1

 

                DEPARTMENT OF HEALTH AND HUMAN SERVICES

 

                      FOOD AND DRUG ADMINISTRATION

 

                CENTER FOR DRUG EVALUATION AND RESEARCH

 

 

 

 

 

 

 

 

 

 

 

 

 

 

              GASTROINTESTINAL DRUGS ADVISORY SUBCOMMITTEE

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                        Wednesday, July 14, 2004

 

                               8:30 a.m.

 

 

 

                          ACS Conference Room

                               Room 1066

                           5630 Fishers Lane

                          Rockville, Maryland

                                                                 2

 

                              PARTICIPANTS

 

         Ronald P. Fogel, M.D., Acting Chair

         Thomas H. Perez, M.P.H., R.Ph.,

            Executive Secretary

 

         MEMBERS:

 

         Alan Lewis Buchman, M.D.

         Byron Cryer, M.D.

         Alexander H. Krist, M.D.

         John T. LaMont, M.D.

         Robert A. Levine, M.D.

         David C. Metz, M.D.

         Weichung Joe Shih, Ph.D.

         David B. Sachar, M.D.

         Jose M. Vega, M.D., Industry Representative

 

         DRUG SAFETY AND RISK MANAGEMENT

         ADVISORY COMMITTEE (Voting):

 

         Brian L. Strom, M.D., M.P.H.

         Curt D. Furberg, M.D., Ph.D.

         Arthur A. Levin, M.P.H., Consumer Representative

 

         CONSULTANTS (Voting):

 

         Ralph D'Agostino, Ph.D.

         Allen Mangel, M.D., Ph.D.

 

         FEDERAL EMPLOYEE (Voting):

 

         Maria H. Sjogren, M.D.

 

         FDA STAFF:

 

         Robert Justice, M.D., Director, Division

            of Gastrointestinal and Coagulation

            Drug Products

         Robert Prizont, M.D., Medical Officer

         Garry Della'Zanna, D.O., M.Sc., Medical Officer

         Julie Beitz, M.D., Deputy Director, ODE III

                                                                 3

 

                            C O N T E N T S

 

      Call to Order, Introductions, Ronald Fogel, M.D.,          5

 

      Meeting Statement, Thomas H. Perez, M.P.H.                 8

 

      Opening Comments, Robert Justice, M.D., Director,

         Division Gastrointestinal and Coagulation Drug

         Products                                               11

 

      Novartis Presentation, Zelnorm, NDA 21-200:

 

      Introduction, John R. Cutt, Ph.D., Novartis

         Executive Director Global Head GI, Drug

         Regulatory Affairs                                     14

 

      Chronic Constipation: An Unresolved Problem for

         Many Patients, Charlene M. Prather, M.D., St.

         Louis University School of Medicine                    20

 

      Zelnorm: Efficacy and Safety in Chronic

         Constipation,

      Eslie Dennis, M.D., Novartis Senior Medical

         Director, GI Clinical Develop and Medical

         Affairs                                                40

 

      Zelnorm: Safety Overview, Bo Joelsson, M.D.,

         Novartis Senior Medical Director, Clinical R&D         69

 

      Fatality Cases, Michael Shetzline, M.D., Ph.D.,

         Novartis Senior Medical Director, U.S. Clinical

         Development and Medical Affairs                        82

 

      Zelnorm: Safety Overview (continued),

         Bo Joelsson, M.D.                                      92

 

      Benefit/Risk Assessment, Philip Schoenfeld, M.D.,

         University of Michigan School of Medicine              94

 

      Questions on Presentation                                116

 

      FDA Efficacy Presentation, Robert Prizont, M.D.,

         Medical Officer, Division of Gastrointestinal

         and Coagulation Drug Products                         158

                                                                 4

 

                      C O N T E N T S (Continued)

 

      Questions on Presentation                                173

 

      FDA Safety Presentation, Gary Della'Zanna, M.Sc.,

         Medical Officer, Division of Gastrointestinal

         and Coagulation Drug Products                         199

 

      Questions on Presentation                                220

 

      Open Public Hearing:

 

      Jeffrey D. Roberts, B.Sc., IBS Self Help Group           229

      Constance Hill                                           235

      Linda Roepke                                             241

 

      Clarification of Issues                                  249

 

      Discussion of Questions                                  295

 

      Adjournement                                             364

 

                                                                 5

 

                         P R O C E E D I N G S

 

                      Call to Order, Introductions

 

                DR. FOGEL:  Good morning.  My name is Ron

 

      Fogel.  I am acting chair for today's meeting of

 

      the Gastrointestinal Drugs Advisory Committee.

 

      Today's meeting deals with the new drug application

 

      of Zelnorm for the proposed indication of the

 

      treatment of patients with chronic constipation and

 

      relief of associated symptoms of straining hard or

 

      lumpy stools and infrequent defecation.

 

                There has been one change to today's

 

      agenda.  The agenda has been pushed back half an

 

      hour so the tentative time of adjournment is five

 

      o'clock.  Why don't we start by going around the

 

      table and introducing ourselves?  If we could start

 

      on my far left?

 

                DR. VEGA:  Jose Vega, from Amgen in

 

      California.

 

                DR. LEVIN:  Arthur Levin.  I am a member

 

      of the Drug Safety and Risk Management Advisory

 

      Committee.  I am a consumer representative and I am

 

      a guest as a consumer representative here today.

 

                                                                 6

 

                DR. STROM:  Brian Strom, University of

 

      Pennsylvania.  I am a recent graduate of the Drug

 

      Safety and Risk Management Advisory Committee--I

 

      have already forgotten the name of the committee!

 

      I am here as a special government employee, though

 

      that is not what is says there.

 

                DR. FURBERG:  I am Curt Furberg, from Wake

 

      Forrest University.  I am an active member of the

 

      Drug Safety and Risk Management Advisory Committee.

 

                DR. D'AGOSTINO:  Ralph D'Agostino, from

 

      Boston University, statistician, consultant to the

 

      FDA.

 

                DR. LAMONT:  I am Tom LaMont.  I am a

 

      member of the GIDAC.  I work at Beth Israel

 

      Hospital in Boston and Harvard Medical School.

 

                DR. LEVINE:  I am Bob Levine, State

 

      Medical University, Syracuse, New York, and I am a

 

      member of the GI advisory committee.

 

                DR. METZ:  David Metz, University of

 

      Pennsylvania.  I am on the GI drug advisory

 

      committee.

 

                DR. PEREZ:  Tom Perez, Executive Secretary

 

                                                                 7

 

      to this meeting.

 

                DR. FOGEL:  Ron Fogel, Henry Ford Health

 

      System, in Detroit.

 

                DR. SACHAR:  I am David Sachar, from Mount

 

      Sinai School of Medicine, in New York--my maiden

 

      voyage on the GI drug advisory committee.

 

                [Laughter]

 

                DR. BUCHMAN:  Alan Buchman, from

 

      Northwestern University, in Chicago, and this is

 

      also my first cruise with today as well.

 

                DR. MANGEL:  Allen Mangel, Research

 

      Triangle Institute.  I am a special government

 

      employee.

 

                DR. CRYER:  I am Byron Cryer, from the

 

      Dallas VA Medical Center and UT Southwestern

 

      Medical School.  I am a member of the GI advisory

 

      committee.

 

                DR. DELLA'ZANNA:  Garry Della'Zanna,

 

      medical officer in the GI and Coagulation Drug

 

      Product Division.

 

                DR. JUSTICE:  Robert Justice, Director,

 

      Division of Gastrointestinal and Coagulation Drug

 

                                                                 8

 

      Products.

 

                DR. BEITZ:  Julie Beitz, Deputy Director

 

      in the Office of Drug Evaluation III.

 

                DR. FOGEL:  Thank you, all.  At this point

 

      Tom Perez will read the meeting statement.

 

                           Meeting Statement

 

                DR. PEREZ:  Thank you and good morning.

 

      The following announcement addresses the issue of

 

      conflict of interest with regard to this meeting,

 

      and is made part of the record to preclude even the

 

      appearance of such at this meeting.

 

                Based on the submitted agenda for the

 

      meeting and all financial interests reported by the

 

      committee participants, it has been determined that

 

      all interests in firms regulated by the Center for

 

      Drug Evaluation and Research present no potential

 

      for an appearance of a conflict of interest at this

 

      meeting, with the following exceptions:

 

                In accordance with 18 USC Section

 

      208(b)(3), full waivers have been granted to the

 

      following participants, Dr. Ronald Fogel has been

 

      granted a waiver for serving as a member of the

 

                                                                 9

 

      sponsor's speakers bureau.  His lectures are

 

      unrelated to the matter at issue and he receives

 

      less than $10,001 per year.

 

                Dr. Ralph D'Agostino has been granted a

 

      waiver for serving on a competitor's advisory board

 

      on unrelated matters.  He receives less than

 

      $10,001 per year.

 

                Dr. Byron Cryer has been granted a waiver

 

      under 21 USC 355(n)(4), amendment of Section 505 of

 

      the Food and Drug Administration Modernization Act,

 

      for ownership of stock in a competitor.  The stock

 

      is worth less than $5,001.  Because this interest

 

      falls below the de minimis exemption allowed under

 

      5 CFR 2640.202(a)(2) a waiver underlying 18 USC

 

      208(b)(3) is not required.

 

                Dr. David Metz has been granted waivers

 

      under 18 USC Section 208(b)(3) and 21 USC 355(n)(4)

 

      for his spouse's ownership of stock in a competitor

 

      valued from $50,001 to $100,000.

 

                Lastly, Dr. Allen Buchman has been granted

 

      waivers under 18 USC Section 208(b)(s) and 21 USC

 

      355(n)(4) for owning stock in a competitor valued

 

                                                                10

 

      from $25,001 to $50,000.

 

                A copy of the waiver statements may be

 

      obtained by submitting a written request to the

 

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

 

      or the Parklawn Building.

 

                In the event that the discussions involve

 

      any other products or firms not already on the

 

      agenda for which an FDA participant has a financial

 

      interest, the participants are aware of the need to

 

      exclude themselves from such involvement and their

 

      exclusion will be noted for the record.

 

                We would also like to note that Dr. Jose

 

      Vega has been invited to participate as an industry

 

      representative, acting on behalf of regulated

 

      industry.  Dr. Vega is employed by Amgen, Inc.

 

                With respect to all other participants, we

 

      ask in the interest of fairness that they address

 

      any current or previous financial involvement with

 

      any firm whose product they may wish to comment

 

      upon.  Thank you.

 

                DR. FOGEL:  Thank you.  At this time I

 

      will turn the meeting over to Dr. Justice, of the

 

                                                                11

 

      FDA, for opening comments.

 

                            Opening Comments

 

                DR. JUSTICE:  Good morning.  I would like

 

      to welcome everyone to today's meeting of the

 

      Gastrointestinal Drugs Advisory Committee, and I

 

      would especially like to welcome members of the

 

      committee and special government employees for

 

      taking the time to provide us with your advice.

 

                As you have heard, today we will be

 

      discussing the application for Zelnorm tablets for

 

      the proposed indication of treatment of chronic

 

      constipation.  Before going on to the

 

      presentations, I would just like to briefly go

 

      through the questions so you will have them in mind

 

      as you listen to the discussions.

 

                The first item is that we would like you

 

      to discuss the appropriateness of a primary

 

      efficacy endpoint of an increase of equal to or

 

      greater than 1 complete spontaneous bowel movement

 

      per week versus a total of greater than 3 complete

 

      spontaneous bowel movements per week.

 

                The second question is, is the population

 

                                                                12

 

      studied representative of patients with chronic

 

      constipation?  If not, how do the populations

 

      differ?

 

                The third question is only 9 to 16 percent

 

      of subjects were greater than or equal to 65 years

 

      of age and the treatment effect was significantly

 

      smaller in older patients.  Are these data adequate

 

      for an indication that is common in the elderly?

 

                The fourth efficacy question is that only

 

      9 to 14 percent of the subjects were male and the

 

      treatment effect was smaller in males than females.

 

      Are these data adequate to support approval of

 

      Zelnorm for use in the treatment of chronic

 

      constipation in males?

 

                The next question is are the clinical

 

      trial data adequate with respect to the population

 

      of non-irritable bowel syndrome patients with

 

      chronic constipation that is likely to be treated

 

      with Zelnorm?

