complete cure at the

 

  7   time.  This is now, again, Week 6 to 9, so in 6

 

  8   weeks it has allowed for substantial epidermal

 

  9   turnover.  This is like waiting for many months

 

 10   before you get the chest x-ray.

 

 11             DR. WHITMORE:  I have a question.  This

 

 12   addresses labeling, and not what we are saying the

 

 13   FDA should be approving, right?

 

 14             DR. CANTILENA:  I think actually we have

 

 15   on sort of the next category, we will be talking

 

 16   about the labeling. Here, I think they are asking

 

 17   for really, you know, in terms of a complete cure

 

 18   rate, what is something that is meaningful from our

 

 19   standpoint for an approvable drug.

 

 20             So, like if you had a new drug under

 

 21   development, what would you like to see, and I

 

 22   think the ideas earlier about the active control

 

                                                               368

 

  1   are important.

 

  2             I think that sort of gives you a

 

  3   reference, you can have vehicle only and an active

 

  4   control, and that really sort of tells you exactly

 

  5   where you are, but are you able to ask for those,

 

  6   active control, and placebo, is that something that

 

  7   is feasible, or is that advice that really couldn't

 

  8   be followed?

 

  9             DR. WILKIN:  Again, if it's for an

 

 10   indication that is not life-threatening or severe

 

 11   debilitating, typically, it's against the vehicle

 

 12   or the placebo, and not against an active.  I mean

 

 13   that just has been the standard.

 

 14             I think I missed a response to one of Dr.

 

 15   Bisno's points, and that is, you know, what should

 

 16   the committee be looking at.  It would be I think

 

 17   acceptable to look at maybe something that is less

 

 18   conservative, the effective treatment, realizing

 

 19   that some of the people who have effective

 

 20   treatment are clearly going to have some fungus

 

 21   remaining.

 

 22             None of these are perfect ways of looking

 

                                                               369

 

  1   at it, but if the committee felt more comfortable

 

  2   characterizing the endpoint, the lowest acceptable

 

  3   in terms of effective treatment, we would be happy

 

  4   to hear it either way.

 

  5             DR. BISNO:  Well, I would certainly bow to

 

  6   the expertise of my dermatologic colleagues on this

 

  7   one.  I am out of my depth.

 

  8             DR. CANTILENA:  We actually have a list

 

  9   going here.  We have Epps, Katz, Fincham, Wood, and

 

 10   Davidoff.

 

 11             Dr. Epps.

 

 12             DR. EPPS:  I guess speaking clinically,

 

 13   the patients, we don't see the ones who do well,

 

 14   the ones who go to the drugstore, they get the

 

 15   cream, they are treated, and it works well.  The

 

 16   ones who are referred to me, and when we say

 

 17   "fail," I mean it looks like baseline.  It is still

 

 18   raw, it is still macerated, they are still

 

 19   fissuring, it is not like it is just a little pink,

 

 20   otherwise, they wouldn't come to the dermatologist.

 

 21             If it is getting better with the

 

 22   over-the-counter, they keep using it, oh, it's

 

                                                               370

 

  1   getting better, I am just going to keep going.  How

 

  2   long that is varies by the patient.

 

  3   Percentagewise, I tell a lot of people it's zero or

 

  4   100, it works or it doesn't.  I mean ideally,

 

  5   across the board, I guess I tend to be tough, like

 

  6   I would like 75, 80 percent, I mean we want it to

 

  7   work, that is what I would call most.

 

  8             I don't think "most" is equivalent to

 

  9   better, because we are not comparing drug to drug,

 

 10   but certainly it should be better than vehicle, it

 

 11   should be better than placebo, obviously, that is

 

 12   proven.

 

 13             As far as culturing, by the time we get to

 

 14   the subspecialist, you know, they are partially

 

 15   treated, it's not very useful, you may still get a

 

 16   KOH, sometimes that can be helpful, but a lot of

 

 17   the ones that don't work tend to be weeded out.

 

 18             I mean you use if three or four times, it

 

 19   is not working, you just don't use that drug

 

 20   anymore, and fortunately, we have a lot of options,

 

 21   but a lot of the patients, if you ask them--and I

 

 22   guess that goes to reporting--what was the cream

 

                                                               371

 

  1   that you used before, well, it was white, and

 

  2   that's all you can get.  They don't remember the

 

  3   name, they don't remember, you know, well, it was

 

  4   my friend's, you know, you get a lot of answers, so

 

  5   that clearly affects the reporting of failures, as

 

  6   well.

 

  7             DR. CANTILENA:  Dr. Katz.

 

  8             DR. KATZ:  Well, the question is what

 

  9   should we accept as the lowest acceptable rate.

 

 10   Now, it was my understanding from a previous

 

 11   meeting at the FDA that the FDA approves medication

 

 12   if the safety profile was such that it shows some

 

 13   effectiveness, even the slightest statistically

 

 14   significant effectiveness in the face of pretty

 

 15   complete safety.

 

 16             If that is the case, and you can correct

 

 17   me, Dr. Wilkin, if that is not correct, that is why

 

 18   things like Penlac, which is almost tantamount to

 

 19   useless, but it is completely safe, and it did show

 

 20   a slight, after a year, 15 percent of people got

 

 21   better, so that is why it was approved.  I wasn't

 

 22   involved in that.  So that was my understanding.

 

                                                               372

 

  1             Now, if that is the case, then, the answer

 

  2   to this question should be the lowest acceptable

 

  3   rate in the face of pretty complete safety, should

 

  4   be good effect over placebo even if it's 20

 

  5   percent.

 

  6             That, seeming somewhat ludicrous, we get

 

  7   into the situation, which we are not answering the

 

  8   question on labeling now, but in answer to Dr.

 

  9   Wood's comment, I don't know that we have to set a

 

 10   certain percentage here if there is truth in

 

 11   labeling.

 

 12             That is going to be another issue, but

 

 13   rather than arbitrarily set the lowest acceptable

 

 14   rate, if something is on the label that says 15

 

 15   percent of patients can expect complete clearing,

 

 16   but that 50 percent of patients can expect

 

 17   significant improvement, that tells the consumer

 

 18   quite a bit.

 

 19             I know you don't want to get into

 

 20   labeling, but that would be my argument against

 

 21   setting a lowest acceptable rate, if my feeling of

 

 22   the charge at the FDA is correct.

 

                                                               373

 

  1             DR. CANTILENA:  Yes, Dr. Bull.

 

  2             DR. BULL:  I would like to bring your

 

  3   attention to the other part of that statement,

 

  4   which is that the lowest acceptable rate of cure

 

  5   that is clinically meaningful, and I think

 

  6   certainly we want to be in the business on behalf

 

  7   of public health of approving drugs that provide

 

  8   something clinically meaningful for the patients,

 

  9   who are either prescribed a drug or the ones for

 

 10   over-the-counter products, purchase them on the

 

 11   basis of self-diagnosis and self-management.

 

 12             So, I think it is very important to attend

 

 13   to the qualifier that is part of this Question 1,

 

 14   which is what is clinically meaningful, and that

 

 15   what we want your input on is to attend to what is

 

 16   the lowest acceptable rate that addresses this

 

 17   concern of what is clinically meaningful and

 

 18   patients having a reasonable expectation of having

 

 19   a positive effect, a benefit relative to the risk

 

 20   for their condition.

 

 21             DR. KATZ:  Then, perhaps on the basis of

 

 22   that and Dr. Bisno's comments, this question should

 

                                                               374

 

  1   be altered, rather than saying our definition of

 

  2   cure, rather that we should use the definition of

 

  3   effectiveness, which means significant clinical

 

  4   improvement and mycologic cure.  Maybe the question

 

  5   should be changed.

 

  6             DR. CANTILENA:  As we go around, you can

 

  7   qualify your answer in that way.  I think that is

 

  8   perfectly reasonable.

 

  9             Dr. Fincham.

 

 10             DR. FINCHAM:  I guess just looking at this

 

 11   from a consumers' perspective, if you have

 

 12   something on the label that says "cures most," I

 

 13   think it would behoove everybody involved, and

 

 14   certainly people are making excellent points about

 

 15   definitions and rates and whatnot, but I think we

 

 16   need to be specific or suggest that it be specific

 

 17   as far as what those words mean, so the consumer

 

 18   can make an informed decision in order to be

 

 19   empowered about his or her health.

 

 20             To get to what Dr. Epps said, you know, we

 

 21   saw slide, several times curiously, from different

 

 22   people, about presentation of interdigital tinea

 

                                                               375

 

  1   pedis, and it looked one way on the screen, but if

 

  2   you look at the photo, page 4 of the Novartis

 

  3   handout, I would doubt that this patient just

 

  4   appeared at the pharmacy to get this fixed.

 

  5             I mean I would say that there are some

 

  6   serious involvement here.  It looks like there is

 

  7   some nail involvement.  What I am trying to say is

 

  8   a person like this or a person with a less severe

 

  9   case of tinea pedis should have an informed ability

 

 10   to empower themselves to make a decision based upon

 

 11   what the labeling says relative to "cures most,"

 

 12   what does cure mean, what does most mean.

 

 13             Again, we are back to semantics.  We are

 

 14   back probably to 3(b), but it is hard to separate

 

 15   these out and look at them one question at a time,

 

 16   and I just think that the more specific that you

 

 17   can be, the better it is going to be for the most

 

 18   important person in this whole equation.  It is not

 

 19   us in the room, it's the patient that is going to

 

 20   use it or try to use it to get better.

 

 21             DR. CANTILENA:  Dr. Wood.

 

 22             DR. WOOD:  Well, I am a great believer in

 

                                                               376

 

  1   letting the marketplace shake these things out.  I

 

  2   mean I think the way to handle this is to have

 

  3   people put on the label the efficacy found from

 

  4   that product, defined in whatever common way you

 

  5   want to define that, and that should have on the

 

  6   label and the comparison that can be achieved from

 

  7   an Rx product.

 

  8             The reason I like that is going back to

 

  9   the comment that was just made, is what is the

 

 10   minimally clinically significant effect is a moving

 

 11   target.  You know, the minimally clinically

 

 12   significant effect for a diuretic was different

 

 13   when it was a mercurial diuretic from when

 

 14   furosemide came along.

 

 15             So, as therapy improves, what is minimally

 

 16   acceptable, and hopefully improves with it,

 

 17   minimally acceptable, to me, seems different today

 

 18   with systemic and the drugs that have been given

 

 19   systemically produce 70 percent cure in patients

 

 20   who have been defined as resistant to treatment.

 

 21             So, I agree with what was just said by

 

 22   Jack, I mean I think the consumer should know what

 

                                                               377

 

  1   they are likely to see with the efficacy, and that

 

  2   when Dr. Whitmore, or whoever it was, goes into the

 

  3   pharmacy and picks up these packets and looks at

 

  4   them, he should be able to see the different

 

  5   response rates for the different products, and have

 

  6   some concept of how that fits with alternatives.

 

  7             DR. DAVIDOFF:  I want to be sure I am

 

  8   clear on exactly why this question is being asked.

 

  9   I mean I am assuming that it is being asked because

 

 10   the Agency is trying to decide whether they should

 

 11   set a threshold level before a drug is approved.

 

 12   Am I correct?  That makes some difference as to the

 

 13   way I would answer the question.

 

 14             DR. CANTILENA:  Dr. Wilkin, would you like

 

 15   to answer?

 

 16             DR. WILKIN:  Again, I think there is a

 

 17   marketing pressure for faster, and faster may mean

 

 18   it still beats vehicle, but there may be a drop in

 

 19   the efficacy whether you look at it as complete

 

 20   cure or effective treatment.

 

 21             We are wondering if there ought to be some

 

 22   base rate below which even if you have a product

 

                                                               378

 

  1   that has no major safety issues in the safety

 

  2   profile, whether still there should be that

 

  3   baseline.

 

  4             DR. DAVIDOFF:  So, it is an approval

 

  5   decision question.  My thoughts in that connection

 

  6   are that if it is an approval question, it seems to

 

  7   me it would be difficult to justify accepting a new

 

  8   product unless the efficacy rate, whether it is

 

  9   defined on the basis of complete cure or effective

 

 10   cure, that is less than what is on the market.

 

 11             That just seems reasonable to me.  I

 

 12   realize the marketplace maybe speaks otherwise, but

 

 13   in terms of regulatory decisions, that seems

 

 14   reasonable.

 

 15             I also recognize, though, that there are

 

 16   other approaches to making the decision.  I mean

 

 17   one would be to look at what is the absolute risk

 

 18   reduction for other drugs or other classes that is

 

 19   considered acceptable, sometimes expressed as

 

 20   number needed to treat, and number needed to treats

 

 21   in the range of 5, which is what I understand the

 

 22   complete cure rate here would translate into, are

 

                                                               379

 

  1   considered terrific.  I mean a lot of drugs on the

 

  2   market that have NNTs of 100 or whatever.

 

  3             So, I think that you could take that

 

  4   approach and say that at least it ought to be doing

 

  5   as well as most other drugs in terms of NNT, and it

 

  6   clearly would be, I think.

 

  7             The final thought in connection with

 

  8   rationale would be that I agree with Alastair Wood

 

  9   that it is hard to give a single answer, because a

 

 10   lot depends on the seriousness of the underlying

 

 11   condition.

 

 12             I think you would accept efficacy of maybe

 

 13   1 percent absolute risk reduction for something

 

 14   that was a fatal disease.  I mean I would be happy

 

 15   to have a 1 percent chance of being protected or

 

 16   cured if I was otherwise going to die, but if I

 

 17   took the drug, I would have a small chance of

 

 18   survival.

 

 19             If it is a matter of clearing up a rash on

 

 20   my feet, I might see it differently.  I might be

 

 21   interested in complete cure rates that were In a

 

 22   different ballpark than maybe would have to be

 

                                                               380

 

  1   higher--

 

  2             DR. CANTILENA:  But that is the question,

 

  3   Frank, is higher.

 

  4             DR. DAVIDOFF:  Yes, I understand, and I

 

  5   think that that is a reasonable way to go if the

 

  6   condition that you are treating is less than fatal.

 

  7             DR. CANTILENA:  We have Dr. Ringel.

 

  8             DR. RINGEL:  I have two comments.  The

 

  9   first one addresses what everyone is talking about

 

 10   here.  Basically, I kind of disagree.  I think that

 

 11   the FDA should use as a standard mycologic cure

 

 12   rather than complete cure or even effective cure,

 

 13   and the reasons are threefold.

 

 14             First, because at the very least, I think

 

 15   you should be able to say that you should kill the

 

 16   fungus to an optimal level.  Whether or not the

 

 17   person gets better, I don't know, but at the very

 

 18   least, we should be able to say that the fungus

 

 19   dies.  That is number one.

 

 20             The second is that perhaps it is not quite

 

 21   as straightforward as complete cure, but it is

 

 22   certainly more straightforward than effective cure.

 

                                                               381

 

  1   At least you can measure it, you could do a KOH,

 

  2   you could do a culture.  I know they are not

 

  3   perfect, but it's doable.

 

  4             The third reason is that I don't know any

 

  5   other antimicrobial agent that is being held to the

 

  6   standards that we are holding tinea pedis.  When I

 

  7   treat a patient for scabies, the scabies' mites

 

  8   will be dead the next day or two days perhaps, but

 

  9   I tell the patient he is going to itch for another

 

 10   two weeks, and I don't call that ineffective

 

 11   treatment.

 

 12             When someone has pneumonia, they cough for

 

 13   another month.  That doesn't mean that they still

 

 14   have pneumococcus. When they have meningitis, they

 

 15   are going to feel lousy for the next two months.

 

 16   It doesn't mean that their CNS is still infected.

 

 17             I think that for those reasons, mycologic

 

 18   cure is actually the better standard here, and I am

 

 19   going to go a little bit out on the limb.

 

 20             I would say that if we are going to choose

 

 21   an efficacy level, I would choose that of the first

 

 22   modern antifungal, which at least in my mind has

 

                                                               382

 

  1   always been miconazole, and that is very

 

  2   subjective, I realize, but, you know, trained when

 

  3   I did, I thought of the old antifungals and the new

 

  4   antifungals.

 

  5             I have always thought of the new

 

  6   antifungals as starting with miconazole, so I would

 

  7   say that the efficacy for mycologic cure should be

 

  8   at least that of miconazole, and I supposed we

 

  9   could look that up.  I know it is arbitrary, but

 

 10   that is what I would do.  That is the first

 

 11   comment.

 

 12             The second comment is I guess this is

 

 13   addressing Dr. Wood about whether or not we need to

 

 14   compare topical antifungals to oral antifungals,

 

 15   and I would I think argue against that for two

 

 16   reasons.

 

 17             First of all, I think most normal

 

 18   consumers would assume that over-the-counter

 

 19   medications are not as effective as prescription

 

 20   medications.  It may or may not be true, but I

 

 21   think that is what people assume.

 

 22             For example, if they get an

 

                                                               383

 

  1   over-the-counter antitopical, antibiotic that is

 

  2   not helping, they will go to their doctor and say,

 

  3   gee, that didn't help, what else do you have,

 

  4   assuming the doctor is going to have something that

 

  5   is stronger and better.

 

  6             The other issue is that I think that you

 

  7   can't assume that the safety of a topical

 

  8   antibiotic is going to be the same as the safety of

 

  9   a systemic antibiotic.

 

 10             I don't think that people should assume,

 

 11   well, I can just go the doctor and do better,

 

 12   because the systemic antibiotics have black box

 

 13   warnings for liver toxicity, for congestive heart

 

 14   failure, and also have significant hematologic

 

 15   toxicity, so I really don't want my patients going

 

 16   to the drugstore and say, hey, well, I can just get

 

 17   Sporonox.

 

 18             I don't think that is good.  I would

 

 19   rather have them approach it the way I think most

 

 20   people do, when you are first looking at

 

 21   over-the-counter, if that doesn't help, then, going

 

 22   to their physician for a prescription.

 

                                                               384

 

  1             DR. CANTILENA:  Dr. Schmidt.

 

  2             DR. SCHMIDT:  Looking at the data that has

 

  3   been presented today and thinking about skin

 

  4   diseases just in general, when I have patients come

 

  5   in with a lot of these skin diseases, like acne, I

 

  6   usually consider a good improvement, say, for acne,

 

  7   at about 20 percent per month, and usually, someone

 

  8   after about 3 months, I like to see about, say, 75

 

  9   to 85 percent clearing.

 

 10             To me, I think these antifungal agents are

 

 11   much more effective than some of the medications

 

 12   that we use for acne, so in looking at these

 

 13   graphs, I would say that what I would put down for

 

 14   this, if you want some hard data, is between 20 and

 

 15   30 percent improvement in a week or two, and then I

 

 16   think the bar should be about 75 percent after a

 

 17   month for all these topical antifungals.

 

 18             I think that, to me, you know, 75 percent,

 

 19   that is a magic number in my mind, maybe more in

 

 20   acne, eczema, but if you had to say from what you

 

 21   see in these studies, you know, with the 20 to 30

 

 22   percent, and then it bounces up with some of the

 

                                                               385

 

  1   others, that that is the bar that I would say if we

 

  2   are looking for numbers.

 

  3             DR. BISNO:  Do you mean symptomatic in

 

  4   mycologic, but not complete?

 

  5             DR. SCHMIDT:  Yes.

 

  6             DR. CANTILENA:  Dr. Ghannoum.

 

  7             DR. GHANNOUM:  I think the way, let's say,

 

  8   we look at other antifungals, like it was suggested

 

  9   it would be good to have a comparator,

 

 10   non-inferiority sort of cases.  We don't have that

 

 11   because we don't have gold standard.

 

 12             But I think we have what is available in

 

 13   the market, and I think that should be for complete

 

 14   cure, and if say like "assume," it is

 

 15   non-inferiority, it should be between 20 to 30

 

 16   percent.

 

 17             If we go into the effective cure, even if

 

 18   you look at the oral stuff, let's say Lamisil

 

 19   compared to Sporonox when they are compared for

 

 20   onychomycosis, it was 65 percent sort of cure, so I

 

 21   think that is reasonable for the effective cure.

 

 22             DR. CANTILENA:  Thank you.

 

                                                               386

 

  1             Dr. Wood.

 

  2             DR. WOOD:  I think we should answer this

 

  3   question the way we are doing it.  I think I

 

  4   understand now what Dr. Wilkin is asking us, and it

 

  5   seems to me that the question we are being asked is

 

  6   how we evaluate products, and everybody rushing to

 

  7   the bottom, and that everybody moves to the bottom

 

  8   of the pack and finds the lowest dose that they can

 

  9   give for the shortest period of time, anything that

 

 10   beats placebo.

 

 11             Now, I think we answered that already, and

 

 12   I think we said that we should see exposure

 

 13   ranging, and I think you should only approve drugs,

 

 14   assuming they have no toxicity, that are given at

 

 15   the exposure that produces the maximum effect.

 

 16             That gets you off the hook for the rush to

 

 17   the bottom, which is what I am hearing here, and

 

 18   having said that, maybe surprisingly, I am very

 

 19   opposed to introducing new hurdles that drugs have

 

 20   to leap to get approved.

 

 21             So, the hurdle is you beat placebo right

 

 22   now, and the idea that we are going to sit around

 

                                                               387

 

  1   here and kind of chew on our thumbs and come up

 

  2   with some arbitrary number that you have to beat to

 

  3   get approved is very disturbing to me, because that

 

  4   creates all kinds of issues for other drugs, as

 

  5   well, you know, what is it in heart failure, what

 

  6   is it in Alzheimer's, for God's sake, I mean the

 

  7   effects there are pretty trivial for most of the

 

  8   drugs on the market.

 

  9             So, I think the answer to your problem is

 

 10   I am telling you that we should look at exposure

 

 11   ranging.  I would expect that you would only

 

 12   approve a drug, assuming the drug has minimal

 

 13   toxicity, as these topical agents do, that you

 

 14   would approve the drug at the dose or exposure of

 

 15   the drug that produces the drug's maximum effect.

 

 16             As a consumer, that is what I would think

 

 17   when I was standing in the drugstore.  If you do

 

 18   that, then, you are not in this position of this

 

 19   rush to the bottom, because I think that is a very

 

 20   dangerous step to get into.

 

 21             DR. CANTILENA:  But how about if the drug

 

 22   overall is not very effective, it has just barely

 

                                                               388

 

  1   beaten placebo?

 

  2             DR. WOOD:  Well, if the drug overall is

 

  3   not very effective, I think we should tell people

 

  4   what the efficacy is, and I think if you are

 

  5   standing in the drugstore and you have got three

 

  6   packets in front of you, and one says this is 20

 

  7   percent effective, one says this is 60 percent

 

  8   effective, and one says it is something else, let

 

  9   people choose.

 

 10             I mean if they like the prettier packet

 

 11   that's 20 percent effective or maybe it will be

 

 12   cheaper.

 

 13             DR. CANTILENA:  Dr. Epps.

 

 14             DR. EPPS:  Brief comments.  Certainly when

 

 15   there is a discussion about the movement to

 

 16   decrease the duration, certainly, if we were

 

 17   talking about antibiotics, we would be certainly

 

 18   concerned about resistance.  Does it apply to

 

 19   antifungals?  I don't know.

 

 20             Although tinea pedis may not be life or

 

 21   death, certainly, there are quality of life issues.