 

                The next efficacy question is, is Zelnorm

 

      effective for the treatment of chronic constipation

 

      and associated symptoms?

 

                                                                13

 

                As far as the safety questions,

 

      postmarketing access of ischemic colitis and

 

      serious complications of diarrhea were not limited

 

      to patients with irritable bowel syndrome.  What

 

      are the implications of these adverse events from

 

      patients with chronic constipation?

 

                The next safety question is that the

 

      incidence of diarrhea and discontinuation due to

 

      diarrhea was higher in patients 65 years of age or

 

      older.  Is there sufficient information that

 

      Zelnorm is safe for use in this age group?

 

                The next safety question is do the adverse

 

      event data from the clinical trials and

 

      postmarketing surveillance provide adequate

 

      evidence of safety of Zelnorm for the treatment of

 

      chronic constipation?

 

                The next safety question is should the

 

      information on the postmarketing cases of ischemic

 

      colitis and intestinal ischemia be moved from the

 

      "precautions" section to the "warning" section of

 

      the package insert?

 

                Then, the final question will be the

 

                                                                14

 

      overall question of should Zelnorm be approved for

 

      the proposed indication of the treatment of

 

      patients with chronic constipation and relief of

 

      associated symptoms of straining, hard or lumpy

 

      stools, and infrequent defecation?

 

                With that, I will turn it back over to Dr.

 

      Fogel for Novartis' presentation.

 

                DR. FOGEL:  Thank you very much.  At this

 

      juncture I will turn the meeting over to Dr. John

 

      Cutt, Global Head of GI Drug Regulatory Affairs for

 

      Novartis, who will introduce the speakers and the

 

      presentations.  Thank you.

 

                         Novartis Presentation

 

                              Introduction

 

                DR. CUTT:  Thank you.  First I would like

 

      to thank Dr. Beitz, Dr. Justice--Dr. Prizont is not

 

      here yet--and Dr. Della'Zanna and the rest of the

 

      FDA reviewers, and Dr. Fogel and the rest of the

 

      advisory committee, and say good morning to you.

 

                My name is John Cutt.  As Dr. Fogel said,

 

      I am the executive director and the global head for

 

      the gastrointestinal regulatory group at Novartis,

 

                                                                15

 

      and it is my pleasure to share with you today the

 

      clinical data on chronic constipation that we have

 

      generated.

 

                Let me start out with the objectives, as

 

      we see them today for the meeting.  We would like

 

      to share the Zelnorm Phase 3 clinical data in

 

      support of a new indication.  Dr. Fogel read that

 

      before, I will read it again.  Zelnorm is indicated

 

      for the treatment of patients with chronic

 

      constipation and the relief of associated symptoms

 

      of straining, hard or lumpy stools, and infrequent

 

      defecation.

 

                The second topic that we are going to

 

      review today is the postmarketing safety data that

 

      we have generated since the approval of the drug in

 

      the United States in July of 2002.  This approval

 

      was for patients with irritable bowel syndrome with

 

      constipation.

 

                A brief introduction of the compound,

 

      Zelnorm is tegaserod maleate.  It is 5-HT                                

                                                                  4 receptor

 

      partial agonist with affinity for the 5-HT                               

                                                                     4

 

      receptor in the GI tract.  For its pharmacologic

 

                                                                16

 

      activity in the GI tract, Zelnorm enhances

 

      intestinal motility; increases intestinal

 

      secretion; and inhibits visceral sensitivity.  We

 

      have also demonstrated in clinical trials that

 

      Zelnorm can improve the constipation symptoms in

 

      patients with irritable bowel syndrome with

 

      constipation.

 

                So, these data together are the basis for

 

      the hypothesis that Zelnorm could be effective to

 

      treat patients suffering from chronic constipation.

 

                Novartis-designed clinical development

 

      program for chronic constipation included two

 

      randomized, placebo-controlled pivotal studies.

 

      Both the studies were 12 weeks in duration to

 

      assess the efficacy, safety and tolerability of the

 

      drug.  We studies both the 2 mg dose and the 6 mg

 

      dose BID versus placebo.  In total, there were

 

      2,612 patients that were studied.  The program also

 

      included one extension phase study which was added

 

      on to one of the pivotal studies.  This was a

 

      13-month extension for assessing the long-term

 

      safety of the compound.  The other pivotal studied

 

                                                                17

 

      included a 4-week withdrawal period.  Today what we

 

      are going to do is show you the results of these

 

      pivotal studies.

 

                We will also share with you the

 

      postmarketing clinical data that we have collected

 

      since the approval of the drug in the United States

 

      in July of 2002.  That approval was for the

 

      short-term treatment of women with irritable bowel

 

      syndrome whose primary bowel symptom is

 

      constipation.  The recommended dose is 6 mg BID for

 

      a period of up to 12 weeks.  At the time of the

 

      approval we demonstrated the efficacy, safety and

 

      tolerability in 5,319 patients in the clinical

 

      trial program.  At this point in time, now, we have

 

      generated data on 11,600 patients in clinical

 

      trials.  These patients were all treated with

 

      Zelnorm.  What this means is that it translates to

 

      approximately 3,456 patient-year exposure to the

 

      drug in the clinical trials.

 

                In terms of the worldwide clinical

 

      experience for the drug, Zelnorm is now approved in

 

      56 countries for the indication of IBS with

 

                                                                18

 

      constipation.  We have also received approval for

 

      the drug in 10 countries for the indication of

 

      chronic constipation that we are seeking from the

 

      advisory committee and the FDA.

 

                We first made the drug available to

 

      patients suffering from IBS-C in January of 2001 in

 

      the rest of the world.  So, at this point we have

 

      over 3 years of postmarketing experience with the

 

      drug in patients.  What this means is that we have

 

      treated approximately 3 million patients globally

 

      with the drug and about 2 million of those patients

 

      have been treated in the United States.  This now

 

      translates to about 362,000 patient-years of

 

      experience to Zelnorm.

 

                The safety data from the clinical trial

 

      setting and the postmarketing environment we

 

      believe supports a favorable safety profile for

 

      Zelnorm.  So, our conclusion from the data that you

 

      will see today during the presentations is that

 

      Zelnorm, at the recommended dose of 6 mg BID, is

 

      efficacious and safe for the treatment of patients

 

      with multiple symptoms of chronic constipation.

 

                                                                19

 

                What I want to do is review the agenda

 

      very briefly, the people that will be presenting

 

      for us.  First we have Dr. Charlene Prather.  She

 

      is from the St. Louis University and will speak

 

      about chronic constipation.  Her presentation is

 

      title an unresolved problem for many patients in

 

      clinical practice.

 

                She will be followed by Dr. Eslie Dennis.

 

      Eslie is from the Novartis clinical development and

 

      medical affairs department.  Dr. Dennis will

 

      present the efficacy and safety data from the

 

      pivotal studies.

 

                That will be followed by Dr. Bo Joelsson.

 

      He will present our overall clinical safety data

 

      and review some of the adverse events of special

 

      interest that we have agreed to talk about with the

 

      FDA.

 

                Finally, Dr. Philip Schoenfeld, who is the

 

      chief of the gastrointestinal group at the Veterans

 

      Hospital in Ann Arbor, at the University of

 

      Michigan, will conclude historical presentation

 

      with a benefit/risk assessment for the drug.

 

                                                                20

 

                We also have four consultants that have

 

      joined us today to answer questions that you may

 

      have.  The first one is Dr. Felix Arellano.  He is

 

      from the Risk Management Resources group.  His

 

      expertise is pharmacovigilance, epidemiology and

 

      risk management.  Then we have Dr. Gary Koch.  Dr.

 

      Gary Koch is from North Carolina, Chapel Hill.  He

 

      is an expert in biostatistics.  We have Dr. David

 

      Lieberman.  He is from the Oregon Health and

 

      Science University.  He will be here to answer any

 

      questions you have on the core database which is

 

      part of the presentation.

 

      Then we have Dr. Walter Peterson, a

 

      gastroenterologist from the University of Texas

 

      Southwestern.

 

                We have also a number of scientists and

 

      clinicians from Novartis who can answer any of the

 

      specific questions that you have on Zelnorm.

 

                Now I would like to invite Dr. Prather up

 

      to the podium.

 

                         Chronic Constipation:

 

                An Unresolved Problem for Many Patients

 

                                                                21

 

                DR. PRATHER:  Thank you, Dr. Cutt.  Dr.

 

      Fogel, committee members, ladies and gentlemen, my

 

      name is Charlene Prather.  As you heard, I am from

 

      St. Louis University.  I am a gastroenterologist.

 

      I have been in practice for over ten years.  My

 

      career has been dedicated to the clinical

 

      investigation and, importantly, the clinical

 

      treatment of patients with functional bowel

 

      disorders and gastrointestinal motility disorders.

 

      Chronic constipation is one of the very common

 

      problems that I see in my clinical practice and it

 

      is, indeed, an unresolved problem for many of the

 

      patients that come to see me.

 

                First I would like to review my

 

      presentation objectives.  I will begin with a

 

      definition of chronic constipation.  I will discuss

 

      epidemiology and resource utilization that is

 

      associated with chronic constipation.  I will

 

      review available therapies and the limitations that

 

      some of these therapies may have.  I will also

 

      summarize for you my feelings regarding the unmet

 

      medical need associated with chronic constipation.

 

                                                                22

 

                First, beginning with the definition of

 

      chronic constipation, there are a variety of ways

 

      to define constipation.  I have decided to define

 

      constipation into either primary causes of

 

      constipation or secondary causes of constipation.

 

                First let's discuss the secondary causes

 

      of chronic constipation.  Secondary causes include

 

      things such as drug-induced constipation.  We are

 

      certainly familiar with this with the narcotics we

 

      may give our chronic pain patients.  Metabolic

 

      factors--hypothyroidism, hypocalcemia may be

 

      associated with chronic constipation.  Importantly,

 

      co-morbid medical conditions.  We are certainly

 

      familiar with a variety of neurological disorders,

 

      such as Parkinson's disease, multiple sclerosis, in

 

      which constipation is an important complaint that

 

      many of these patients may bring to us.  However,

 

      this is not what I am here to discuss today.

 

                Today I would like to review primary

 

      constipation.  Again, with primary constipation we

 

      have learned much in the past several years

 

      regarding what causes primary constipation.  There

 

                                                                23

 

      may be impaired colonic transit or motor function,

 

      certainly an area that I am very interested in.  We

 

      often call this slow transit constipation.  This

 

      may result from a failure of the neurenteric

 

      function of the digestive system or from the

 

      gastrointestinal reflexes that are involved.  It

 

      may also result because there is a problem with the

 

      muscle, a failure of the muscular apparatus.

 

                We also can look at chronic constipation

 

      as a subgroup having ineffective defecation.  We

 

      also may call this functional outlet obstruction.

 

      This is really where there is a poor coordination

 

      in the muscular apparatus that is involved in the

 

      defecation process.  There are some other

 

      terminologies that may be used as well, such as

 

      pelvic dyssynergia or anismus may be a term that

 

      you have also heard.  Most cases of primary chronic

 

      constipation fall into neither of these categories.

 

      They are actually normal transit constipation.

 

                Constipation really isn't defined by

 

      physiologic testing; it is defined on the basis of

 

      symptoms.  In my practice the most common reported

 

                                                                24

 

      symptoms that I see coming from my patients are

 

      complaints of hard or lumpy stools; increased

 

      straining.  They may complain of infrequent bowel

 

      movements, but often the sensation of incomplete

 

      evacuation, really outcome having a satisfactory

 

      bowel movement and, not uncommonly, the complaint

 

      of gloating or fullness.  Typically, the longer

 

      they have gone since they had a bowel movement, you

 

      know, they are feeling more full and they may

 

      describe that as a bloated sort of sensation.

 

                When I think about chronic constipation,

 

      this is more persistent than intermittent or

 

      episodic constipation.  We are familiar with

 

      transient constipation that may occur as a result

 

      of a dietary change.  We may also see it in

 

      relation to travel.  When I think about what is the

 

      definition I will use for chronicity, it needs to

 

      have been present for several months duration and

 

      quite commonly, in my practice, these patients have

 

      had their constipation for years, frequently dating

 

      back to early adolescence or sometimes even

 

      childhood.