 

 22   I have patients who can't walk, they can't go to

 

                                                               389

 

  1   work, they can't go to school because it is so

 

  2   severe.  So, I certainly don't think it is trivial,

 

  3   but it is certainly not fatal and certainly, to

 

  4   piggyback on what Ms. Knudson said, I think if we

 

  5   are going to move to approve drugs or have

 

  6   antifungals approved, they should work.

 

  7             Certainly, whether it's $8.00 or $15.00,

 

  8   or whatever the co-pay is, there should be some

 

  9   reasonable expectation that they are going to

 

 10   benefit from it.

 

 11             DR. CANTILENA:  Thank you.

 

 12             I think what I would like to do is for

 

 13   anyone who has not expressed their opinion on this,

 

 14   I will give you an opportunity yet to do so, but I

 

 15   think we have heard from probably 90 percent, which

 

 16   is clinically significant, I believe, by anyone's

 

 17   definition.

 

 18             Is there anyone else who would like to add

 

 19   to the discussion?

 

 20             DR. TEN HAVE:  Could we hear from the

 

 21   consumer representatives on what the consumers

 

 22   would think?

 

                                                               390

 

  1             DR. CANTILENA:  Good.  We have Dr. Patten

 

  2   and Ms. Knudson.

 

  3             MS. KNUDSON:  I have an unrealistic

 

  4   expectation that we should have 100 percent

 

  5   effectiveness on anything that is on a shelf.  I

 

  6   realize that is unrealistic.  However, I do want to

 

  7   see some comparisons between anything that is on

 

  8   the shelf as to what the effectiveness rate is for

 

  9   most people.

 

 10             DR. CANTILENA:  Are you able to do that in

 

 11   terms of the current regulations, can you put

 

 12   efficacy rates, comparison to like other things

 

 13   that are generic?

 

 14             DR. GANLEY:  You wouldn't necessarily

 

 15   compare something else.  You could be able to put

 

 16   in cure rates or efficacy rates.  The company who

 

 17   does want to do two comparative studies, comparing

 

 18   it to another regimen of another drug, and show

 

 19   that they are better than them, they could achieve

 

 20   labeling by doing that.

 

 21             I think that we would have to talk about

 

 22   it internally, there is some difficulties, because

 

                                                               391

 

  1   we don't have, particularly for the monograph

 

  2   products, we don't have the consistent types of

 

  3   efficacy endpoints that we have for the NDA

 

  4   products, at least the most recent approvals.

 

  5             DR. TEN HAVE:  Then, how can you set a

 

  6   standard?

 

  7             DR. GANLEY:  We would have to go back and

 

  8   look at the data that was collected.  Nothing is

 

  9   perfect here.

 

 10             DR. TEN HAVE:  In terms of defining the

 

 11   minimum rate, if the efficacy definitions differ

 

 12   across studies--

 

 13             DR. GANLEY:  Well, that is the potential

 

 14   down side, and that goes back to what Dr. Fritsch

 

 15   had said, is that in some of these studies, they

 

 16   may have included patients with onychomycosis, for

 

 17   example, which may lead to a lower efficacy rate.

 

 18             So, it is like comparing apples and

 

 19   oranges in some cases.  But it may be that you

 

 20   create categories of efficacy or something, I don't

 

 21   know, I think we would have to talk about it.

 

 22             DR. TEN HAVE:  So, is the implication,

 

                                                               392

 

  1   though, that we need different thresholds,

 

  2   different minimum acceptable thresholds for

 

  3   different categories for these different

 

  4   definitions?

 

  5             DR. GANLEY:  No, I don't think so, but I

 

  6   think that it is what we do with the products we

 

  7   have now and what we decide we are going to do for

 

  8   the future, so I think that is where we have to

 

  9   really start from, and then set the standard of

 

 10   what we would like to do for the future and see

 

 11   what we can do for the other products that are on

 

 12   the market right now.

 

 13             Nothing is going to be perfect here,

 

 14   because of that.

 

 15             DR. CANTILENA:  I think we also want to

 

 16   hear from Dr. Patten.

 

 17             DR. PATTEN:  I am going to agree with Dr.

 

 18   Ringel.  I would say that, at a minimum, there

 

 19   needs to be negative mycology.  If anything comes

 

 20   in without that, then, it seems to me it's an

 

 21   application for something that will manage the

 

 22   condition or decrease severity of symptoms, and the

 

                                                               393

 

  1   concept of cure would be inappropriate.

 

  2             My understanding of this is that this is

 

  3   the agent that causes the condition.  If the agent

 

  4   is still there, the condition may recur, will

 

  5   recur.

 

  6             DR. CANTILENA:  Thank you.

 

  7             Let's move to the last broad topic area,

 

  8   which has to do with the label.  Actually, I would

 

  9   like to start with the safety issue, which is

 

 10   Question 6, and then we will do Question 3, (a) and

 

 11   (b).

 

 12             I think what I heard this morning, and I

 

 13   apologize, Dr Bisno, if I didn't hear you

 

 14   correctly, but that with regard to safety, it

 

 15   really didn't seem to be a large problem, and from

 

 16   the AERS database, it doesn't show up in terms of

 

 17   cellulitis.

 

 18             So, I think what the Question 6(a)

 

 19   basically talks about subpopulations, which I would

 

 20   like to hear from everyone.  I am sure we all have

 

 21   an opinion on if there are specific subpopulations,

 

 22   because if so, then, we will sort of meld that into

 

                                                               394

 

  1   the labeling.

 

  2             I will open it up for general comments and

 

  3   talk about the risk of secondary infections, and

 

  4   then if there are any subpopulations who are at

 

  5   higher risk, and, if so, should that be in the

 

  6   label.

 

  7             Yes, Dr. Bisno.

 

  8             DR. BISNO:  If I may say, I think the

 

  9   study that needs to be done, probably should be

 

 10   done, is to look at patients who have cellulitis

 

 11   and particularly those who have recurrent

 

 12   cellulitis, and to grade them on two different

 

 13   factors.

 

 14             One is the severity of their tinea pedis,

 

 15   and the other is their coexistent comorbidities.  I

 

 16   think if that study were ever done, we would see

 

 17   that there is probably a small subsegment of people

 

 18   with severe tinea and comorbidities who are

 

 19   probably at much risk of cellulitis and that the

 

 20   general population is not.

 

 21             Lacking those data, my suggestion would

 

 22   be, what I had in my last slide, although I would

 

                                                               395

 

  1   expand it just a little, I said tinea pedis is only

 

  2   one of a number of risk factors for the development

 

  3   of lower extremity cellulitis, but it is one of the

 

  4   most modifiable of such factors.

 

  5             The committee might wish to add a caution

 

  6   about the importance of eradication of tinea pedis

 

  7   in patients with such risk factors as lymphedema,

 

  8   venous insufficiency, edema of the legs, marked

 

  9   obesity, saphenous venectomy for coronary artery

 

 10   bypass graft, or previous episodes of cellulitis.

 

 11             It might be worthwhile to add

 

 12   immunosuppression there, too, immunosuppressed

 

 13   patients, and although the data on diabetes are not

 

 14   clear-cut, I wouldn't object if you wanted to add

 

 15   diabetes, too.

 

 16             That would be my suggestion, to just have

 

 17   something on there that says that tinea pedis is a

 

 18   risk factor for cellulitis particularly in this

 

 19   group of patients, and they should take particular

 

 20   care to eradicate their condition.

 

 21             DR. CANTILENA:  Thank you.

 

 22             Other comments?  Dr. Benowitz.

 

                                                               396

 

  1             DR. BENOWITZ:  I think we need a

 

  2   clarification of what the issue is here.  One

 

  3   issue, if tinea infection predisposes to

 

  4   cellulitis, then, we should treat them.

 

  5             The question would be if you are at high

 

  6   risk of cellulitis, should you use oral instead of

 

  7   topical, because it is more effective.  I mean that

 

  8   would be one question.

 

  9             Or is there a concern that if you have

 

 10   cellulitis, you are not being treated for

 

 11   cellulitis adequately, because you think it's

 

 12   tinea, and you are being treated for that instead.

 

 13             So. those are the problems, but I am not

 

 14   sure what the intent is of special labeling.  We

 

 15   should effectively treat someone if they are

 

 16   infected, right?

 

 17             So, my question is what is the purpose of

 

 18   the special label?

 

 19             DR. BISNO:  The question that was raised

 

 20   by the committee and to me specifically is what

 

 21   recommendation I could make regarding the issue of

 

 22   cellulitis and tinea pedis, and my feeling was that

 

                                                               397

 

  1   there are certain subgroups of people who are at

 

  2   higher risk, and that it would be prudent and

 

  3   feasible to identify those.

 

  4             We are not telling anybody not to treat

 

  5   tinea pedis, but we also know tinea pedis is

 

  6   extremely common and in many cases, go untreated

 

  7   unless they are highly symptomatic.

 

  8             DR. BENOWITZ:  I understand that, but in

 

  9   terms of the labeling for a product to treat tinea,

 

 10   the question is if you have this, make sure you

 

 11   take this product?

 

 12             DR. WHITMORE:  I think this is not a

 

 13   consumer information product.  I think this is a

 

 14   physician education product, and those patients who

 

 15   do have these risk factors are being seen by a

 

 16   physician, so it actually is the responsibility of

 

 17   the physician to look for tinea pedis.

 

 18             You can bet that the majority of the

 

 19   people with those predisposing factors probably

 

 20   have fungus on their feet, too.

 

 21             DR. CANTILENA:  Dr. Alfano.

 

 22             DR. ALFANO:  I am concerned about changing

 

                                                               398

 

  1   the label for a potential effect that has occurred

 

  2   at such a low, ultra-low rate.  I mean we learned

 

  3   this morning that we are really now talking about

 

  4   hundreds of million of doses, of treatments, and we

 

  5   have 13 cases reported, and as Dr. Bisno pointed

 

  6   out this morning when he reviewed those cases, most

 

  7   of them didn't seem to him to be cellulitis in any

 

  8   case, they seemed to be allergic reactions.

 

  9             We have seen the industry propose to add

 

 10   some labeling that would encourage people to seek

 

 11   the advice of a physician if the condition worsens

 

 12   or changes in any way, which would be sort of the

 

 13   preamble to cellulitis, so there already is sort of

 

 14   a--I don't think we need a fix--but there already

 

 15   is I think a good one that has been proposed.

 

 16             I am very concerned that as we make the

 

 17   label more complicated, it becomes less

 

 18   understandable and more intimidating, and we could

 

 19   actually be discouraging people from using this

 

 20   product, and it could have the unintended effect of

 

 21   decreasing use and increasing risk.

 

 22             So, in the absence of any consumer

 

                                                               399

 

  1   comprehension studies, label comprehension studies,

 

  2   I just wouldn't go near this particular one for

 

  3   such a seemingly inconsequential risk.

 

  4             DR. CANTILENA:  Dr. Schmidt.

 

  5             DR. SCHMIDT:  We are seeing more cardiac

 

  6   surgery and we are seeing a lot more stasis

 

  7   dermatitis, and a lot more lipodermatosclerosis,

 

  8   and I think even though these cellulitises of the

 

  9   lower extremities, I don't think they are rare, and

 

 10   I think that the cases that they presented were not

 

 11   cellulitis, they were contact dermatitis, but I

 

 12   would be interested to hear from the consumer reps

 

 13   because, to me, this does sound like a good idea,

 

 14   you know, we are doing something for these people.

 

 15             A lot of these people just kind of bang

 

 16   around and then they finally come in with problems,

 

 17   and, to me, to have this on the labeling where

 

 18   someone comes in and they have a fungus, and they

 

 19   read this and they say wait a minute, I do have--I

 

 20   am wearing my support hose and I did have, you

 

 21   know, they have harvested my veins and now my legs

 

 22   are messed up, and I am going to start putting this

 

                                                               400

 

  1   on, because it is a treatment that we can do

 

  2   something about it, whereas, this other stuff, it

 

  3   just happens.

 

  4             So, I vote for this.

 

  5             DR. CANTILENA:  Dr. Wood.

 

  6             DR. WOOD:  I want to agree with what Neal

 

  7   and Dr. Alfano said.  We can bog the label down

 

  8   with so much stuff, and I don't understand the

 

  9   problem we are addressing here. There is no

 

 10   evidence that these drugs produce cellulitis. This

 

 11   is not hepatic toxicity or some side effect we are

 

 12   trying to identify and tell people to go their

 

 13   doctor about.

 

 14             These people are also at risk for having a

 

 15   heart attack.  Why don't we put in the label, you

 

 16   know, if you get chest pain, be sure to go to see

 

 17   your doctor.  These people are in danger of having

 

 18   a DVT, if you get calf pain, go and see your doctor

 

 19   and particularly if you get short of breath. I mean

 

 20   there is no end to this.

 

 21             Unless there is some association between

 

 22   the drug and some adverse outcome, and that

 

                                                               401

 

  1   informing the consumer will help prevent that

 

  2   adverse outcome, I don't think we should burden the

 

  3   label with a bunch of stuff, that I don't see that

 

  4   it helps them very much.

 

  5             Maybe I am missing something here, but I

 

  6   have not heard some reason to believe that going to

 

  7   your drugstore, buying an antifungal, it makes you

 

  8   more at risk for cellulitis than you were five

 

  9   minutes before you did that.

 

 10             DR. CANTILENA:  It is just the

 

 11   complications if it is unsuccessfully treated, and

 

 12   I think that is what we don't know.

 

 13             Dr. Davidoff.

 

 14             DR. DAVIDOFF:  I understand the kind of

 

 15   concerns that Alastair and others have had about

 

 16   unduly complicating things.  The problem I have is

 

 17   not so much the concern of whether or not the drug

 

 18   is causing the infection, and so on, which it

 

 19   clearly isn't, the problem I have is that patients

 

 20   who are not clear whether they have a beginning

 

 21   cellulitis or tinea pedis, and if they have decided

 

 22   that it's tinea pedis and start treating it, when,

 

                                                               402

 

  1   in fact, it really was cellulitis, and the continue

 

  2   treating it because they think if I wait 7 days or

 

  3   4 weeks, or whatever, I am going to be okay, those

 

  4   are the people I am concerned about.

 

  5             So, I think that the notion of adding some

 

  6   wording about if the condition worsens or if

 

  7   irritation occurs, and so on, it is more than

 

  8   reasonable, because of the issue of difficulty in

 

  9   people's minds in distinguishing what is going on

 

 10   in their foot, so that is my view on that

 

 11   particular subquestion.

 

 12             I had some comments on some of the other

 

 13   subquestions, too.  One of them was on this issue

 

 14   of cure rate, because it seems to me that the

 

 15   notion of adding data about cure rates for the

 

 16   different products--

 

 17             DR. CANTILENA:  Actually, that is going to

 

 18   be coming up.

 

 19             DR. DAVIDOFF:  I am sorry, okay, I will

 

 20   save it.

 

 21             DR. CANTILENA:  Dr Bisno.

 

 22             DR. BISNO:  I would like to say, first of

 

                                                               403

 

  1   all, that I am not advocating for this change.  I

 

  2   was asked to make a suggestion for the committee as

 

  3   what could be done about this very difficult and

 

  4   complex issue on which there is not a lot of data,

 

  5   and this was the best suggestion I could come up

 

  6   with.  I am not advocating it one way or another.

 

  7             But I would disagree, Dr. Wood, with your

 

  8   analysis or your comparison with other kinds of

 

  9   illnesses, because these are illnesses that are

 

 10   distinct risks for these cases of cellulitis, and

 

 11   some of these cases are severe and, at times, even

 

 12   life-threatening, and they are directly related, at

 

 13   least in part, not in total, but in part to the

 

 14   tinea pedis.

 

 15             What is missing is we don't have

 

 16   tremendous great data to indicate--you said topical

 

 17   or oral--we don't have tremendous data to indicate

 

 18   that either of those would be actually effective in

 

 19   preventing it.  It is only an assumption that if we

 

 20   are treating with something that is effective

 

 21   against the t. pedis, that we are going to

 

 22   therefore not be having a nidus for the bacteria,

 

                                                               404

 

  1   and therefore we won't have the cellulitis, but

 

  2   that is a lot of speculation based on no firm data.

 

  3             So, anyway, just to conclude, I am not

 

  4   advocating one way or another, I was asked to

 

  5   suggest what could possibly be said about this, and

 

  6   this is the best I could come up with.

 

  7             DR. CANTILENA:  We will have a comment

 

  8   here from FDA, and then we will actually go around

 

  9   the table with the vote.

 

 10             DR. WILKIN:  One of the things we learn in

 

 11   advisory committees is how to construct questions

 

 12   better.  I think this has been expanded in a very

 

 13   useful way.  I mean I think we have heard about

 

 14   some other areas other than what our original

 

 15   intent was, but I thought I would just share with

 

 16   you what the original intent was.

 

 17             We did think that it would be helpful to

 

 18   have Dr. Bisno's experience given his writings in

 

 19   the literature, and, in part, we saw this paper by

 

 20   Morton Schwartz, Cellulitis.  It is the Clinical

 

 21   Practice section in the New England Journal of

 

 22   Medicine.

 

                                                               405

 

  1             He goes on to say the things to do in the

 

  2   management.  You can imagine that the large part is

 

  3   devoted to antimicrobial therapy, but then when you

 

  4   get down under Ancillary Measures, he talks about

 

  5   the local care.

 

  6             The second sentence is, "Interdigital

 

  7   dermatophytic infections should be treated with a

 

  8   topical antifungal agent until they have been

 

  9   cleared.  Such lesions may provide ingress for

 

 10   infecting bacteria"--and then he goes on.

 

 11   "Observational data suggest that after the

 

 12   successful treatment of such dermatophytic

 

 13   infections, the subsequent prompt use of topical

 

 14   antifungal agents at the earliest evidence of

 

 15   recurrence or prophylaxis application once or twice

 

 16   per week will reduce the risk of recurrences of

 

 17   cellulitis."

 

 18             That was the genesis of the question.

 

 19             DR. CANTILENA:  Would you have any

 

 20   objection if we slightly modify this to say, "Would

 

 21   you recommend that the current labeling be modified

 

 22   for subpopulations at risk for secondary

 

                                                               406

 

  1   infections, yes or no, and if yes, which ones would

 

  2   you highlight?"  Is that acceptable to you?  Okay.

 

  3             Is it a burning question, Dr. Benowitz?

 

  4             DR. BENOWITZ:  Yes, because there is still

 

  5   two things that are totally different that I don't

 

  6   understand what we are labeling.

 

  7             One is a misdiagnosis question, so make

 

  8   sure that you don't have cellulitis before you take

 

  9   this stuff and it gets worse, and the second thing

 

 10   is if you have a predisposition to this, you should

 

 11   be treated more promptly. I don't see how either

 

 12   one is really relevant to the label, or the first

 

 13   one might be to diagnosis, but I still don't

 

 14   understand what you really want out of the label.

 

 15             DR. CANTILENA:  In that case, then, your

 

 16   answer would be no, because of those reasons, but

 

 17   if you have subpopulations, if you are concerned

 

 18   about the diabetics, for example, who would use the

 

 19   product, and it would fail for them, they would

 

 20   have a secondary infection that they still think is

 

 21   the slowly healing fungus, then, that is another

 

 22   issue.

 

                                                               407

 

  1             DR. BENOWITZ:  I guess I just need to know

 

  2   what specific label are you talking about, is it a

 

  3   diagnosis label or is it a treatment label?  I just

 

  4   don't understand what the label would be.

 

  5             DR. BISNO:  Are you addressing that to me?

 

  6   The first issue that you raised was, let's see, it

 

  7   has nothing to do with if you have cellulitis, you

 

  8   should do something. That is not relevant.

 

  9             The second issue is maybe it's not an

 

 10   appropriate place to put on a label, I am not

 

 11   saying it is, I am saying this is the best I can

 

 12   come up with if you want to give a caution to

 

 13   patients as part of the label as to what people are

 

 14   at particular risk of getting cellulitis related to

 

 15   t. pedis, and it may or may not be an appropriate

 

 16   thing to go on a label, that is for the committee

 

 17   to decide.

 

 18             DR. CANTILENA:  Would you like to vote yes

 

 19   or no on should we modify the label for

 

 20   subpopulations at risk for secondary infections

 

 21   like cellulitis?  That would be a yes/no.

 

 22             DR. GANLEY:  Lou, I would just interject

 

                                                               408

 

  1   here.  I think it is probably better just to get

 

  2   comments from people, because there is a lot of

 

  3   caveats that have been thrown into this, and I

 

  4   think we can try to sort it out.

 

  5             There is numerous ways to do things.

 

  6   Clearly, if we thought, for example, that people

 

  7   with lymphedema or venous insufficiency shouldn't

 

  8   even be starting a therapy on their own, you could

 

  9   include something in the label, such as ask a

 

 10   doctor before use if you have these conditions.

 

 11             If there is no data here to support that,

 

 12   then, your answer would be no.  Or you could decide

 

 13   that maybe we should put some package insert in

 

 14   there and include some information on some

 

 15   conditions that if you are not getting better, you

 

 16   should get better in this period of time, if you

 

 17   are not getting better, you should see a doctor

 

 18   immediately if you have these underlying

 

 19   conditions, and I think that is what Dr. Bisno was

 

 20   getting at.

 

 21             I think there is a lot of ways to do it,

 

 22   and I think it is probably more fruitful to have

 

                                                               409

 

  1   just a discussion as what people's biases are.

 

  2             DR. CANTILENA:  Okay.

 

  3             DR. BISNO:  Let me just say that one thing

 

  4   we wouldn't want to do is say go to your doctor

 

  5   before starting to treat this.  I mean we don't

 

  6   want to discourage people with these risk factors

 

  7   from starting self-treatment.

 

  8             DR. WOOD:   But you want to encourage them

 

  9   surely.

 

 10             DR. GANLEY:  I think it comes out more in

 

 11   a discussion than in a vote.

 

 12             DR. CANTILENA:  How about if we just start

 

 13   over here, just go around the table and comment on

 

 14   your thoughts on this.

 

 15             We will start over here.  Ms. Knudson.

 

 16             MS. KNUDSON:  It seems to me that if

 

 17   diabetics are at higher risk for secondary

 

 18   infection or those who are immunocompromised, and

 

 19   certainly AIDS patients must get tinea pedis in

 

 20   great numbers, but I would like to see something in

 

 21   the label that indicates that if you have these

 

 22   conditions and you are not responding to the drug,

 

                                                               410

 

  1   please see your physician or we recommend that you

 

  2   see your physician.

 

  3             DR. CANTILENA:  Dr. Benowitz.

 

  4             DR. BENOWITZ:  I would certainly agree

 

  5   with that as a label, and I think what the

 

  6   manufacturers suggested seemed like a reasonable

 

  7   label.  If you want to do just extra education

 

  8   about people at risk of cellulitis, if there is

 

  9   room on the label, that's fine.

 

 10             DR. CANTILENA:  Dr. Clapp.

 

 11             DR. CLAPP:  It seems like the addition of

 

 12   a cautionary note on the outside of the box, that

 

 13   states if this is not getting better or gets worse,

 

 14   and give a specific time frame, that could be a

 

 15   clear general warning to anyone, and therefore give

 

 16   information that would make people stop and take

 

 17   note without giving a tedious list that might not

 

 18   be all-encompassing of the types of people who are

 

 19   at increased risk for problems secondary to

 

 20   cellulitis following or associated with the tinea

 

 21   pedis infection.