 

                                                                25

 

                Well, how valid are my ideas about what my

 

      patients bring me with those symptoms?  There

 

      actually have been some studies that have taken a

 

      look at this.  One of the first studies, performed

 

      by Dr. Robert Sandler, in North Carolina, took a

 

      look at a group of young adults, those around the

 

      university community.  These were individuals who

 

      had constipation and the symptoms they reported

 

      most often were, indeed, straining 52 percent of

 

      the time; hard stools, 44 percent of the time;

 

      wanted to have a bowel movement but were unable to,

 

      34 percent of the time; with infrequent stools

 

      being reported just 32 percent of the time.

 

                Now let's think about this.  Physicians

 

      were often called upon to think very quantitatively

 

      so we often think about the frequency as being the

 

      most important symptom in constipation.  But,

 

      clearly, our patients seem to be telling us

 

      something a bit different.  Now, this was not a

 

      population-based study so what actually happens in

 

      the population when we discuss symptoms and

 

      constipation?

 

                                                                26

 

                I have two studies to review with you.

 

      First is a study on the left, a large

 

      population-based, epidemiologic study by Stewart.

 

      He took a look at the symptoms most commonly

 

      reported in constipation.  Again, at the top we see

 

      the complaint--an incomplete bowel movement 83

 

      percent of the time.  Unsuccessful bowel movement,

 

      being called a stool but being unable to 65 percent

 

      of the time.  We see complaints of abdominal

 

      discomfort, needing to press on the abdomen in

 

      order to have a bowel movement; some abdominal

 

      bloating in a group of patients; but, again, down

 

      at the bottom of this list is frequency, with less

 

      than 3 bowel movements per week being reported by

 

      only 13 percent of this cohort.

 

                On the right hand of the slide is another

 

      population-based study by Pare.  Again we see

 

      similar findings, with straining right at the top.

 

      Again, near the bottom less than 3 bowel movements

 

      per week being less frequent in this case, in this

 

      population, 36 percent of the time.

 

                Now, I previously mentioned the subtypes

 

                                                                27

 

      of primary constipation that I considered.  Might

 

      it be slow transit constipation; might it be an

 

      outlet problem; or is it normal transit

 

      constipation?  Well, unfortunately, the symptoms

 

      don't help me differentiate between those different

 

      physiologic groups.  Fortunately, that is not

 

      necessary because in practice we don't use

 

      physiologic testing, nor do we use the patient

 

      symptoms to define which subgroup they belong in.

 

      This has been information we have really found out

 

      over the past several years.  We would like to

 

      think their symptoms will tell us exactly which

 

      subgroup they belong into but that just hasn't been

 

      the case.  In clinical practice and in clinical

 

      trials we really don't try to define the subtype of

 

      constipation based on either their symptoms or on

 

      physiologic testing.

 

                However, it is important that we have

 

      criteria for the use of clinical testing and having

 

      a relatively homogenous group of patients that we

 

      can take a look at.  An important stab at this has

 

      been the Rome criteria.  I would like to review

 

                                                                28

 

      with you the Rome II criteria that are used in the

 

      diagnosis of functional constipation.

 

                The Rome II diagnostic criteria include at

 

      least 12 weeks, which not be consecutive, in the

 

      past 12 months of 2 or more of the following

 

      symptoms:  These symptoms include straining, lumpy

 

      or hard stools, a sensation of incomplete

 

      evacuation, a sensation of anorectal obstruction or

 

      blockage, or having to use manual maneuvers, such

 

      as digitation, to facilitate defecation.  You see

 

      an asterisk by these because these need to have

 

      been present on at least a quarter of defecations.

 

      The other criterion is less than 3 defecations per

 

      week.

 

                Looking back at the top line, we see that

 

      it is 2 or more of the following symptoms.  So, a

 

      patient may have straining, lumpy or hard stools 25

 

      percent of the time and this would be consistent

 

      with the Rome II criteria for chronic constipation.

 

      Or, it could be that they do have less than 3

 

      defecations per week and a sensation of incomplete

 

      evacuation.  For this criterion loose stools must

 

                                                                29

 

      not be present and there should be insufficient

 

      criteria for irritable bowel syndrome.

 

                A caveat with the Rome criteria is that

 

      one of the criteria that they say is that I cannot

 

      use these criteria if my patients are already on

 

      laxatives.  So, these are criteria that are really

 

      appropriate for individuals who are not currently

 

      using laxatives.

 

                Using these definitions and, again, the

 

      Rome I definition was for the criteria from before,

 

      how common is chronic constipation in the general

 

      population?  These are some population-based

 

      studies and, depending on the criteria that have

 

      been used, we see a prevalence in the range of 4

 

      percent up to 16 percent.  This is a lot of

 

      patients that are complaining of constipation.

 

      However, not all of these patients are actually

 

      coming to see us.  A few of these studies actually

 

      looked at how many of these patients or individuals

 

      had actually sought physician care for the

 

      evaluation and treatment of constipation.

 

                What we see is that it is only about 25

 

                                                                30

 

      percent that actually come in to the physician's

 

      office in order to seek some sort of treatment.

 

                A little bit more about the prevalence,

 

      when we think about constipation we need to know

 

      what age groups might be affected.  In the Pare

 

      study he was able to divide this out.  In the green

 

      bars we see the Rome I criteria and in the magenta

 

      bars the Rome II criteria.  There are some slight

 

      differences, again, depending on the definition

 

      that has been used.  This is true of all of the

 

      epidemiologic studies, that we really need to

 

      understand the criteria.

 

                Well, what we see is that actually

 

      constipation is a bit more common in the younger

 

      age group, the 18-34 year-old age group.  This is

 

      consistent with my clinical practice.  We see that

 

      the prevalence is relatively flat when we take a

 

      look at the 35-49 year-old age group; the 50-64

 

      year-old age group; and even the over 64 year-ole

 

      age group.  So, constipation really affects all age

 

      groups.

 

                To summarize the epidemiology related with

 

                                                                31

 

      constipation quite briefly, chronic constipation

 

      is, indeed, common in the general population.

 

      Again, not all of these individuals come to see us.

 

      Approximately 25 percent actually seek physician

 

      care.  In data I have not presented, it is slightly

 

      more common in women than it is in men.  The female

 

      to male ratio ranges from 1.3 to 2.5.  Importantly,

 

      constipation affects all age groups.

 

                Now, how does this really reflect with

 

      what I see in my clinical practice?  In my clinical

 

      practice generally I see females.  Now, this may be

 

      because I am a female gastroenterologist, that is

 

      the obvious.  However, when I discuss this with my

 

      male colleagues they tell me that they too are

 

      seeing predominantly women that come to see them

 

      for chronic constipation.  Most of my patients have

 

      been symptomatic for many years, typically over 10

 

      years.  The majority have tried life style changes.

 

      They have tried fiber.  They have used

 

      over-the-counter laxatives prior to even seeking

 

      initial care from their primary care physicians.

 

      Most of them manage their constipation with

 

                                                                32

 

      combinations of these, a combination of fiber and

 

      laxatives.  The patients that come to me in my

 

      practice are predominantly referred to me by

 

      primary care physicians and I am also going to see

 

      patients that come from other gastroenterologists.

 

                Again, I really like my patient population

 

      and I like taking care of patients with functional

 

      bowel disorders.  These are not all crazy patients

 

      as I know some gastroenterologists think.  They

 

      actually cope reasonably well with their condition,

 

      however, they are not completely satisfied and they

 

      are looking for something a little bit better.

 

                So, what is the impact of this condition?

 

      Is it just kind of a minor annoyance to my

 

      patients?  I would like to present some data

 

      related to the impact this condition has in

 

      patients.  First I would like to take a look at

 

      quality of life.  There haven't been that many

 

      studies.  I will present three of the four studies

 

      I am aware of.

 

                In Olmstead County, Minnesota, individuals

 

      with chronic constipation reported a significant

 

                                                                33

 

      impact in quality of life with reduced SF-36

 

      scores.  Similarly, in Canada, people who have

 

      either self-reported or Rome II constipation also

 

      had worse SF-36 scores compared to the normal

 

      population.  In Australia, people with constipation

 

      had significantly worse SF-12 scores on both the

 

      mental and the physical components.  So, there is

 

      certainly an impact on these individuals' quality

 

      of life.

 

                Not only does chronic constipation impact

 

      quality of life, but it is also associated with

 

      increased healthcare utilization.  In this next

 

      slide we see that 5.7 million constipation-related

 

      outpatient visits do occur annually; 4.1 million of

 

      these are physician office-based visits.  However,

 

      there are 991,000 emergency room visits and 587,000

 

      hospital outpatient visits each year.

 

                The cost is a little bit difficult to get

 

      at as it relates to how expensive is this

 

      condition.  The one study that I found was from

 

      1997, a study by Rantis and colleagues, who found

 

      in patients who had been referred for tertiary care

 

                                                                34

 

      evaluation had costs for additional testing on the

 

      average of $2,752.  Again, in 2004 dollars I am

 

      sure that may be a bit more.  But the point is

 

      really that this disorder does have an impact both

 

      from a quality of life and from a healthcare

 

      utilization perspective.

 

                So, if this is affecting my patients'

 

      lives I would like to be able to treat them

 

      appropriately, and my goal of therapy is that I

 

      would like to be able to improve GI function in

 

      order to obtain relief of the key symptoms that my

 

      patients are bringing to me, and we have reviewed

 

      what these symptoms are.

 

                Well, what do we have available in order

 

      to do this?  Certainly we have fiber; laxatives, be

 

      they osmotic or stimulant laxatives.  We can use

 

      enemas or suppositories and we do have some

 

      miscellaneous agents that we use.  We can use a

 

      cholinergic agonist, such as bethanchol.  I don't

 

      think too many of the gastroenterologists have used

 

      that actually for treatment of constipation but it

 

      is available for us and we have used it in the

 

                                                                35

 

      past.  We may use a prostaglandin analog called

 

      misoprostil and we have also used

 

      colchicine--again, certainly not ideal agents but

 

      they are things that we do have available for us.

 

                Well, there are some challenges with these

 

      agents.  My patients tell me that they really

 

      aren't consistently getting relief.  There is a

 

      variable treatment response.  Importantly, for the

 

      constellation of constipation symptoms that we see

 

      the efficacy really has not been evaluated or

 

      demonstrated for most of these agents.

 

      Importantly, chronic constipation is just that, it

 

      is a chronic problem and most agents are indicated

 

      for less than or equal to 2 weeks of therapy.  I

 

      would certainly like to be able to offer my

 

      patients something on an ongoing basis.

 

                There are other limitations associated

 

      with these agents.  First is the worsening of some

 

      of the constipation symptoms that I am actually

 

      trying to treat.  I mean, who among us has not

 

      given fiber to patients only to have them come back

 

      a week or two later complaining of increased

 

                                                                36

 

      bloating and gas?  Likewise, these agents can also

 

      cause cramping, abdominal pain or colicky stools.

 

      Fortunately, complications are not common with the

 

      treatments that I use for treating constipation.  I

 

      do worry in some patients should they develop

 

      severe diarrhea which can result in hypovolemia or

 

      electrolyte disturbance.  Metabolic disturbances

 

      can occur, such as hypokalemia or hypomagnesemia

 

      depending on the agent I may have used.

 

                There are also other adverse effects

 

      which, fortunately, also are not too common.  We

 

      can see interference with concomitant drug

 

      absorption.  For instance, some laxatives when

 

      given with cipro may result in poor absorption of

 

      that medication or with theophylline.

 

                I am not too concerned about the

 

      structural changes that may occur in the gut

 

      mucosa, things such as melanosis coli or the abuse

 

      potential or dependency, although I can tell you my

 

      patients and many physicians do consider these to

 

      be obstacles to use of many of the agents that are

 

      currently available.  My patients certainly tell me

 

                                                                37

 

      that there is diminished therapeutic effect that

 

      they see that occurs over time when using these

 

      agents, causing them to have to escalate the drug

 

      usage and often with additional side effects

 

      associated with this.