 

 22             DR. CANTILENA:  Thank you.

 

                                                               411

 

  1             Dr. Epps.

 

  2             DR. EPPS:  Perhaps on both ends, one, you

 

  3   could say for uncomplicated cases of, you know,

 

  4   tinea pedis, interdigital, that sort of thing, and

 

  5   then follow with a sentence about if you X, Y, Z

 

  6   conditions, you consider asking your doctor about

 

  7   use.

 

  8             DR. CANTILENA:  Dr. Raimer.

 

  9             DR. RAIMER:  Logically, it does seem like

 

 10   people with lymphedema and obesity, and that sort

 

 11   of thing, certainly would have a higher risk of

 

 12   getting cellulitis if they did have a nidus or

 

 13   infection, so it seems logically like a reasonable

 

 14   thing to do, but I don't know if we should actually

 

 15   label, put things in labels when we don't have any

 

 16   scientific proof at this point in time.

 

 17             So, I would like to see it done just

 

 18   because my opinion is that it is kind of logical

 

 19   that it would happen, but maybe it's too early,

 

 20   maybe we shouldn't do it without any real proof

 

 21   that it is happening.

 

 22             DR. CANTILENA:  Thank you.

 

                                                               412

 

  1             Dr. Wilkerson.

 

  2             DR. WILKERSON:  I like the labeling that

 

  3   Novartis came up with.  I think this is reasonable

 

  4   for consumer packaging.  I think if you put too

 

  5   many things in there, list all these conditions, it

 

  6   just causes confusion.

 

  7             I agree with Dr. Raimer.  Teleologically,

 

  8   we believe that we are right about treating tinea

 

  9   pedis, but as far as I know, no one has done a

 

 10   large-scale study to show that if you put the stuff

 

 11   on once a day, twice a week, whatever, that we

 

 12   actually affect the outcome that we think we are

 

 13   going to affect here.

 

 14             I think keep it simple, and their wording

 

 15   seems very good to me.

 

 16             DR. CANTILENA:  Dr. Patten.

 

 17             DR. PATTEN:  I would support indicating on

 

 18   the label if condition does not improve, condition

 

 19   worsens, or new symptoms develop, see your doctor.

 

 20   I would not support naming specific conditions.

 

 21             If there is evidence to support increased

 

 22   risk of any kind coming from these conditions,

 

                                                               413

 

  1   then, perhaps in insert, but not on the label.

 

  2             DR. CANTILENA:  Dr. Lam.

 

  3             DR. LAM:  I definitely agree with what Dr.

 

  4   Patten said, to make it simple.

 

  5             DR. CANTILENA:  Dr. Ringel.

 

  6             DR. RINGEL:  I would recommend putting a

 

  7   caution on the outside of the box, but simply have

 

  8   it refer to the medication guide inside the box, in

 

  9   other words, to say, you know, please see Caution

 

 10   Section of package insert or whatever, and then in

 

 11   the medication guide, then, have a discussion of

 

 12   specific issues.

 

 13             I would think things on the label should

 

 14   have more to do with whether a person would buy the

 

 15   product or not, does he need to know that

 

 16   information at the time of purchase or does he not.

 

 17   I would say no, you don't need it at the time of

 

 18   purchase, you need to know it as you are using it.

 

 19             So, I think it could go inside on the

 

 20   medication guide.

 

 21             There is another issue that perhaps should

 

 22   be addressed, as well, having to do with diabetes,

 

                                                               414

 

  1   not only as a risk factor possibly for cellulitis,

 

  2   but also in terms of poor wound healing.  People

 

  3   with diabetes and peripheral vascular disease get

 

  4   ulcers on their feet if they are scratching at them

 

  5   all the time.

 

  6             There are a number of issues that may come

 

  7   up that you might want to reference, and you can't

 

  8   possibly put all of that on the package.

 

  9             DR. CANTILENA:  Dr. Fincham.

 

 10             DR. FINCHAM:  I would vote to have the

 

 11   packaging be as inclusive as possible, and

 

 12   specifically because we are looking at a

 

 13   self-diagnosis in many cases and relying on the

 

 14   patient to make a decision without input from a

 

 15   health professional, so I think it needs to be

 

 16   inclusive.

 

 17             I don't see this as any different than

 

 18   some of the things that are on pseudoephedrine

 

 19   labeling relative to hyperthyroidism, hypertension,

 

 20   prostate disorders, et cetera.  I think the more

 

 21   inclusive you can be, you just give consumers a

 

 22   better chance to be better informed.

 

                                                               415

 

  1             DR. CANTILENA:  Dr. Whitmore.

 

  2             DR. WHITMORE:  I think the proposed

 

  3   packaging with back label information on the box by

 

  4   Novartis is good, and I think that is adequate.

 

  5             DR. CANTILENA:  Dr. Davidoff.

 

  6             DR. DAVIDOFF:  I would tend to the more

 

  7   conservative side, that is, trying to avoid

 

  8   overcrowding an already crowded label, on top of

 

  9   which I think it would kind of lead to endless

 

 10   discussions about what conditions should be and

 

 11   what shouldn't be on that complicating list.

 

 12             I do like the notion of including

 

 13   information about those conditions or whatever

 

 14   subset in the package insert, however.

 

 15             DR. CANTILENA:  Dr. Schmidt.

 

 16             DR. SCHMIDT:  I agree with Dr. Raimer and

 

 17   Dr. Davidoff.  I think it sounds good, that it

 

 18   makes sense to be inclusive with some of these

 

 19   things, but it is going to crowd this package

 

 20   insert, and until we really know just how many

 

 21   times we have, you know, these cellulitises, I

 

 22   think it probably is best left out.

 

                                                               416

 

  1             I agree, I think that the package insert

 

  2   that Novartis, they have pretty well covered

 

  3   everything.

 

  4             DR. CANTILENA:  Dr. Katz.

 

  5             DR. KATZ:  I would say no to the

 

  6   overinclusive listing of each subpopulation, and

 

  7   just a general comment if you don't get better, see

 

  8   your doctor, which I assume is on all the other

 

  9   over-the-counter things, so one sentence would be

 

 10   fine without listing all of the other

 

 11   subpopulations.

 

 12             DR. CANTILENA:  Dr. Ghannoum.

 

 13             DR. GHANNOUM:  I think make it simple, and

 

 14   I agree with the other members that just provide

 

 15   information as mentioned by Novartis.

 

 16             DR. CANTILENA:  Dr. Bisno.

 

 17             DR. BISNO:  I think after listening to the

 

 18   discussion, I would agree that this is probably

 

 19   inappropriate to put on the package label, and

 

 20   don't think it should be put on.

 

 21             If there is a decision to add such a

 

 22   caution anywhere else, on the box or anywhere else,

 

                                                               417

 

  1   I would advocate that the conditions that I

 

  2   mentioned in my slide be put on, because they are

 

  3   established risk factors, and I would diabetes on

 

  4   general grounds and also immunosuppression, which

 

  5   is also an established risk factor, if there is a

 

  6   decision to do that, but I would certain agree that

 

  7   it doesn't belong on the package labeling.

 

  8             DR. CANTILENA:  Dr. Wood.

 

  9             DR. WOOD:  I agree with what was just said

 

 10   about presumably, every over-the-counter product

 

 11   should probably have some disclaimer that says if

 

 12   you are not getting better or you are getting

 

 13   worse, see your doctor.

 

 14             I am comfortable with putting lists on the

 

 15   label that are actually lists of things that should

 

 16   encourage you to take the drug rather than lists of

 

 17   things that can go wrong when you take the drug,

 

 18   and these are very different issues.  I think most

 

 19   consumers would interpret a list on the label as

 

 20   something that should encourage them to avoid

 

 21   taking the drug rather than the other way around.

 

 22             In fact, in Dr. Bisno's risk factors, it

 

                                                               418

 

  1   would seem to me to be indications for rushing out

 

  2   today and buying these drugs, and the idea that

 

  3   consumers will read this label and be discouraged

 

  4   from taking it seems to me a major public health

 

  5   hazard actually.

 

  6             DR. CANTILENA:  Thank you.

 

  7             Dr. Ten Have.

 

  8             DR. TEN HAVE:  Support a simple general

 

  9   statement, cautionary statement.

 

 10             DR. CANTILENA:  Dr. Alfano.

 

 11             DR. ALFANO:  Same comment I made earlier,

 

 12   simple statement as has been propose by both

 

 13   Novartis and CHPA, essentially, the same statement.

 

 14             DR. CANTILENA:  Thank you.

 

 15             Mr. Kresel.

 

 16             MR. KRESEL:  I support a simple statement.

 

 17   I think the first rule of label writing is keep it

 

 18   simple.  People don't read beyond that, or they

 

 19   just get so confused they give up.

 

 20             DR. CANTILENA:  I would agree with

 

 21   generally what has been said, that we should not

 

 22   add specifics at this point until we have the data

 

                                                               419

 

  1   to support that, but we do need to strengthen the

 

  2   other warnings, which have already been talked

 

  3   about, and I would support those changes.

 

  4             Okay. I think we have all talked about the

 

  5   shortcomings of the existing label, so I am

 

  6   confident that this group can go right to 3(b), are

 

  7   there claims on the current labeling that may

 

  8   mislead consumers to have greater expectations.

 

  9             We can start here and we will do an actual

 

 10   yes or no on this.  If there are claims, then, if

 

 11   you would specify which ones trouble you the most

 

 12   about misleading consumers.

 

 13             Tab 7, Table 2 tells you the choices for

 

 14   the monograph, and Table 3 has some samples of

 

 15   information from some of the OTC NDA drugs.  We had

 

 16   sort of touched on these earlier today.

 

 17             Some people have significant trouble with

 

 18   some of the wording and whatnot, and the qualifiers

 

 19   or lack thereof, so I think maybe we can just say

 

 20   whether or not you do have a problem with the

 

 21   existing label in terms of it being misleading to

 

 22   consumers, and if you do, which are the things that

 

                                                               420

 

  1   trouble you the most.

 

  2             Go ahead, Mr. Kresel.

 

  3             MR. KRESEL:  I think the one that we have

 

  4   talked about the most is "cures most," which I

 

  5   don't think anybody really had any understanding of

 

  6   anyway, it doesn't seem to have any meaning, so it

 

  7   ought to go away.  I think "cures most" being

 

  8   replaced with "treats" makes a lot of sense to me.

 

  9             DR. CANTILENA:  Dr. Alfano.

 

 10             DR. ALFANO:  I think back to what Dr. Bull

 

 11   said, what is clinically meaningful to the

 

 12   consumer, and if you think of the data that was

 

 13   presented by Schering-Plough, most consumers buy

 

 14   these products for sort of symptomatic relief, they

 

 15   are not treating hyperkeratosis.

 

 16             So, under that basis, just to clear up the

 

 17   issue on cures, I would agree that "treats" would

 

 18   be a better word as proposed by Novartis.

 

 19             DR. CANTILENA:  Dr. Ten Have.

 

 20             DR. TEN HAVE:  I agree that "treats" is

 

 21   better.

 

 22             DR. CANTILENA:  How about in terms of the

 

                                                               421

 

  1   other items in the current OTC labeling?  Let me

 

  2   find a good example of that.  Attachment 2?

 

  3             DR. FINCHAM:  It is Tab 7, Attachment 2,

 

  4   not Table 2.

 

  5             DR. CANTILENA:  Attachment 2 in Tab 7.

 

  6   Yes, we are going to go all the way around.

 

  7             Dr. Wood.  I think I know what your most

 

  8   important concern is.