 

                I am talking to my patients not being

 

      satisfied, and can I get at is there truly a

 

      quantitative effect that tells me how satisfied are

 

      patients or physicians with these therapies?  Well,

 

      there really isn't much out there.  Fortunately, a

 

      colleague of mine, Dr. Larry Schiller, has shared

 

      with me an abstract that he has submitted to The

 

      American College of Gastroenterology.  This is an

 

      Internet-based study that was done, and a group of

 

      physicians were asked are your patients completely

 

      satisfied with treatments for constipation?  The

 

      physicians overwhelmingly, 82 percent, said no, my

 

      patients are not completely satisfied.

 

                If you take a look at the box on the

 

      right, the reasons for dissatisfaction included

 

      lack of efficacy, 93 percent; safety or side

 

      effects, 57 percent; or other reasons such as taste

 

                                                                38

 

      or compliance in 27 percent.  In this group of

 

      physicians, 60 percent of physicians agreed that

 

      they do not have adequate products for treating

 

      their patients with chronic constipation, and 90

 

      percent of these physicians wanted better treatment

 

      options.  Physicians cited frustration with the

 

      current treatments as one of the top 3 reasons

 

      patients state for seeking care for their

 

      condition.

 

                Another study, a population-based study,

 

      also Internet based, took a look at patients who

 

      had seen a physician for constipation within the

 

      past year.  In this group of 557 patients, they

 

      were asked are you completely satisfied with your

 

      treatment for constipation?  Nearly half said no,

 

      they were not completely satisfied.  So, again,

 

      these are patients that have seen a physician

 

      within the past year that were obtained through a

 

      national database survey.  The reasons for

 

      dissatisfaction included efficacy, similar to the

 

      physicians, in 82 percent.  Patients weren't quite

 

      as concerned as physicians were about safety or

 

                                                                39

 

      side effects but still an important concern of

 

      theirs in 16 percent.  Other reasons, such as taste

 

      or not wanting to take the agents regularly, in 17

 

      percent.

 

                At the bottom of the slide we see two

 

      other references, one from Irvine and one from

 

      Ferrzzi.  These data support the findings that they

 

      found in their studies related to patient concerns

 

      regarding the currently available treatments for

 

      constipation.

 

                In conclusion, chronic constipation, in my

 

      opinion, is a condition that is truly in need of a

 

      better approach.  Constipation is characterized by

 

      a constellation of symptoms and we need to

 

      recognize what the symptoms are that our patients

 

      bring to us as being most important, including the

 

      complaints of straining and incomplete evacuation.

 

      Certainly, we want to remember frequency but this

 

      is not our patients' primary concern.  Chronic

 

      constipation is associated with high resource

 

      utilization and does have a significant negative

 

      impact on our patients' quality of life.  The

 

                                                                40

 

      current pharmacologic agents have some limitations

 

      and many patients and their physicians are not

 

      completely satisfied with the available therapies.

 

      I truly believe that better treatment options are

 

      needed for this condition.

 

                Thank you for allowing me to share with

 

      you today my thoughts about chronic constipation.

 

      This is obviously a topic of great importance to me

 

      and to my patients.  I am looking forward to

 

      hearing more from the other speakers today what I

 

      am sure will be a very lively and interesting

 

      discussion.

 

                    Zelnorm: Efficacy and Safety in

 

                          Chronic Constipation

 

                DR. DENNIS:  Thank you, Dr. Prather.  Dr.

 

      Fogel, members of the advisory committee, FDA

 

      representatives, ladies and gentlemen, good

 

      morning.  My name is Eslie Dennis and I am one of

 

      the senior medical directors for gastroenterology

 

      at Novartis Pharmaceuticals.  I am delighted to be

 

      here today to be able to share with you our chronic

 

      constipation program, and I thank you for the

 

                                                                41

 

      opportunity to do so.

 

                Over the next 30 minutes I will provide

 

      you with our rationale for studying patients with

 

      chronic constipation.  I will then highlight the

 

      study objectives of our Phase 3 program, walk you

 

      through the study design, and provide more

 

      specifics around the patient population that was

 

      studied.  Then I will present the efficacy data

 

      from our primary and secondary endpoints and,

 

      finally, the safety data for the 12-week

 

      double-blind, placebo-controlled studies and the

 

      safety data from the 13-month blinded extension

 

      study.

 

                Zelnorm is a 5-HT                                              

                             4 receptor partial

 

      agonist.  It is representative of a new class, the

 

      aminoguanidine indole, and it was designed

 

      specifically to act at 5-HT                                              

                             4 receptors in the GI

 

      tract.  The molecular structure of Zelnorm is based

 

      on serotonin which we know plays a crucial role in

 

      the normal functioning of the GI tract.  We also

 

      know that the action of serotonin at 5-HT                                

                                                                  4

 

      receptors is prokinetic.

 

                                                                42

 

                Our mechanism of action and preclinical

 

      data have demonstrated that tegaserod is, indeed, a

 

      promotility agent.  Tegaserod has been shown to

 

      augment peristalsis, thereby enhancing gut motility

 

      and decreasing transit time.  Furthermore, animal

 

      studies have shown that tegaserod increases

 

      chloride and water secretion which would improve

 

      stool consistency independent of the promotile

 

      effect of the drug.  In addition, we have the data

 

      from our IBS with constipation studies that confirm

 

      the significant improvement with Zelnorm compared

 

      to placebo on stool frequency, stool consistency

 

      and straining--all important benefits when treating

 

      chronic constipation.

 

                On the basis of our IBS with constipation

 

      studies, we felt that we could proceed directly to

 

      Phase 2 trials in chronic constipation without a

 

      formal Phase 2 program, and that we would use the

 

      same doses that were tested in our IBS-C Phase 3

 

      trials.

 

                Let me now walk you through the Phase 3

 

      chronic constipation program.  The study objectives

 

                                                                43

 

      were to evaluate the efficacy, tolerability and

 

      safety of 2 doses of Zelnorm, 2 mg BID and 6 mg

 

      BID, compared to placebo over a 12-week treatment

 

      period in patients with chronic constipation.

 

                We had 2 large randomized, double-blind,

 

      placebo-controlled clinical trials in our program.

 

      Study 2301 was conducted in 128 centers in 16

 

      countries in Europe and in Australia and South

 

      Africa.  The design consisted of a 2-week baseline

 

      period, followed by a 12-week treatment period with

 

      either Zelnorm 2 mg BID, 6 mg BID or placebo.

 

                One thousand, two hundred and sixty-four

 

      patients were randomized.  We chose the time line

 

      of 12 weeks of treatment for the core studies in

 

      keeping with the Rome committee guidelines

 

      regarding duration of clinical studies in

 

      functional bowel diseases for chronic therapies.

 

      The 2 doses of Zelnorm and the BID regimen were

 

      based on our experience with the previous

 

      dose-ranging and Phase 3 studies that were

 

      conducted in IBS-C patients.

 

                The initial 12-week treatment period was

 

                                                                44

 

      then followed by an optional 13-month extension

 

      period.  This extension period was double-blinded

 

      but there was no placebo arm.  So, patients who had

 

      received Zelnorm 2 mg BID or 6 mg BID remained on

 

      these doses and patients who had received placebo

 

      then received Zelnorm 6 mg BID in the extension,

 

      and 842 patients entered the extension study.

 

                The primary aim of the extension study was

 

      to provide long-term safety data for the 2 doses of

 

      Zelnorm.  Study 2302 was conducted in 105 centers

 

      in 7 countries in North and South America.  The

 

      study design was very similar, with a 2-week

 

      baseline period and a 12-week treatment period.

 

      However, in this study the 12-week treatment period

 

      was followed by a 4-week drug-free withdrawal

 

      phase.  A similar number of patients were

 

      randomized, 1,348.

 

                Patient inclusion and several of the

 

      endpoints, including the primary endpoint, were

 

      based on the number of complete, spontaneous bowel

 

      movements of CSBMs.  Let me clarify this

 

      terminology that we have used.  BMs refer to all

 

                                                                45

 

      bowel movements.  SBMs refer to spontaneous bowel

 

      movements.  Spontaneous means a non-laxative

 

      induced stool, in other words, no laxative or enema

 

      in the preceding 24 hours.  These can be stools

 

      with either complete evacuation or incomplete

 

      evacuation.  CSBMs refer to complete spontaneous

 

      bowel movements.  Complete is a subjective

 

      definition of a bowel movement that results in a

 

      sensation of complete evacuation.  We know that

 

      there are constipated patients out there who have

 

      more than 3 bowel movements a week but these are

 

      often small amounts of hard and lumpy stools with

 

      straining and incomplete evacuation, and these are

 

      patients that are not satisfied with the quality of

 

      their bowel movements.  So, complete spontaneous

 

      bowel movement captures the quality of a bowel

 

      movement that is not laxative induced and is a

 

      measure of both the quality and frequency.  We felt

 

      that this endpoint best captured what patients

 

      complain of, based on expert opinion and the

 

      published literature.

 

                A recent state-of-the-art review on

 

                                                                46

 

      chronic constipation in The New England Journal of

 

      Medicine referred to the large study that Dr.

 

      Prather has shown you, stating that constipation

 

      had been identified in this study as an inability

 

      to evacuate stool completely and spontaneously 3 or

 

      more times a week.

 

                Given that there is no recognized gold

 

      standard for endpoints in chronic constipation, it

 

      seemed very reasonable to use the SCBM endpoint as

 

      our primary endpoint.  In fact, this is a more

 

      stringent endpoint than using just bowel movements

 

      alone.  However, we recognize that different

 

      experts might request different analyses and

 

      different endpoints and so we defined a priori a

 

      number of secondary endpoints representing the

 

      multiple symptoms of chronic constipation that I

 

      will also be presenting to you today.

 

                We included males and females over the age

 

      of 18 years with chronic constipation.  Chronic was

 

      defined as at least 6 months of consistent

 

      symptoms.  Constipation was defined as less than 3

 

      complete, spontaneous bowel movements per week and

 

                                                                47

 

      one or more of the following 25 percent of the

 

      time, very hard or hard stools, sensation of

 

      incomplete evacuation, or straining at defecation.

 

      These criteria were based on the well-established

 

      Rome criteria.

 

                Patients were also required to have had a

 

      normal endoscopic of radiological evaluation of the

 

      bowel within the past 5 years and after the onset

 

      of symptoms.  In addition, there had to be no

 

      history or evidence of alarm features such as

 

      weight loss, rectal bleeding or anemia since the

 

      evaluation was performed.

 

                Patients were excluded if they had

 

      constipation for which the cause was known, in

 

      other words, secondary constipation as you can see

 

      listed on the slide.  So, we studied patients with

 

      chronic constipation of unknown cause.  In

 

      addition, patients on concomitant medications that

 

      could affect GI transit were excluded, as well as

 

      patients with fecal impaction requiring surgical or

 

      manual intervention.  These criteria were excluded

 

      based on a comprehensive history, thorough physical

 

                                                                48

 

      examination, as well as baseline ECG and laboratory

 

      assessments.

 

                At the end of a 2-week baseline period and

 

      just prior to randomization additional exclusion

 

      criteria were applied.  Patients were excluded if

 

      constipation could not be confirmed by the number

 

      of CSBMs, straining and/or very hard or hard stools

 

      recorded in daily diaries.  They were also excluded

 

      if they had loose or watery stools for more than 3

 

      of the 14 days and if they used laxatives outside

 

      of the guidelines for more than 2 of the 14 days.

 

      Patients were deemed to be non-compliant with diary

 

      completion if they entered less than 11 days in the

 

      daily diary and were subsequently also excluded.

 

                On a daily basis we assessed a number of

 

      parameters related to bowel habits--straining,

 

      stool frequency, stool form that we measured using

 

      the Bristol Stool Scale, and whether evacuation was

 

      complete or incomplete.  Patients were required to

 

      collect this data for each individual bowel

 

      movement, and we determined which bowel movement

 

      was spontaneous based on the daily diary data

 

                                                                49

 

      reflecting the time of administration of any rescue

 

      laxatives.

 

                On a weekly basis we asked about

 

      satisfaction with bowel habits, as well as

 

      bothersomeness of constipation, bothersomeness of a

 

      bowel movement distention or bloating and

 

      bothersomeness of abdominal discomfort or pain.

 

                Let's look at the patient disposition.