 

  9             DR. WOOD:  My biggest concern is most, but

 

 10   seriously, I think there are other questions that

 

 11   are in here that we should address, on page 6, for

 

 12   example, that are specifically addressed, at least

 

 13   I imagine are specifically addressed to the

 

 14   committee.

 

 15             I like the idea on page 5 of including

 

 16   specific efficacy data, which would not have to

 

 17   rely on comparative studies.  Does that make sense?

 

 18   So, the data that came from the studies, if that

 

 19   exists; if it doesn't exist, then, tough luck.  I

 

 20   mean if it doesn't exist, you don't get to put

 

 21   anything on, and people should draw their own

 

 22   conclusions from that.  Maybe you should say there

 

                                                               422

 

  1   are no data to say how effective this is, if that

 

  2   is what it is, and if the other products that says

 

  3   it is X percent effective--

 

  4             DR. CANTILENA:  I think perhaps you are

 

  5   crossing over into 3(a) with additions.  I am

 

  6   actually sort of looking for problems that you have

 

  7   with the current label.

 

  8             DR. WOOD:  Then, I will pass.

 

  9             DR. CANTILENA:  We will have an

 

 10   opportunity to come back to all the items that we

 

 11   would like to add.

 

 12             Dr. Bisno.

 

 13             DR. BISNO:  I don't have any comment.

 

 14             DR. CANTILENA:  Dr. Ghannoum.

 

 15             DR. GHANNOUM:  I agree "treat" is better.

 

 16             DR. CANTILENA:  Dr. Katz, any problems

 

 17   with the current label?

 

 18             DR. KATZ:  There is a lot of problems here

 

 19   because as Dr. Wood said initially, "cures most,"

 

 20   it clearly doesn't cure most, so that is wrong, it

 

 21   is deceptive.  It is not even effective in most, so

 

 22   using that word is very deceptive.  The effective

 

                                                               423

 

  1   treatment in Dr. Fritsch's discussion on page 8,

 

  2   Table 16, even effective treatment, if you subtract

 

  3   the effective improvement from the placebo, in none

 

  4   of them does it even reach 50 percent.  That is not

 

  5   considering cure, it is just effective.

 

  6             So, using that word, I agree with Dr. Wood

 

  7   adamantly that that is deceptive.  Even treating

 

  8   most, what does that mean, "treating most?"  I

 

  9   don't understand that.  If I am a consumer and I go

 

 10   to the store, and I see it "treats most," what does

 

 11   that mean, that it helps most?  So, that is another

 

 12   word that shouldn't be there.

 

 13             The most clear-cut situation would be

 

 14   clear symptoms in whatever the number that the FDA

 

 15   and company agree upon improves symptoms in 48

 

 16   percent of patients, or if you take a few studies,

 

 17   in anywhere between 35 and 48 percent of patients.

 

 18   That means something.  Most consumers know what

 

 19   that percentage means.

 

 20             So, I would be very specific with that

 

 21   without getting too tedious, and that should be for

 

 22   each drug.

 

                                                               424

 

  1             That's all the comments I had.

 

  2             DR. CANTILENA:  Dr. Schmidt.  Problems

 

  3   with the existing label.

 

  4             DR. SCHMIDT:  I agree. I think put "treats

 

  5   athlete's foot," and then I agree with Dr. Wood

 

  6   that there should be some percentage, if it's

 

  7   available.

 

  8             DR. CANTILENA:  Dr. Davidoff.

 

  9             DR. DAVIDOFF:  I also have a concern with

 

 10   the "cures most," phrasing, but for a somewhat

 

 11   different reason. It seemed to me that we have been

 

 12   looking at this from a rather narrow point of view,

 

 13   namely, sort of a bug in the skin, and it seems to

 

 14   me that the actual situation is more complicated

 

 15   than that in the sense that there is bugs in the

 

 16   skin and in the surrounding environment, and that

 

 17   unless you take that ecological view, it's I think

 

 18   not fair to be talking about cure, because unless

 

 19   you treat all parts of the situation, you are not

 

 20   really dealing with the whole situation.

 

 21             It would be a little bit like talking

 

 22   about preventing surgical infections because you

 

                                                               425

 

  1   have given pre-op antibiotics, but surgeons don't

 

  2   have to wash their hands.  I mean the ecological

 

  3   view would include the surgeons' hands.

 

  4             So, having said that, I think it is also

 

  5   fair to say that the word "cure" is appropriate for

 

  6   many patients. The organism is eliminated, the

 

  7   symptoms either disappear or get much better, and

 

  8   what is residual may not be related to the

 

  9   infection.  So, I think "cure" actually is not an

 

 10   unreasonable term.

 

 11             So, putting that all together, it seems to

 

 12   me that the word "cure" might be appropriately

 

 13   retained, that the word "most" should go, agree,

 

 14   but I think there are other words that could be

 

 15   used, for example, I know you may not want to get

 

 16   into wordsmithing, but even saying "cures many"

 

 17   would be not be unreasonable.  That is not I think

 

 18   false advertising.

 

 19             Finally, if you take the ecological point

 

 20   of view, you might want to include a word like

 

 21   "helps," so "helps cure many tinea pedis

 

 22   infections" might be useful in the same sense that

 

                                                               426

 

  1   fluoride in toothpaste, the claim for it is

 

  2   included in the context, you know, the ADA's

 

  3   statement about fluoride is that fluoride helps

 

  4   prevent cavities as part of a program.

 

  5             I wondered if from the dermatologists'

 

  6   point of view, having a word like "helps" might be

 

  7   useful in the sense that it would allow or

 

  8   encourage patients to at least find out what else

 

  9   they could be doing like the other things that

 

 10   dermatologists do talk to their patients about,

 

 11   like how they should deal with their socks and

 

 12   shoes and their shower, their avoidance of swimming

 

 13   pools, or whatever else.

 

 14             So, I would summarize it by suggesting

 

 15   that "helps cure many" might be the way to go.

 

 16             DR. CANTILENA:  Dr. Whitmore.

 

 17             DR. WHITMORE:  I agree with what has been

 

 18   said about the current labeling and then if I could

 

 19   say something about the proposed label.  On the

 

 20   front of the Lamisil box, they talk about

 

 21   "eliminating fungal infection," and I would not say

 

 22   that, I would say "treat fungal infection."  The

 

                                                               427

 

  1   same is true for the Desenex.

 

  2             DR. CANTILENA:  We will talk about the

 

  3   additions that you would like in the next question,

 

  4   but thank you.

 

  5             Dr. Fincham.

 

  6             DR. FINCHAM:  I have troubles with the

 

  7   wording of "cures" and "most," and an appropriate

 

  8   replacement needs to be made.  One of the problems

 

  9   with advisory committees is they give you advice,

 

 10   and I appreciate your patience listening to us

 

 11   today.

 

 12             DR. CANTILENA:  Dr. Ringel.

 

 13             DR. RINGEL:  I think that the label should

 

 14   reflect exactly what the product does, and I think

 

 15   what this product does is that it kills athlete's

 

 16   foot fungus, and I think that the label should say

 

 17   "kills most athlete's foot fungus."  If, then, the

 

 18   symptoms don't go away, the person should have

 

 19   assumed that either he has persistent inflammation

 

 20   or some other disease that is not athlete's foot,

 

 21   or perhaps a resistant organism, but that is as

 

 22   honest as I can think of, it kills athlete's foot

 

                                                               428

 

  1   fungus.

 

  2             DR. CANTILENA:  Dr. Lam.

 

  3             DR. LAM:  I actually think that the word

 

  4   "most" should go just because it's misleading, and

 

  5   leave out "cure athlete's foot."  To me, the

 

  6   consumer will actually think that it takes care of

 

  7   the problem, and when you look at the response

 

  8   rate, it doesn't.

 

  9             So, I think it should just state what it

 

 10   is supposed to be used for, which is treatment of

 

 11   athlete's foot, and that, in a sense, make an

 

 12   implication that there is not guarantee that it

 

 13   will take care of that condition in every single

 

 14   patient.

 

 15             DR. CANTILENA:  Dr. Patten.

 

 16             DR. PATTEN:  Certainly, the word "most"

 

 17   should go, and I even wonder about the word

 

 18   "treatment."  I wonder if, in the general usage of

 

 19   that word, or the way it is conceptualized,

 

 20   treatment does not imply the goal of cure.

 

 21             I just raise that question. I am operating

 

 22   on the assumption that it does, so I would favor

 

                                                               429

 

  1   information that tells people that it improves

 

  2   symptoms or alleviates symptoms, or something like

 

  3   this.

 

  4             Also, I am looking farther back in this

 

  5   Section 7, and I am seeing some samples on

 

  6   prescription drug labels, and I am seeing the word

 

  7   dermatologic and dermal crop up several places, and

 

  8   I think when that is for consumption of the

 

  9   purchasing public, the word "skin" should be used

 

 10   rather than dermal or dermatologic.

 

 11             DR. CANTILENA:  Thank you.

 

 12             Dr. Wilkerson.

 

 13             DR. WILKERSON:  The only thing I have to

 

 14   add, I have seen on some packaging, there is a

 

 15   warning on there to the effect of do not use on

 

 16   nails, and I don't see that in any of our

 

 17   materials. I just wondered if Dr. Ganley could--I

 

 18   mean many times we don't want to treat patients

 

 19   with systemic antifungals, and we tell them to go

 

 20   get something, and they read this warning on the

 

 21   box not to use this on their nails, thinking that

 

 22   some harm is going to come to them outside of the

 

                                                               430

 

  1   fact that it may not work.

 

  2             Dr. Ganley, I was wondering, it is not in

 

  3   our materials, but I know it is on consumer items,

 

  4   I have seen it in the last few weeks.  Maybe it is

 

  5   in there.

 

  6             DR. CANTILENA:  Dr. Ganley, do you know?

 

  7             DR. GANLEY:  Yes, I am looking on page 18

 

  8   of Tab 7.  Do not use on nails or scalp.

 

  9             DR. WILKERSON:  A lot of people interpret

 

 10   that to mean that--I mean is this the standard

 

 11   wording every time, or are there variations on this

 

 12   wording?

 

 13             DR. CANTILENA:  This is for the NDA

 

 14   version, right?

 

 15             DR. GANLEY:  It's on some of the products,

 

 16   I believe, not all of them.

 

 17             DR. WILKERSON:  Would there be other

 

 18   wording that would actually warn against using it

 

 19   on hair or nails?

 

 20             DR. GANLEY:  I think the point would be is

 

 21   whether this would be effective in treating a nail

 

 22   infection like onychomycosis, and it may be that it

 

                                                               431

 

  1   may have to be stated differently, but I think it

 

  2   is a point well taken.

 

  3             DR. WHITMORE:  I think it might be helpful

 

  4   to say do not use to treat infection of the scalp

 

  5   or nails, because patients will come in and say I

 

  6   got some on my nails, am I going to die.

 

  7             DR. CANTILENA:  So, you have a problem

 

  8   with that in the NDA version.

 

  9             Dr. Raimer.

 

 10             DR. RAIMER:  I don't really have much to

 

 11   add either.  I don't like the most cures obviously,

 

 12   as everyone else has stated, but what we should

 

 13   replace it with exactly, I think we have had

 

 14   several good suggestions, I don't have any strong

 

 15   feelings about any of them.

 

 16             DR. CANTILENA:  Dr. Epps.

 

 17             DR. EPPS:  Well, if someone wanted to use

 

 18   cures, that would be a nice time to put in your

 

 19   percentage cures, or a little asterisk referring to

 

 20   the bottom, in our trials 50 percent or 20 percent

 

 21   or 60 percent or whatever, that might be helpful.

 

 22             Are we commenting on all the label or just

 

                                                               432

 

  1   that part?  I like relieves, for relief of, as

 

  2   well.