 

      Over 80 percent of randomized patients completed

 

      the study, with fewer than 20 percent

 

      discontinuations.  The most common reason for

 

      discontinuation was for unsatisfactory therapeutic

 

      effect, with the largest percentage being in the

 

      placebo group, as we might expect.  Adverse events

 

      accounted for similar numbers of discontinuations

 

      in the placebo and Zelnorm 2 mg BID groups, with a

 

      slightly higher percentage in the 6 mg BID group

 

      which was not statistically significant.  The

 

      pattern of disposition was similar in the 2 trials.

 

                Let's look at the results, starting with

 

      the demographic data.  These were very similar

 

      between the two studies.  The vast majority of

 

                                                                50

 

      patients, 86 and 90 percent, were female.  The mean

 

      age was 46 and 47 years, with a similar age range,

 

      from 18-88 years.  Fourteen percent and 12 percent

 

      were 65 years or older, and just under half the

 

      female population was postmenopausal.  The vast

 

      majority were Caucasian, more so in the European

 

      study.

 

                Patients were required to have had at

 

      least a 6-month history of constipation symptoms.

 

      As you can see, the mean duration of symptoms was

 

      considerably longer, 14.7 and 19.5 years.

 

                The means of the characteristics of bowel

 

      habit by history and during the 14-day baseline

 

      period are shown on the slide here.  However, as

 

      these baseline parameters would not be normally

 

      distributed in a constipated population it may be

 

      more relevant to look at median data at baseline.

 

      When we do so, we see from the history the duration

 

      of symptoms was 10 and 15 years, with hard or very

 

      hard stools 90 percent of the time and a median

 

      number of one SBM per week.  Now, in clinical

 

      practice the Rome criteria are applied to the

 

                                                                51

 

      history to make a diagnosis of chronic

 

      constipation.

 

                From the baseline diary data we see that

 

      the median number of CSBMs was zero and SBMs 2.5

 

      and 2.9.  So, these patients fulfilled the

 

      inclusion criteria of having less than 3 CSBMs per

 

      week.  In fact, they had less than 3 SBMs per week

 

      by history and by baseline median data.  In

 

      addition, the number of SBMs with straining per

 

      week was 2.0 and 2.5 so the majority of spontaneous

 

      bowel movements were associated with straining.

 

      This confirms that the patient population was,

 

      indeed, constipated and, indeed, had chronic

 

      constipation.

 

                I have outlined the study design, the

 

      patient population, demographics and the baseline

 

      characteristics.  Now let's look at the primary

 

      efficacy variable.  For this endpoint we defined a

 

      responder as having an increase of at least one

 

      complete spontaneous bowel movement per week on

 

      average during the first 4 weeks of the treatment

 

      compared to the 2 weeks at baseline.  They had to

 

                                                                52

 

      have had at least 7 days of treatment.

 

                The results were positive.  In study 2301

 

      the responder rates for Zelnorm were 35.6 percent

 

      for 2 mg BID, 40.2 percent for 6 mg BID compared to

 

      26.7 percent for placebo.

 

                In study 2302 the responder rates were

 

      41.4 percent with 2 mg, 43.2 percent with 6 mg BID

 

      compared to 25.1 percent on placebo.  The p values

 

      were significant.  The 6 mg BID dose was

 

      consistently more efficacious, with deltas of 13.5

 

      percent and 18.1 percent for the 2 studies.

 

                Now, in order to confirm sustained

 

      efficacy of Zelnorm we analyzed those patients with

 

      an increase of at least one complete spontaneous

 

      bowel movement per week on average over the entire

 

      12-week trial duration, compared to the baseline

 

      period of 2 weeks.

 

                Again the results were positive and

 

      consistent with the results for the primary

 

      efficacy variable.  A treatment effect for the 6 mg

 

      BID dose over placebo of 13 and 18 percentage

 

      points for the 2 trials respectively was

 

                                                                53

 

      demonstrated.

 

                When we look at weekly responder rates

 

      using this responder definition, we can see that

 

      the effect of Zelnorm is seen early, within the

 

      first week, and is sustained throughout the entire

 

      treatment period.  In study 2302 we can see that

 

      the treatment effect is lost once the drug is

 

      withdrawn.  The percentage of responders in both

 

      Zelnorm groups reached the level of placebo within

 

      2 weeks after termination of treatment.  The

 

      results with the 6 mg BID dose are consistently

 

      superior to placebo, and here I am showing you the

 

      data for this dose alone so that you can more

 

      clearly see the benefit.

 

                When we look at the number of CSBMs, there

 

      is a marked increase within the first week of

 

      treatment with a significant improvement over

 

      placebo.  The number of CSBMs decreased on

 

      withdrawal of the drug, approaching but not

 

      reaching the level observed during the baseline

 

      period.  There was no rebound effect demonstrated.

 

      The effect was again more consistent with the  6 mg

 

                                                                54

 

      BID dose, which you can see more clearly on this

 

      slide.

 

                In order to further assess the benefit of

 

      Zelnorm, we conducted analyses on other

 

      constipation assessments which we defined a priori.

 

      Let me share these results with you.  Let's start

 

      with satisfaction with bowel habits.  Now, this is

 

      an important endpoint and an important measure of

 

      clinically relevant benefit.  The Rome committee

 

      has advocated the use of global endpoints and

 

      satisfaction really is a composite subjective

 

      assessment by the patient.  We asked the question

 

      how satisfied were you with your bowel habits over

 

      the past week?  We used a 5-point ordinal scale,

 

      with zero being a very great deal satisfied and 4

 

      being not at all satisfied.  So, improvement was

 

      represented by a decrease in the satisfaction

 

      score.

 

                Here we defined a responder as having a

 

      mean decrease of 1 or more on the 5-point scale

 

      over 12 weeks compared to baseline.  We

 

      subsequently have validated this data relating

 

                                                                55

 

      satisfaction scores to a relative shift in

 

      distribution, and we have looked at baseline

 

      standard deviations and week 12 standard deviations

 

      and a 1-point change on this score is associated

 

      with significant effect sizes.  We saw significant

 

      superiority of both doses of Zelnorm compared to

 

      placebo in this satisfaction endpoint.

 

                Stool form is another important marker of

 

      constipation, and also showed significant

 

      improvement

 

      on Zelnorm.  Stool form was 2.5 and 2.8 at baseline

 

      in the 2 studies respectively and on treatment with

 

      Zelnorm.  On treatment with Zelnorm this was

 

      maintained at around a score of 3.5 on the Bristol

 

      Stool Scale.

 

                On this slide you can see the change from

 

      baseline in stool form, which showed significant

 

      benefit over placebo for nearly all weeks.  Again,

 

      we can see the loss of benefit during the

 

      withdrawal period.

 

                What about straining, yet another

 

      important symptom of constipation?  For each bowel

 

                                                                56

 

      movement we asked the question did you have any

 

      straining?  This was a 3-point scale and the

 

      possible responses were zero, no straining; 1,

 

      acceptable straining; and 2, too much straining.

 

      We did not capture straining in the absence of a

 

      bowel movement.  We subsequently analyzed straining

 

      scores for spontaneous bowel movements and saw

 

      significant improvement on Zelnorm compared to

 

      placebo which was consistent over time, as we saw

 

      with the other variables.

 

                Now, what about the bothersomeness

 

      questions?  On a weekly basis patients were asked

 

      to evaluate the bothersomeness of constipation.

 

      Now, this is a global assessment in keeping with

 

      the global satisfaction assessment.

 

                In addition, we looked at the

 

      bothersomeness of a bowel movement bloating and

 

      distention and bothersomeness of abdominal

 

      discomfort.  As you heard from Dr. Prather earlier,

 

      patients with chronic constipation can present with

 

      bloating and abdominal discomfort, and we can see

 

      significant improvement in the bothersomeness of

 

                                                                57

 

      constipation on Zelnorm for both doses in both

 

      studies.  For abdominal bloating and distention and

 

      abdominal discomfort and pain we saw improvement in

 

      these symptoms in both studies, reaching

 

      statistical significance for the 2 doses in study

 

      2302.

 

                As you also heard from Dr. Prather, many

 

      of the currently available therapies for

 

      constipation in fact aggravate the symptoms of

 

      abdominal bloating and abdominal discomfort so this

 

      is another important benefit of Zelnorm.

 

                So, I have presented several secondary

 

      endpoints.  Now the question we asked ourselves was

 

      is there an association between responders for the

 

      primary endpoint and responders for the secondary

 

      efficacy variables.  Well, as you can see on this

 

      slide, there is a strong positive association

 

      between responders for the primary endpoint and

 

      response to secondary variables.  Remember, the

 

      primary responder definition was an increase of at

 

      least one CSBM per week compared to baseline over

 

      the first 4 weeks of the treatment.

 

                                                                58

 

                Improvement on stool form is represented

 

      by a positive increase, while improvement on the

 

      other variables is represented by a decrease in

 

      scores.  You can see the clear-cut difference

 

      between responders and non-responders, which is

 

      significant for each endpoint, which supports the

 

      CSBM primary endpoint.

 

                Now I will walk you through some of the

 

      additional analyses that were done.  In discussions

 

      with the FDA early last year, some other responder

 

      analyses were requested prior to database lock.

 

      One of these define a responder was having at least

 

      3 CSBMs per week for the first 4 weeks of the

 

      study.

 

                Now, this was a fixed definition with no

 

      comparison to baseline, and this was a high hurdle

 

      to achieve considering that the patient population

 

      had a median number of CSBMs of zero and a mean

 

      number of CSBMs of 0.5 at baseline.  So, reaching a

 

      level of greater than or equal to 3 CSBMs per week

 

      represents on average a 6-fold increase required to

 

      meet this responder definition.  As you can see

 

                                                                59

 

      though, Zelnorm was significantly better than

 

      placebo.  Both doses in both studies were

 

      significant, with deltas of 9 percent for the 6 mg

 

      BID dose in the 2 studies.  We saw similar results

 

      using this responder definition over the 12-week

 

      treatment period, with deltas of 9 and 11 percent

 

      for the 6 mg BID dose.

 

                So, we have demonstrated significant

 

      benefit of Zelnorm compared to placebo for our

 

      primary endpoint, and we have demonstrated

 

      significant benefit of Zelnorm compared to placebo

 

      in these analyses that were requested by the FDA.

 

                Let us now look at the effect of the

 

      number of bowel movements at baseline on response.

 

      Now, bearing in mind that we used the concept of

 

      complete spontaneous bowel movements, which is a

 

      relatively new concept, we wanted to see if

 

      baseline number of bowel movements, and that is

 

      all-comers, would affect our primary efficacy

 

      variable.

 

                So, we looked at patients who had less

 

      than 3 bowel movements per week at baseline.  What

 

                                                                60

 

      you can see is that Zelnorm is equally effective in

 

      the group that has less than 3 bowel movements per

 

      week as it is in the group that has more than 3

 

      bowel movements per week at baseline.

 

                We also did various subgroup analyses.

 

      These were planned prospectively but we did not

 

      attempt to meet a minimum number of patients in any

 

      subgroup.  Subsequently, some of these groups had

 

      very few subjects and this is reflected in the wide

 

      confidence intervals.  It is important to remember

 

      that the purpose of subgroup analyses is not to

 

      demonstrate efficacy as these analyses are not

 

      powered to detect statistical significance.  The

 

      purpose of subgroup analyses is to ensure that the

 

      effect in any subgroup is consistent with the

 

      overall effect and that we are not seeing any

 

      negative trends.

 

                Here I am showing you the data for the 6

 

      mg BID dose, and we can see the positive odds

 

      ratios for almost all the subjects that we

 

      analyzed.  In the group 65 years and older there

 

      was a total of 88 patients in the 6 mg BID group

 

                                                                61

 

      and 117 patients in the placebo group, with an odds

 

      ratio of 1 for the overall population.

 

                For the male patients, there were 106 on 6

 

      mg BID and 93 on placebo.  The odds ratio was

 

      positive at 1.36, and improvement on Zelnorm was

 

      seen for most variables in men.

 

                One of the issues I want to address now is

 

      the question how many of these patients in this

 

      chronic constipation program were, in fact, IBS

 

      patients, and did this have an effect on our

 

      results.  We did not actively exclude IBS patients

 

      from the study but when we went back to the patient

 

      history only 4 percent of patients had a diagnosis

 

      of IBS in their history.

 

                As we did not administer the Rome

 

      questionnaire for IBS, we decided to take a

 

      conservative approach to try and identify patients

 

      that we thought may be potentially IBS-like.  So,

 

      we identified all patients in whom abdominal pain

 

      was the main complaint at baseline, and this was

 

      about 12 percent of our patients.  In addition, we

 

      included patients who had abdominal pain that may

 

                                                                62

 

      not necessarily have been their predominant symptom

 

      but they also had diarrhea together with this

 

      abdominal pain.  So, criteria (a) and (b) on this

 

      slide come from the history and criteria (c) comes

 

      from the baseline diary data.

 

                We came up with a total of 22 percent of

 

      our patients as possibly having IBS.  These were

 

      equally represented in the 3 treatment arms.  So,

 

      we felt confident that almost 80 percent of our

 

      patients were, indeed, chronic constipation

 

      patients and did not have IBS.  However, we were

 

      interested to see what the efficacy results would

 

      look like if we excluded those patients who were

 

      IBS-like.

 

                Here is the pooled data.  In this group,

 

      without IS-like features, in other words, the pure

 

      chronic constipation population, you can clearly

 

      see the benefit of Zelnorm with improvement over

 

      placebo of 40 percent in the 2 mg BID group and 18

 

      percent in the 6 mg BID group.  We can compare this

 

      to the deltas in the pooled ITT primary efficacy

 

      analysis in which there was a 13 percent delta in

 

                                                                63

 

      the 2 mg BID group and 16 percent delta in the 6 mg

 

      BID group.  So, in this pooled subgroup analysis

 

      the results in the pure chronic constipation group

 

      are even more robust than in the ITT analysis.

 

                So, I have presented data here that

 

      demonstrate the efficacy of Zelnorm in patients

 

      with chronic constipation.  The onset of action is

 

      early.  The effect is sustained, and there is no

 

      rebound phenomenon.

 

                We have measured the efficacy of Zelnorm

 

      using a number of parameters and Zelnorm is

 

      efficacious for multiple symptoms of chronic

 

      constipation which include straining, hard stools

 

      and infrequent stools, with overall improved

 

      satisfaction.  The 6 mg BIT dose has emerged as

 

      consistently more efficacious than the 2 mg BID

 

      dose.

 

                Now let's look at the safety data.  I am

 

      going to go through the 12-week data looking at

 

      exposure, adverse event profile, serious adverse

 

      events, and laboratory evaluations, and then the

 

      long-term safety profile from the extension study. 

 

                                                                64

 

      This was a 13-month extension study, providing a

 

      total of 16 months of data for the groups that

 

      received Zelnorm in the core study.

 

                Let's start with overall exposure.  The

 

      intended study duration was 84 days.  Exposure was

 

      comparable across all treatment groups.  The mean

 

      duration of treatment was 80 days, and 84 percent

 

      of patients completed at least 11 weeks of

 

      treatment and 69 percent had more than 85 days of

 

      exposure in this 12-week period.  The total number

 

      of patients who experienced any adverse event was

 

      60 percent in the placebo group, 57 percent in the

 

      6 mg BID group and 56 percent in the 2 mg BID

 

      group.  The most frequent adverse events were

 

      headache, nasopharyngitis , diarrhea, abdominal

 

      pain and nausea.  The only notable adverse event

 

      seen more frequently with Zelnorm was diarrhea, as

 

      you would expect given the pharmacodynamic action

 

      of this drug.

 

                When we look at the most frequent adverse

 

      events leading to discontinuation, we see abdominal

 

      pain, diarrhea, abdominal distension, nausea and

 

                                                                65

 

      headache.  On this table we have included all

 

      discontinuations in which there were at least 5

 

      patients on any dose of Zelnorm.  Overall, the only

 

      one where discontinuations appeared to be

 

      dose-dependent was diarrhea, with a discontinuation

 

      rate of less than 1.0 percent on the 6 mg BID dose

 

      and 0.3 percent for the 2 mg BID dose.

 

                Let's look at the diarrhea in more

 

      detail--4.2 percent with the 2 mg BID dose, 6.6

 

      percent with the 6 mg BID dose versus 3 percent

 

      with placebo.  Over 80 percent of patients who

 

      experienced diarrhea had only a single episode, and

 

      the median duration of the first episode was about

 

      2 days.  Most diarrhea occurred on the first day of

 

      treatment.

 

                When we look at the characteristics of the

 

      stool on the first day of diarrhea, the median

 

      number of bowel movements was 3 in the placebo

 

      group, 2 on Zelnorm 2 mg BID and 3 in the mg BID

 

      group.  The median stool form was essentially

 

      similar across all treatment groups at 5.7 for

 

      placebo and 6 and 6.3 for the 2 Zelnorm doses

 

                                                                66

 

      respectively.

 

                Most patients who had diarrhea continued

 

      on their medication and took no action.  There were

 

      more patients on 6 mg BID who adjusted their dose

 

      or temporarily interrupted therapy but there were

 

      very few patients who discontinued permanently

 

      because of diarrhea.  None of these cases met the

 

      definition of a serious adverse event or the

 

      definition of clinically significant consequences

 

      of diarrhea such as hypovolemia, hypokalemia or the

 

      need for IV fluids or electrolyte replacement.

 

                Let's look at serious adverse events.

 

      Incidence rates were comparable across all

 

      treatment groups.  There were very few

 

      discontinuations due to these serious adverse

 

      events.  There were no deaths during the course of

 

      the study but there was one death 67 days after the

 

      last dose of study medication in study 2302.  This

 

      was an 85 year-old man who had been on Zelnorm 2 mg

 

      BID.  He died from respiratory failure and

 

      mesothelioma secondary to preexisting asbestosis.

 

                We also evaluated a number of laboratory

 

                                                                67

 

      parameters.  There was a low frequency of notable

 

      abnormalities which were essentially similar across

 

      all treatment groups.

 

                The incidence of any abdominal or pelvic

 

      surgeries in the Zelnorm-treated group was lower

 

      than in the placebo group.  One patient in study

 

      2302, on Zelnorm 6 mg BID, had a cholecystectomy.

 

      The investigator assessed the event as not related

 

      to study medication.  The incidence of other

 

      surgeries was well balanced between Zelnorm and

 

      placebo.

 

                Now let's look at the 13-month extension

 

      study, and 842 patients entered the extension

 

      phase.  And, 61.7 percent were exposed to at least

 

      12 months of Zelnorm; 46 percent of patients

 

      discontinued over the 13 months.  Most

 

      discontinuations were for unsatisfactory

 

      therapeutic responses, with very few

 

      discontinuations for adverse events.  The same

 

      adverse events predominated as during the core

 

      period.  Frequencies followed the same pattern as

 

      seen in the core studies, although the incidence

 

                                                                68

 

      rates were generally higher due to the longer

 

      duration of exposure.  No relevant differences were

 

      seen in the rates between the 2 doses of Zelnorm.

 

      There were no deaths in the 13-month extension.

 

                So, to summarize our safety conclusions,

 

      the incidence of adverse events on Zelnorm in

 

      chronic constipation is similar to placebo, except

 

      for diarrhea, which is what we would expect from

 

      the pharmacodynamic profile.  There were low

 

      discontinuation rates due to adverse events.  The

 

      long-term safety profile was similar to the profile

 

      in the core 12-week studies.  Zelnorm, therefore,

 

      as been demonstrated to be safe and well tolerated

 

      in patients with chronic constipation.

 

                What are our final overall conclusions?

 

      Zelnorm is effective in the treatment of multiple

 

      symptoms of chronic constipation, with the 6 mg BID

 

      dose consistently more efficacious than the 2 mg

 

      BID dose.  Zelnorm improves satisfaction with bowel

 

      habits; straining; hard and lumpy stools; and

 

      infrequent bowel movements.  In addition, Zelnorm

 

      has a favorable safety profile.

 

                                                                69

 

                Therefore, we are asking for an approval

 

      for Zelnorm for the treatment of patients with

 

      chronic constipation and relief of associated

 

      symptoms of straining, hard or lumpy stools, and

 

      infrequent defecation.

 

                That concludes my presentation.  Thank you

 

      very much.  I would now like to introduce Dr. Bo

 

      Joelsson, vice president and head of clinical

 

      research and development for gastroenterology, who

 

      will present the general safety overview.  Dr.

 

      Joelsson?

 

                        Zelnorm Safety Overview

 

                DR. JOELSSON:  Good morning, Dr. Fogel,

 

      advisory committee, representatives from the FDA,

 

      ladies and gentlemen.  My name is Bo Joelsson and I

 

      am the head of GI research and development at

 

      Novartis.

 

                Today I will review with you the overall

 

      safety experience with Zelnorm, and demonstrate to

 

      you that Zelnorm is a safe and well-tolerated drug.

 

      This is what I am going to review with you today.

 

      First I will show that the positive safety profile

 

                                                                70

 

      of Zelnorm that was established at the time of

 

      approval in July, 2002 is confirmed in our chronic

 

      constipation clinical program.  Secondly, I will

 

      briefly present a few safety topics that we have

 

      agreed with the FDA to discuss at this meeting:

 

      serious consequences of diarrhea; rectal bleeding;

 

      ischemic colitis and other forms of intestinal

 

      ischemia; biliary tract disorders and ovarian

 

      cysts.  Finally, I will summarize our experience

 

      demonstrating that Zelnorm is a safe and well

 

      tolerated drug.

 

                The three most common adverse events that

 

      were reported at approval in July, 2002 were

 

      headache, abdominal pain and diarrhea, and the

 

      incidence of diarrhea was higher on Zelnorm.

 

                This slide shows that the adverse event

 

      data from the chronic constipation clinical trials

 

      compared favorably to the IBS constipation data.

 

      Headache incidence is similar between the treatment

 

      arms.  Abdominal pain was less common in the

 

      chronic constipation studies than in the IBS

 

      trials, demonstrating that the chronic constipation

 

                                                                71

 

      population is different from the IBS population

 

      which is characterized by abdominal pain.  The

 

      incidence of abdominal pain in Zelnorm and placebo

 

      treated patients indicates that abdominal pain as

 

      an adverse event is not related to Zelnorm

 

      treatment.  As in IBS, the reported incidence of

 

      diarrhea is higher on Zelnorm.  Adverse events

 

      leading to discontinuation are also low in the

 

      chronic constipation clinical trials.

 

                At approval in July, 2002 the incidence of

 

      serious adverse events was low.  This was 1.6

 

      percent on Zelnorm as compared to 1.1 percent on

 

      placebo.  Serious adverse events leading to

 

      discontinuation of study drug were 0.7 percent on

 

      Zelnorm and 0.6 on placebo.

 

                The incidence of serious adverse events in

 

      the chronic constipation clinical trials was

 

      similar to that in the IBS clinical program.  The

 

      incidence of serious adverse events leading to

 

      discontinuation was lower and identical in Zelnorm

 

      and placebo treated patients.

 

                The clinical trial adverse event data

 

                                                                72

 

      collected in chronic constipation clinical program

 

      supports and strengthens the positive safety

 

      profile established at the time of approval.  With

 

      the exception of diarrhea, the Zelnorm safety

 

      profile is similar to that of placebo.

 

                We have at this time experience with use

 

      of Zelnorm both from clinical trials in patients

 

      with IBS, chronic constipation and upper GI

 

      indications, as well as postmarketing clinical use.

 

      In clinical trials more than 15,000 patients have

 

      been included and more than 11,000 subjects have

 

      taken Zelnorm, which corresponds to 3,456

 

      patient-years of Zelnorm experience.  More than

 

      10,000 patients have been involved in controlled

 

      clinical trials and close to 7,000 of them have

 

      been on Zelnorm.

 

                Zelnorm is currently registered in 56

 

      countries worldwide.  It has been available since

 

      January, 2001 and here, in the United States, since

 

      July, 2002.  Approximately 3 million patients have

 

      been treated, 2 million in the United States.  That

 

      corresponds to more than 350,000 patient-years of

 

                                                                73

 

      treatment and more than 230,000 patient-years in

 

      the United States.

 

                We have agreed with the FDA to discuss

 

      several specific safety topics at this advisory

 

      committee meeting.  The first of these is serious

 

      consequences of diarrhea.  Diarrhea is an expected

 

      effect of Zelnorm in some patients due to the

 

      mechanism of action.  The diarrhea is generally

 

      mild, is generally transient and self-limiting, and

 

      rarely leads to serious consequences.