 

  3             DR. CANTILENA:  Dr. Clapp, problems with

 

  4   the existing label and what you don't like.

 

  5             DR. CLAPP:  Problems with the existing

 

  6   label certainly are "cures most," because I haven't

 

  7   seen any evidence of that.  "Most" and "cures" is a

 

  8   standard that I don't think most of them can live

 

  9   up to within the time frame that is expected.  I

 

 10   think if we take it out to 6 to 9 weeks, then, we

 

 11   see more relationship to actual cure.

 

 12             But I think that the efficacy endpoint are

 

 13   interesting, and negative mycology certainly would

 

 14   be among our standards for expectation with

 

 15   patients, but I think the patients are more

 

 16   interested in a symptomatic cure or to symptomatic

 

 17   relief, so I like the concept of effective

 

 18   treatment as being the standard for us to consider

 

 19   as opposed to actual cure, complete cure, but I

 

 20   think it could also be something that consumers

 

 21   could conceptualize better than cure, and that if

 

 22   they have a relapse or recrudescence or just

 

                                                               433

 

  1   incomplete treatment, they can say, well, it didn't

 

  2   say it was going to cure me and just didn't

 

  3   effectively treat me.

 

  4             Perhaps that is a middle ground that makes

 

  5   patients more willing to try again.

 

  6             The other things on the label that I am

 

  7   concerned about are the warnings for children,

 

  8   because I am not sure--I know that this is getting

 

  9   into a different scope, but I think we have to

 

 10   consider always reasons that we are limiting use

 

 11   for children under 2 if there is not a legitimate

 

 12   reason, or whether or not there is.

 

 13             Also, we are talking about the monograph

 

 14   labels, are we?

 

 15             DR. CANTILENA:  Actually, either one.

 

 16   There is NDA, OTC, and the monograph.

 

 17             DR. CLAPP:  Some say don't use in children

 

 18   under 2, some say use only in children over 12, and

 

 19   I think we have to have a good reason for the use

 

 20   specific to the medications that are being used.

 

 21             The other interesting thing that I find ,

 

 22   the Novartis label is interesting, the graphics are

 

                                                               434

 

  1   nice, but I am concerned about the claim that is

 

  2   must be used twice daily for full 7 days to

 

  3   eliminate fungal infection, when, in fact, on the

 

  4   indications that we have for usage was the moccasin

 

  5   type tinea pedis, is that it must be used for 2

 

  6   weeks, so there is an ambiguity here that I think

 

  7   perhaps patients are not, when they grab the box

 

  8   and read it, and if they think that they have

 

  9   tinea, and it is the moccasin type, I don't think

 

 10   they are distinguishing between moccasin versus

 

 11   intertriginous, and they would perhaps expect,

 

 12   leave with the expectation that they are fully

 

 13   cured in one week, so I think that ambiguity should

 

 14   be addressed.

 

 15             The other part that I see in some of these

 

 16   labels are where we are demanding of the patient to

 

 17   make the diagnosis of not only tinea, but

 

 18   intertriginous versus moccasin type, and I think it

 

 19   puts quite burden on the patient, and when you read

 

 20   the attached labels, some of the labels you have

 

 21   say cures between the toes, and others say but not

 

 22   on the bottom of the feet or only for use between

 

                                                               435

 

  1   the toes, and I want to make sure there is some

 

  2   consistency between the use and indication, and the

 

  3   actual reality of whether or not patients should

 

  4   then think that they should not use it if they have

 

  5   it on their feet or whether they can only use it if

 

  6   it is between the toes.

 

  7             The instructions to the patient has to be

 

  8   consistent with the type of tinea that we are

 

  9   advising them or the location of the tinea that we

 

 10   are advising that they could treat.

 

 11             Oh, and one last thing about the Novartis.

 

 12   If we are talking about the last question about

 

 13   indications or warnings for patients, many stated

 

 14   that they liked their label in terms of the

 

 15   warnings to ask a doctor if the symptoms worsen or

 

 16   new symptoms develop, but then it also has a

 

 17   precautionary note especially if you have diabetes,

 

 18   and I haven't heard that we have a clear link

 

 19   between diabetes as being worse than anything else.

 

 20   I like the caution, but not specifying diabetes and

 

 21   not listing lymphedema and CABG patients and

 

 22   everything else.

 

                                                               436

 

  1             DR. CANTILENA:  Thank you.

 

  2             Dr. Benowitz.

 

  3             DR. BENOWITZ:  For the first part, I am

 

  4   happy to say "treats athlete's foot."  One thing

 

  5   which I just noticed in this Novartis ad which is a

 

  6   problem because it's not true, although it is not a

 

  7   bad idea to encourage people, but it says, "Must be

 

  8   used to eliminate."

 

  9             According to these guidelines, to

 

 10   eliminate fungal infection, that's not true.  Most

 

 11   people don't use it according to the way it is

 

 12   supposed to be used, and in many cases, it still

 

 13   works.  I think we should encourage people, but not

 

 14   say that it must be used according to guidelines in

 

 15   order to kill fungi.

 

 16             DR. CANTILENA:  Ms. Knudson.

 

 17             MS. KNUDSON:  Well, everything I was going

 

 18   to say has been said.  I really do not like the

 

 19   word "most," I don't like the word "cure," and I am

 

 20   not crazy about the word "treatment" either.

 

 21             I like Dr. Ringel's idea about "kills

 

 22   athlete's foot fungus."  I think that is a pretty

 

                                                               437

 

  1   clear statement and there is enough information to

 

  2   back that up.

 

  3             I would also like to see something that

 

  4   says something about when you could expect your

 

  5   symptoms to clear.

 

  6             DR. CANTILENA:  Well, that will be coming

 

  7   up actually.  We will make it unanimous in terms of

 

  8   nobody likes "cures most," and I think you should

 

  9   obviously fix that, and then strengthening the

 

 10   warnings is something that we will talk about now.

 

 11             That was unanimous for 3(b).

 

 12             Let's conclude.  I don't think you all

 

 13   want to come back tomorrow morning just for one

 

 14   part of one question, so although we are past the

 

 15   hour, I apologize, but I think we will be finished.

 

 16             3(a) is the last thing we need to deal

 

 17   with, and basically, in addition to what has

 

 18   already been said, I would like to get everyone's

 

 19   opinions, and we will go around the room this way

 

 20   looking for specific additions that should be made

 

 21   with regard to the three things that were

 

 22   suggested.  Cure rate, should that be there. 

 

                                                               438

 

  1   Expectation of symptom relief, you know, delay in

 

  2   response, and anything else that you need, that you

 

  3   think should be added to the label to help

 

  4   consumers select this and use this class of

 

  5   products.

 

  6             Ms. Knudson, would you like to talk about

 

  7   things that you would like to see added to the

 

  8   label of existing and future?

 

  9             MS. KNUDSON:  I would like to see what the

 

 10   effective treatment rate is.  I think that is more

 

 11   important for consumers than cure rate, because

 

 12   they are going to think that it is has really gone

 

 13   forever.

 

 14             I would like to see certainly expectation

 

 15   of symptom relief.  That is something that I think

 

 16   is terribly important.  I think that since it has

 

 17   been pointed out repeatedly in the material that we

 

 18   have received, that there is a delay in response.

 

 19   I think that should be noted, so that consumers can

 

 20   expect that and will continue with the drug or wait

 

 21   to see what happens for the full 7 days or however

 

 22   many days it's appropriate.

 

                                                               439

 

  1             DR. CANTILENA:  Thank you.

 

  2             Dr. Benowitz.

 

  3             DR. BENOWITZ:  I agree with Paula's

 

  4   comments.

 

  5             DR. CANTILENA:  So, everything that was in

 

  6   the question, you are in favor of.

 

  7             DR. BENOWITZ:  Yes.

 

  8             DR. CANTILENA:  Dr. Clapp.

 

  9             DR. CLAPP:  Oops, I think I gave my answer

 

 10   already.

 

 11             DR. CANTILENA:  Well, that's all right.  I

 

 12   just wanted to come back to see if you had any

 

 13   additional comments.  You were on such a roll

 

 14   there, I didn't want to interrupt you.

 

 15             Dr. Epps.

 

 16             DR. EPPS:  Yes, I agree with 3(a) and all

 

 17   its parts.

 

 18             DR. CANTILENA:  Dr. Raimer.

 

 19             DR. RAIMER:  I like the idea of effective

 

 20   treatment rates also rather than cure rates.

 

 21             DR. CANTILENA:  Dr. Wilkerson.

 

 22             DR. WILKERSON:  I like effective rates,

 

                                                               440

 

  1   too, much like what we are doing with psoriasis.

 

  2   Instead of calling this the PASI index, we are

 

  3   going to call it the FASI index. That's the Fungal

 

  4   Area Severity Index, and we will put a 12-week

 

  5   marker, at which time they have to be mycologically

 

  6   negative culture, after a course of therapy,

 

  7   develop a score, and then classify it on an easy

 

  8   scheme.

 

  9             I think this is something we need to cross

 

 10   all drugs right now for comparability is we don't

 

 11   have standards to really compare whatever we are

 

 12   comparing to each other.

 

 13             DR. CANTILENA:  So, how would you express

 

 14   that information on a label for consumers?

 

 15             DR. WILKERSON:  I would develop a very

 

 16   short analog scale 1 to 4 or some kind of

 

 17   classification, very effective or ultra effective,

 

 18   or something, but behind the scenes, we would score

 

 19   these to some standard, 75 percent mycologic cure

 

 20   at 12 weeks or whatever our standard.

 

 21             This thing about the erythema and the

 

 22   scaling, and all that, I agree is nothing, and what

 

                                                               441

 

  1   really counts in the end is once you are treated,

 

  2   does your infection come back, and there is a lot

 

  3   of reasons to have red feet and one thing and

 

  4   another, but in the end, at a reasonable period of

 

  5   time, 3 months out, it could be arbitrary, is your

 

  6   infection still gone, or are your symptoms of your

 

  7   infection still gone.

 

  8             If it is, then, as a consumer, I would

 

  9   probably be very happy.  I think we need some

 

 10   standardized scoring, something that is

 

 11   standardized, easily scored, and to give consumers

 

 12   an idea of which one of these, because as a

 

 13   physician, I have no objective evidence outside of

 

 14   clinical experience to tell me which one I think

 

 15   works better.

 

 16             DR. CANTILENA:  Dr. Patten, specific

 

 17   additions to the label.

 

 18             DR. PATTEN:  I support all three.  I think

 

 19   telling the consumers something about effective

 

 20   treatment is particularly important, but I think

 

 21   you also need to tell the consumer what effective

 

 22   treatment means, so they don't conflate it or

 

                                                               442

 

  1   confuse it with complete cure.

 

  2             DR. CANTILENA:  Dr. Lam.

 

  3             DR. LAM:  Some sort of a measure of

 

  4   effective treatment by whatever means that we agree

 

  5   later.  I think definitely, the consumer should be

 

  6   notified on the label regarding the time course of

 

  7   response relative to the duration of treatment, as

 

  8   well as the time course of resolution of symptoms,

 

  9   so that they know that they have to continuously

 

 10   take the medication as directed.

 

 11             DR. CANTILENA:  Dr Ringel.

 

 12             DR. RINGEL:  I agree that there should be

 

 13   labeling that addresses all three of these issues,

 

 14   however, I think it needs to be pretty general

 

 15   unless we can do one head-to-head study of every

 

 16   antifungal on the market and then update that study

 

 17   every time a new antifungal comes on the market,

 

 18   there is going to be unrealistic competition and

 

 19   unrealistic claims for every product that comes

 

 20   along.