 

                A patient is defined as having a serious

 

      consequence of diarrhea if one or more of the

 

      following took place:  A serious adverse event was

 

      reported as defined by regulatory requirements; if

 

      hypokalemia occurred; if hypovolemia was diagnosed;

 

      if IV fluids were administered; or any medically

 

      significant events related to diarrhea occurred,

 

      such as hypotension, syncope or cardiac effects.

 

                We carefully reviewed our clinical trial

 

      experience of more than 11,000 patients using this

 

      definition in order to identify cases of serious

 

      consequences of diarrhea, and this is our clinical

 

                                                                74

 

      trial experience.  Six cases of serious

 

      consequences of diarrhea were found in the clinical

 

      studies on Zelnorm with more than 11,000 patients.

 

      Four of these patients required hospitalization.

 

      Two received IV fluids.  Two had actually possible

 

      other causes.  One reported gastroenteritis and one

 

      reported antibiotic-induced diarrhea.  All patients

 

      recovered without complications and four of them

 

      were actually able to continue on study medication

 

      after these episodes.

 

                From the postmarketing experience in

 

      approximately 3 million patients, 30 cases have

 

      been reported; 16 were hospitalized; 11 received IV

 

      fluids; 8 exhibited hypotension; 4, syncope; and 4

 

      were considered life-threatening by the reporting

 

      physician; 1 had hypokalemia.  One fatality from

 

      aspiration pneumonia was reported in a patient with

 

      acute pancreatitis and chronic liver cirrhosis.

 

                This demographic information on the 30

 

      patients with serious consequences of diarrhea in

 

      the postmarketing experience.  There was a wide age

 

      spectrum, 18 to 82 years.  The median age was 49

 

                                                                75

 

      years and only 9 patients were older than 65,

 

      indicating that this is not an elderly specific

 

      issue.  As is expected, most were women, reflecting

 

      the label in most countries.  Serious consequences

 

      of diarrhea mostly occurred in patients on 12 mg of

 

      Zelnorm per day but were also reported in some

 

      patients on a lower dose.

 

                In clinical trials diarrhea usually

 

      occurred during the first days of treatment, as we

 

      heard before.  This was also true for serious

 

      consequences of diarrhea in the postmarketing

 

      experience.  It occurred within 5 days in all cases

 

      and the median time was 1 day.

 

                In conclusion, serious consequences of

 

      diarrhea are rare in clinical trials and very

 

      rarely reported in the postmarketing experience.

 

      All cases resolved without sequelae.

 

                Rectal bleeding is of special interest

 

      because of its possible relationship with serious

 

      colon conditions.  We have carefully reviewed our

 

      clinical trial data for terms that indicate the

 

      presence of rectal bleeding, such as rectal

 

                                                                76

 

      hemorrhage, melena, hematochezia, etc., etc.  We

 

      found that the presence of rectal bleeding was very

 

      similar in patients on Zelnorm and placebo in our

 

      controlled clinical trials.

 

                From the postmarketing experience of

 

      approximately 3 million patients, 82 cases of

 

      rectal bleeding were reported. Twenty-one were

 

      reported in conjunction with suspected ischemic

 

      colitis; 1 from another form of intestinal

 

      ischemia; 3 from other forms of colitis.  In 23

 

      cases hemorrhoids were a possible source of

 

      bleeding.  The rest of the cases listed on this

 

      slide show varying etiologies.  Fifteen of the

 

      patients were not investigated.

 

                Our clinical trial data indicated a

 

      similar reporting rate in Zelnorm- and

 

      placebo-treated patients.  There are rare reports

 

      of rectal bleeding from postmarketing experience,

 

      which indicates that Zelnorm therapy is not

 

      causally related to the rectal bleeding.

 

                Now, the occurrence of ischemic colitis

 

      and other forms of intestinal ischemia is a concern

 

                                                                77

 

      with drugs used to treat IBS with diarrhea.  These

 

      drugs block the 5-HT                                                     

          3 receptor and, thus, have a

 

      very different mechanism of action than Zelnorm,

 

      which is a 5-HT                                                        4

receptor agonist used to treat IBS

 

      with constipation.  Nonetheless, since these are

 

      potentially serious conditions and Zelnorm affects

 

      the serotonin receptor, it is important to

 

      carefully assess whether Zelnorm therapy could

 

      increase the risk of intestinal ischemia.

 

                Ischemic colitis is a rare condition in

 

      the general population.  When it occurs, it is

 

      potentially serious but is generally mild and

 

      transient.  It is characterized by mucosal erosions

 

      seen at colonoscopy, with rectal bleeding and

 

      abdominal pain being the most common clinical

 

      presentations.  Usually no specific treatment is

 

      needed and surgical intervention is rarely

 

      indicated.

 

                While ischemic colitis is very rare in the

 

      general population, it is more commonly reported in

 

      IBS patients.  In a study from the Medi-Cal claims

 

      database, 179 cases per 100,000 patient-years were

 

                                                                78

 

      found in IBS patients versus 47 cases per 100,000

 

      patient-years in non-IBS patients.  In a study from

 

      the United Health Care claims database, with a

 

      younger patient population, the corresponding

 

      numbers were 43 in IBS patients and 7 in non-IBS

 

      patients.  In the CORI database which collects data

 

      from endoscopy units all over the United States,

 

      ischemic colitis was found in 93 per 100,000

 

      colonoscopies in patients with IBS-like symptoms

 

      while there were 21 cases per 100,000 screening

 

      colonoscopies in asymptomatic individuals.  All of

 

      these cases were endoscopically verified and in

 

      most cases supported by histology.

 

                It has been suggested by Dr. Brinker et

 

      al., from the FDA, that the increased incidence of

 

      ischemic colitis in IBS is the result of

 

      misdiagnosis.  Dr. Brinker published this analysis

 

      from the patients from the United Health Care

 

      study.  He found evidence for misdiagnosis during

 

      the first 3 weeks after IBS diagnosis.  However,

 

      when patients with IBS were followed for more than

 

      a year, he still found an increased rate of

 

                                                                79

 

      ischemic colitis, 53 per 100,000 patient-years.

 

                Thus, ischemic colitis can be misdiagnosed

 

      as IBS during the first weeks of treatment, but

 

      patients with a stable IBS diagnosis for more than

 

      1 year still have an increased risk of ischemic

 

      colitis diagnosis.

 

                Now, there are two, maybe more, possible

 

      hypotheses why the rate of ischemic colitis in IBS

 

      is increased.  Ascertainment bias because of the

 

      documented fact that IBS patients are investigated

 

      two to three times more than the general

 

      population, and/or because there are currently

 

      unknown common pathophysiological mechanisms that

 

      we don't know about today.

 

                We carefully reviewed all cases of rectal

 

      bleeding, colonoscopy and reports of colitis in our

 

      clinical trials to identify possible cases of

 

      ischemic colitis and there were no cases of

 

      ischemic colitis identified in any of our clinical

 

      trials involving more than 11,000 patients on

 

      Zelnorm.  However, one placebo case with ischemic

 

      colitis was identified in our clinical trials.

 

                                                                80

 

                From postmarketing experience as of June

 

      1, 2004, 26 cases of suspected ischemic colitis

 

      have been reported.  This corresponds to a

 

      reporting rate of 7 cases per 100,000 patient-years

 

      worldwide and 12 per 100,000 patient-years in the

 

      United States.  This rate is consistent with the

 

      background rate incidence in IBS patients.

 

                The reported cases of ischemic colitis do

 

      not exhibit any distinct pattern with regard to

 

      duration of treatment, dose of drug, age of

 

      patients, co-morbid conditions, or other

 

      demographic subgroups.  The absence of ischemic

 

      colitis cases in clinical studies and the low

 

      reporting rate in postmarketing experience suggest

 

      that Zelnorm treatment does not increase the risk

 

      of ischemic colitis.

 

                Now, these findings are not surprising

 

      since Zelnorm is not expected to cause

 

      vasoconstriction as there are no 5-HT                                    

                                                        4 receptors in

 

      the human vascular system.  This is further

 

      supported by preclinical studies.  In vivo animal

 

      studies have demonstrated no effect on colonic

 

                                                                81

 

      vascular conductance which is a measure of vasal

 

      activity.  In addition, although tegaserod has

 

      negligible affinity for the 5-HT                                         

                                          3 receptor,

 

      tegaserod has affinity for the 5-HT1B receptor but

 

      it does not cause vasoconstriction, as illustrated

 

      in this graph.

 

                This graph depicts the results of adding

 

      sumatriptan and ergotamine, which are two known

 

      5-HT1B agonists, and tegaserod to a preparation of

 

      isolated coronary arteries from non-human primates.

 

      As expected, ergotamine and sumatriptan cause

 

      marked contraction while tegaserod has no effect.

 

                In conclusion, there is no evidence for a

 

      causal relationship between Zelnorm and ischemic

 

      colitis.  Preclinical studies have clearly

 

      demonstrated that tegaserod has no vasoconstrictive

 

      potential.  There have been no cases of ischemic

 

      colitis in clinical trials on Zelnorm, and the

 

      reporting rate in the postmarketing experience is

 

      consistent with the background rate of IC in the

 

      IBS population even taking under-reporting into

 

      account.  These data indicate that Zelnorm does not

 

                                                                82

 

      increase the risk of ischemic colitis.

 

                Now, there have been four spontaneous

 

      reports of fatalities in patients with intestinal

 

      ischemia from postmarketing reviews.  We take these

 

      reports very seriously and have investigated them

 

      thoroughly.  Based on our individual and careful

 

      review of each case, we are confident that Zelnorm

 

      did not cause these fatalities.

 

                The four fatalities are as follows: One

 

      case with untreated central line sepsis and

 

      ischemic colitis; one case of untreated chronic

 

      abdominal angina; one case with untreated

 

      hypothyroidism leading to severe fecal impaction;

 

      and one case of multi-organ failure from unknown

 

      cause.

 

                Dr. Shetzline has carefully investigated

 

      these cases and he will now discuss them in some

 

      detail with you.  Please, Dr. Shetzline?

 

                             Fatality Cases

 

                DR. SHETZLINE:  Thanks, Dr. Joelsson.  I

 

      am Michael Shetzline, an gastroenterologist and a

 

      senior medical director at Novartis, responsible

 

                                                                83

 

      for Zelnorm in the United States.  Myself and Dr.

 

      Christian Avery are clinical safety experts

 

      responsible for evaluation of these cases.

 

                I would like to review these cases in some

 

      detail.  Given the complicated nature of the cases,

 

      it is important for us to go into some detail in

 

      order to separate out and look at the medical

 

      issues and make them clear.  The first case is a 76

 

      year-old woman.  Her past medical history is

 

      significant for 16 years of constipation.  She had

 

      IBS with constipation diagnosed in the year 2000

 

      and started on Zelnorm in November of 2002.  She

 

      also had dementia of the Alzheimer's type.

 

                In late August of 2003, after 282 days of

 

      Zelnorm use the patient was found "down" at home.

 

      She presented at the emergency department and was

 

      admitted with abdominal pain, vomiting,

 

      hypotension, hypothermia and altered mental status.

 

      Her urine eventually grew E. coli and an abdominal

 

      CT noted dilated loops of small bowel, consistent

 

      with partial small bowel obstruction,

 

      diverticulosis and focal ischemic changes of the

 

                                                                84

 

      left colon.  She was treated with antibiotics and

 

      hydration.

 

                During this admission she had a

 

      colonoscopy for an incidental episode of guaiac

 

      positive stool, and this revealed sigmoid and

 

      splenic flexure ulcers with areas of regeneration

 

      and healing, consistent with ischemic colitis.

 

      Zelnorm was discontinued at this time.  Biopsies

 

      were consistent with ischemic colitis and she was

 

      placed on bowel rest and provided total parenteral

 

      nutrition.

 

                She was eventually transferred to an

 

      extended care facility and had two colonoscopies on

 

      September 17th and 19th.  Both noted improved

 

      colonic mucosa, resolving ischemic colitis.  This

 

      is the usual expected course of ischemic colitis.