 

 21             So, I think what you need to do is stay

 

 22   pretty general and say something like resolution of

 

                                                               443

 

  1   symptoms may take weeks, not all symptoms may

 

  2   resolve, you know, reinfection is possible, and

 

  3   just leave it at that.

 

  4             DR. CANTILENA:  Dr. Fincham.

 

  5             DR. FINCHAM:  I think to reduce costs on

 

  6   the part of the sponsor, which, in turn, will

 

  7   reduce costs for patients hopefully, I think we

 

  8   need to be general relative to the effective

 

  9   treatment and what that means, but I think

 

 10   something needs to be referenced to that point, and

 

 11   I think expectation of symptom relief, as well as

 

 12   delay in response are perfectly appropriate to have

 

 13   on there.

 

 14             DR. CANTILENA:  Dr. Whitmore.

 

 15             DR. WHITMORE:  I second all that, and I

 

 16   wonder if you could cut down on physician visits

 

 17   for tinea pedis not responding to topicals by

 

 18   adding to the labeling that if after one month, you

 

 19   still have some symptoms, you can repeat it, but

 

 20   that is another issue.

 

 21             DR. CANTILENA:  You would probably have to

 

 22   study that in order to put that in your label.

 

                                                               444

 

  1             Dr. Davidoff.

 

  2             DR. DAVIDOFF:  Yes, I agree that Nos. 2

 

  3   and 3, there should be additional information about

 

  4   the delay in response, and so on.  No. 1, I am not

 

  5   comfortable with, the notion of putting cure rates

 

  6   for several reasons, one being that there aren't

 

  7   head-to-head studies and therefore if you are

 

  8   asking consumers to compare one box to another,

 

  9   they are really comparing data that is not very

 

 10   comparable, and I don't think that is fair or

 

 11   appropriate, on top of which, we can't even decide,

 

 12   I think for good reasons, whether cure rate or

 

 13   effective treatment is the appropriate endpoint to

 

 14   be talking about.

 

 15             Finally, Tom Ten Have and his colleagues

 

 16   have convinced me that relying on point estimates

 

 17   as a way of conveying information alone is very

 

 18   chancy, and I think that putting down cure rates

 

 19   doesn't take into account the measures of

 

 20   uncertainty of the data, and without that, it is

 

 21   actually misleading.

 

 22             DR. CANTILENA:  So, how would you

 

                                                               445

 

  1   communicate that information to the consumer?

 

  2             DR. DAVIDOFF:  I wouldn't try to

 

  3   quantitate it.

 

  4             DR. CANTILENA:  Dr. Schmidt.

 

  5             DR. SCHMIDT:  I agree.  The one thing I

 

  6   would mention, though, as putting information on

 

  7   the labeling, and it is already on this one on page

 

  8   19, is about proper foot care.  I think that is

 

  9   very important.

 

 10             DR. CANTILENA:  Dr. Katz.

 

 11             DR. KATZ:  I think it would be more

 

 12   informative for the consumer to know whether it's

 

 13   effective in 20 percent or 40 percent or 90

 

 14   percent, and a range.  It wouldn't be head-to-head

 

 15   comparison if it was just comparison against

 

 16   placebo.

 

 17             I think also it is very important when you

 

 18   say 80 percent clear, that the consumer know that

 

 19   50 percent of the placebo may be clear in that

 

 20   study, so the effective clearing rate is really 30

 

 21   percent, so I think it is important that we not be

 

 22   deceptive in that degree, but it is more specific

 

                                                               446

 

  1   to let somebody know when they are picking up a

 

  2   tube of medication whether they have a 30 percent

 

  3   chance of stopping itching or 90 percent.

 

  4             I would say also as an aside, that when

 

  5   people say that it's negative mycology completely

 

  6   in 90 percent of patients, things of that sort on

 

  7   page 7, Dr. Fritsch's comment, even negative

 

  8   mycology, if you subtract placebo, you are talking

 

  9   about 23 percent to 67 percent with different drugs

 

 10   giving clearing KOH and culture.  That is on page

 

 11   7.

 

 12             DR. CANTILENA:  Thank you.

 

 13             Dr. Ghannoum.

 

 14             DR. GHANNOUM:  Although I agree with Dr.

 

 15   Davidoff about really it is no comparative, I think

 

 16   it will be helpful to add for the effective

 

 17   treatment, the percentage, clarifying that is

 

 18   relative to the placebo, and I agree with the other

 

 19   two that we should add information as far as

 

 20   symptom relief, that the response may take longer,

 

 21   may be delayed.

 

 22             DR. CANTILENA:  Dr. Bisno.

 

                                                               447

 

  1             DR. BISNO:  No additional comments.

 

  2             DR. CANTILENA:  Dr. Wood.

 

  3             DR. WOOD:  I think we should add efficacy

 

  4   data and although I am very sympathetic to Frank's

 

  5   comments about point estimates, and so on, I think

 

  6   one of the issues here is that we want to encourage

 

  7   people to develop more effective therapy, and the

 

  8   only way we are going to do that is to give them

 

  9   the right to promote on that.

 

 10             So, I think allowing people to put

 

 11   efficacy data on the label encourages better and

 

 12   more effective therapy to be developed, because

 

 13   people will have a commercial advantage.

 

 14             I am very much against putting wording on

 

 15   the label that requires interpretation, like very

 

 16   effective, partially effective, and so on, because

 

 17   the FDA will end up in interminable arguments about

 

 18   where these cutpoints are, and they will appear to

 

 19   have credibility that don't exist, so I mean if you

 

 20   are going to put it on, you put it on the way the

 

 21   studies came out, and you don't try and squeeze

 

 22   them into boxes, because everybody will be trying

 

                                                               448

 

  1   to move the box line to catch their product.

 

  2             DR. CANTILENA:  Dr. Ten Have.

 

  3             DR. TEN HAVE:  As a statistician, I would

 

  4   take Dr. Davidoff's bait and say confidence

 

  5   intervals, of course, but as a consumer with

 

  6   athlete's foot, I can understand both sides of the

 

  7   issue in terms of whether or not you report, say,

 

  8   effective treatment rates.

 

  9             It's a difficult issue and as a scientist,

 

 10   I would say yes, even though the rates are based on

 

 11   different types of responses, it is still the more

 

 12   information and caveat emptor, so, I would have to

 

 13   say report confidence intervals, but I know that is

 

 14   not plausible.

 

 15             DR. CANTILENA:  The comprehension study on

 

 16   that would be interesting.

 

 17             Dr. Alfano.

 

 18             DR. ALFANO:  I would agree with (a) ii and

 

 19   iii, and I think there have been adequate proposals

 

 20   from the industry to enrich those two claim areas.

 

 21             I strongly disagree with any specific

 

 22   statement of cure rates or effective treatment

 

                                                               449

 

  1   rates or whatever.  Dr. Ringel just said it

 

  2   brilliantly, I think.  I mean we will have

 

  3   initiated an insane horsepower race that will only

 

  4   confuse the consumers.  The studies are done at

 

  5   different times in different ways.

 

  6             The newer studies could be penalized

 

  7   because they have more rigorous controls and the

 

  8   response rates might not look as good, and we have

 

  9   already seen how this becomes a slippery slope.  We

 

 10   now have charts, now we are talking about

 

 11   confidence intervals on some package labels.  The

 

 12   consumers are going to need Ph.D.'s to understand

 

 13   these things.

 

 14             I thought we were going the other way.  I

 

 15   thought we were going to simple icons to make it

 

 16   easier for people to do this, and you apply this to

 

 17   other categories, analgesics.  Do you put on

 

 18   headaches, do you put on toothaches, third molar

 

 19   extraction, episiotomy?  I mean it's insane.

 

 20             I understand we want to inform the

 

 21   consumers, but this is I think wasteful information

 

 22   that will only confuse them.

 

                                                               450

 

  1             DR. CANTILENA:  Thank you.

 

  2             Mr. Kresel.

 

  3             MR. KRESEL:  I think meaningful data is

 

  4   the only thing that helps the consumer, and I

 

  5   absolutely agree with Dr. Ringel and Dr. Davidoff.

 

  6   You are just comparing apples and oranges, studies

 

  7   that were done over a 40-year period, conducted

 

  8   different ways, and try to compare them to today's

 

  9   standards.

 

 10             I don't think that gives any meaningful

 

 11   data to consumers.  We here today couldn't agree on

 

 12   whether it should be a complete cure and effective

 

 13   treatment, so we don't even know where that number

 

 14   would start.

 

 15             I think what the consumer really wants to

 

 16   know is when can I expect to start to feel relief,

 

 17   so onset of activity is really important for a

 

 18   consumer, and the fact that after I stop treatment,

 

 19   can I expect to continue improvement and for how

 

 20   long.

 

 21             So, I think those are things that

 

 22   consumers really want to know, need to know, and I

 

                                                               451

 

  1   think it really helps them.

 

  2             DR. CANTILENA:  Dr. Alfano, did you want

 

  3   to add one thing?

 

  4             DR. ALFANO:  One follow-up comment.  I

 

  5   think it's a justifiable concern that the Agency

 

  6   has about improving drugs in this therapy, so I can

 

  7   understand the concern, but there is a mechanism,

 

  8   Dr. Ganley pointed out earlier, and that is, two,

 

  9   well-controlled trials will get you a claim.

 

 10             You can advertise that claim, and you can

 

 11   drive sales in that fashion, and I think that is

 

 12   the mechanism that will drive this category to

 

 13   further improvements.  We have seen it driven that

 

 14   way already without all these other tools brought

 

 15   to bear.

 

 16             DR. CANTILENA:  I would just like to add

 

 17   that I certainly understand what has been said and

 

 18   the concerns about confidence intervals and

 

 19   flooding the label, but I think as it stands now,

 

 20   the consumer is not given enough information for

 

 21   them to select the most efficacious product.

 

 22             There obviously is information available

 

                                                               452

 

  1   because we have seen it today and we will hear the

 

  2   Code in our closed session tomorrow in terms of who

 

  3   is A, B, C, and D.  So, at least you, as a

 

  4   committee member, will be able to go buy the most

 

  5   effective treatment for athlete's foot.

 

  6             So, Tom, if you can just hold on another

 

  7   day, relief is on the way.

 

  8             But I think the other things, what is on

 

  9   the slide, I think would inform the consumer.  I

 

 10   think the current label is inadequate in those

 

 11   areas and I agree with what has been suggested as

 

 12   possible additions.  I don't know the right way to

 

 13   handle the effect of treatment, but you have to

 

 14   give them some information that is quantitative in

 

 15   some respects.

 

 16             So, having almost the last word, we have

 

 17   an issue for tomorrow.  Since we basically

 

 18   accomplished the morning agenda for tomorrow this

 

 19   afternoon, we will start the closed session--the

 

 20   Nonprescription Advisory Committee will meet here

 

 21   at 8 o'clock.  Everyone will meet here and we will

 

 22   split up.

 

                                                               453

 

  1             DR. GANLEY:  Jon and I talked and I think

 

  2   we could probably meet here at 8:30.  We have to

 

  3   have the Open Session at 11 o'clock.  I think both

 

  4   of us have probably two hours' worth of information

 

  5   to go over with the committees.

 

  6             DR. CANTILENA:  Just to summarize for

 

  7   those of you who didn't hear all that, all of us

 

  8   back here at 8:30 tomorrow morning.  The other

 

  9   committee is escorted over to the Parklawn.  We

 

 10   will have another class outing with your chaperons.

 

 11   Then we are all back here together for the Open

 

 12   Public Hearing at 11 o'clock.

 

 13             With that, we will close today's meeting.

 

 14   Thank you very much, members of the committee and

 

 15   members of FDA.

 

 16             (Whereupon, at 6:00 p.m., the meeting was

 

 17   recessed to be resumed at 8:30 a.m., Friday, May 7,

 

 18   2004.)

 

 19                              - - -