 

      However, she remained on TPN, total parenteral

 

      nutrition.  She became hypotensive with E. coli UTI

 

      and was readmitted on September 26th for failure to

 

      thrive, febrile and more acutely ill.

 

                After discussion with the family and

 

      patient, no heroic surgical interventions and/or

 

                                                                85

 

      CPR were to be performed; only supportive care.

 

      She was diagnosed with central line sepsis and,

 

      given her medical co-morbidities and discussion

 

      with the patient and family, a "do not resuscitate"

 

      order was initiated.  Her antibiotics were

 

      discontinue on October 1st and she expired.  In

 

      summary, this event of ischemic colitis resulted

 

      from hypotension and possibly urosepsis.

 

                The second case is a 66 year-old female

 

      who had a past medical history of hypertension,

 

      chronic obstructive pulmonary disease and tobacco

 

      abuse.  She had a prior stroke in 1997 due to small

 

      vessel disease, and carried a prior diagnosis of

 

      non-specific chronic colitis.  Significantly, she

 

      had symptoms of abdominal angina for 2-3 years

 

      characterized by chronic abdominal pain with food

 

      intake, and this resulted in 36 lbs of weight loss

 

      during this interval.  Her IBS was diagnosed in

 

      January of 2000.

 

                In October of 2003 she had continued and

 

      more severe post-prandial abdominal pain and

 

      constipation.  On October 10th she was given

 

                                                                86

 

      samples of Zelnorm, 6 mg BID, by her primary care

 

      physician.  She was not given a prescription and

 

      her caregiver, who was responsible for

 

      administering all her medications, the medications

 

      taken by the patient, does not recall the patient

 

      taking Zelnorm.  He does specifically recall her

 

      increasing use of Vicodin due to this more severe

 

      abdominal pain.

 

                On October 15th she was admitted to the

 

      hospital with severe abdominal pain and bloody

 

      diarrhea.  Zelnorm was not listed as an active

 

      medication in any of her admission documents.

 

                On the 19th she developed acute abdomen

 

      and had an exploratory laparotomy for, quote,

 

      probable chronic intestinal ischemia, acutely

 

      worse, end quote.  The laparotomy revealed

 

      infarcted bowel from the ligament of Treitz to the

 

      terminal ileum, cecum, and proximal ascending

 

      colon, consistent with occlusion of the superior

 

      mesenteric artery.  Given the extensive bowel

 

      necrosis, comfort measures were provided and she

 

      expired.  The cause of death was listed as bowel

 

                                                                87

 

      infarction due to peripheral vascular disease.  In

 

      summary, this is the natural history of end-stage

 

      chronic abdominal or mesenteric angina and it is

 

      likely Zelnorm was not taken by this patient.

 

                The third case is a 41 year-old woman who

 

      had a very significant past medical history of

 

      chronic obstructive pulmonary disease.  She had a

 

      very extensive history of tobacco abuse, with 60-90

 

      pack-years of tobacco use for a 41 year-old woman.

 

      She also had asthma, prior alcohol and illicit drug

 

      use, as well as obsessive-compulsive disorder.  She

 

      had peripheral vascular disease with claudication,

 

      constipation, recurrent urinary tract infections

 

      and hypothyroidism.  She also had a significant

 

      abdominal event due to appendectomy with a rupture

 

      which resulted in abscess formation and a partial

 

      colectomy.  She had medical and medication

 

      non-compliance, as noted in a primary care visit

 

      from November of 2003.

 

                This individual was presumably prescribed

 

      Zelnorm in March of 2003, however, these documents

 

      were not available for review.  We have no

 

                                                                88

 

      follow-up from the March presumed prescription and

 

      the November primary care records which document

 

      her non-compliance.  She developed severe abdominal

 

      pain and she collapsed with a cardiorespiratory

 

      arrest.  After an emergency medical service call

 

      she was resuscitated and admitted.

 

                It is important to note that admission

 

      documents list only her Lithobid and Seroquel as

 

      active medications.  They do not list Zelnorm or

 

      her thyroid supplement.  These documents include

 

      emergency medical service notes at home, admission

 

      notes and multiple physician evaluations.

 

                On admission, her abdominal x-ray revealed

 

      free air in the abdomen and an exploratory

 

      laparotomy demonstrated a rectal sigmoid densely

 

      packed with rock-hard stool.  She had ischemic

 

      colitis and enteritis involving the colon and

 

      terminal ileum and early gangrene of the distal

 

      bowel.  She had marked dilatation, a picture

 

      consistent with toxic megacolon.

 

                She had a sub-total colectomy with

 

      ileostomy and was treated with ventilatory support,

 

                                                                89

 

      broad-spectrum antibiotics and vasopressors.  A

 

      subsequent neurology evaluation revealed anoxic

 

      brain injury with diffuse edema and a suspicion of

 

      herniation.  She developed multi-organ failure and

 

      expired three days after admission.  In summary,

 

      this patient had a bowel obstruction from likely

 

      untreated hypothyroidism due to her medication

 

      non-compliance and a secondary perforation.  Given

 

      her medical and medication non-compliance, it is

 

      likely she never took Zelnorm.

 

                The last case is a 67 year-old woman who

 

      had a very significant history of heart disease,

 

      with known coronary disease, a prior coronary

 

      bypass graft procedure, angioplasty with stent

 

      placements, known occluded grafts, congestive heart

 

      failure, hypotension, atrial fibrillation and

 

      diabetes.  She had chronic and acute renal failure.

 

      She was on Zelnorm 6 mg BID for an unknown

 

      indication from June 16th to August 7th, the date

 

      of this event.

 

                She as admitted at this time with

 

      progressive shoulder and chest pain, as well as

 

                                                                90

 

      shortness of breath, and was hospitalized, on

 

      telemetry for a rule-out myocardial infarction, on

 

      August 7th.  On admission, her abdomen was soft,

 

      non-tender.  Her lungs had few bibasal rales and

 

      her extremities showed trace pedal edema.

 

                It is important to note that at this time

 

      she had no diarrhea, no melena and no bright red

 

      per rectum.  On hospital day 3 she complained of

 

      abdominal pain and nausea, and surgical consult

 

      indicated a soft abdomen which was not distended.

 

      She did, however, have left lower quadrant

 

      tenderness and a questionable diverticulitis.  An

 

      abdominal x-ray at this time showed a large amount

 

      of fecal material in the colon  There was no

 

      gaseous distention or free air.

 

                On the same day laboratory results

 

      indicated an amylase of over 7,000 and a lipase of

 

      over 400.  A pulmonary consult for dyspnea

 

      indicated respiratory failure and she required

 

      mechanical ventilation.  At this time she was

 

      evaluated for bronchitis, pneumonia, rule-out

 

      abdominal sepsis, rule-out ischemic colitis,

 

                                                                91

 

      coronary disease and hypotension.

 

                A clinical evaluation noted, quote, in

 

      view of her acute deterioration and chronic medical

 

      problems, her prognosis is extremely poor.

 

      Consequently, continuation of heroic interventions

 

      may be inappropriate, end of quote.  A cardiologist

 

      summary indicated hypotension and it was felt that

 

      the patient had a catastrophic abdominal event.

 

      This may have included ischemic bowel, possible

 

      perforation, pancreatitis, acute renal failure, all

 

      in addition to her known co-morbidities of ischemic

 

      cardiomyopathy, congestive heart failure, renal

 

      failure and diabetes.  The patient was made a "no

 

      code" and died on hospital day 4.

 

                The death certificate listed

 

      cardiorespiratory failure as the primary immediate

 

      cause of death.  Other factors included shock,

 

      pancreatitis and inflammatory bowel disease.  In

 

      summary, this patient experienced cardiovascular

 

      collapse with a history of coronary disease and

 

      congestive heart failure, as well as other medical

 

      co-morbidities.  This was likely unrelated to

 

                                                                92

 

      Zelnorm.

 

                Now I would like to return the safety

 

      update to Dr. Joelsson.

 

                  Zelnorm: Safety Overview (continued)

 

                DR. JOELSSON:  Thank you, Dr. Shetzline.

 

      In summary, these four cases, as you may

 

      understand, are very complicated.  In two cases it

 

      is actually unclear if the patients actually took

 

      Zelnorm in the first place.  In our opinion and

 

      those of external experts that have reviewed these

 

      cases, the evidence does not support that the death

 

      of these patients was caused by or contributed to

 

      by Zelnorm.

 

                At the time of approval in July, 2002,

 

      biliary tract disorders were discussed because

 

      there was an imbalance of cholecystectomies

 

      introduction he clinical trials.  When pooling the

 

      clinical trial data, there is still an imbalance in

 

      favor of placebo, although smaller than was seen in

 

      the approval trials.

 

                An adjudication was performed with outside

 

      experts, resulting in a rate of 0.06 percent in

 

                                                                93

 

      Zelnorm-treated patients versus 0.03 percent on

 

      placebo.

 

                In the postmarketing experience there were

 

      30 reports of biliary tract events in approximately

 

      3 million patients, and 18 were cholecystectomies;

 

      2 were cholelithiasis; and 10 were other events.

 

      There were no serious sequelae reported from these

 

      patients.

 

                In order to further elucidate the possible

 

      effects of Zelnorm on gallbladder function a very

 

      thorough study was performed using dynamic

 

      ultrasound measurements.  No effect on gallbladder

 

      function was detected.  There was no impact on

 

      ejection fraction, ejection rate and period, or

 

      maximal emptying.  There was no impact on fasting

 

      and residual volume, and there were no stimulus

 

      effects on gallbladder contraction during fasting.

 

      Based on this data, it is unlikely that Zelnorm

 

      affects gallbladder function.

 

                At approval there was also discussion

 

      about ovarian cysts.  However, ovarian cysts are

 

      very well balanced in the clinical trials and there

 

                                                                94

 

      are very rare reports from the postmarketing

 

      experience.  Our conclusion from these data is that

 

      Zelnorm treatment does not increase the risk of

 

      ovarian cysts.

 

                Zelnorm has been extensively studied in

 

      clinical trials and postmarketing experience, and

 

      the safety profile of Zelnorm is very favorable.

 

      In fact, Zelnorm has the overall safety profile of

 

      placebo, with the only exception being diarrhea.

 

      However, serious consequences of diarrhea are very

 

      rare and do not result in significant clinical

 

      sequelae.  Evidence from either clinical trials or

 

      postmarketing experience does not suggest that

 

      Zelnorm increases the risk of rectal bleeding,

 

      ischemic colitis, other forms of intestinal

 

      ischemia, cholecystectomies or ovarian cysts.

 

                Zelnorm is a safe and well-tolerated drug

 

      that has a safety profile that supports its use in

 

      chronic constipation patients.  Thank you.  I would

 

      now like to introduce Dr. Schoenfeld who will

 

      discuss with you his benefit/risk assessment.

 

                        Benefit/Risk Assessment

 

                                                                95

 

                DR. SCHOENFELD:  Well, good morning, Dr.

 

      Fogel, members of the advisory committee, FDA

 

      officers, audience members.  I am Philip

 

      Schoenfeld, a gastroenterologist at the University

 

      of Michigan School of Medicine.  It is my pleasure

 

      to present a risk/benefit analysis of the use of

 

      tegaserod and traditional therapies for the

 

      management of constipation.

 

                Now, I sympathize with the members of the

 

      advisory committee.  You have been sitting here now

 

      for over an hour and a half.  I imagine that I

 

      should keep this presentation brief but also as

 

      stimulating as possible to maintain your attention.

 

      I am going to present an evidence-based medicine

 

      analysis, revising the randomized, controlled trial

 

      data about the efficacy for tegaserod and

 

      traditional therapies in the management of

 

      constipation, and review the best available

 

      clinical trial data about the safety of tegaserod

 

      and traditional therapies in the management of

 

      constipation.

 

                I think it is particularly important to

 

                                                                96

 

      consider the risk/benefit analysis not only for

 

      tegaserod but also for alternative therapies for

 

      constipation because, as a practicing

 

      gastroenterologist, when I am treating a patient

 

      with constipation I have to consider the

 

      risk/benefit analysis for all of these possible

 

      treatments when I select the best possible

 

      treatment for my patient, and I certainly think

 

      this is an important topic.  As Dr. Prather pointed

 

      out during her presentation, constipation is

 

      common.  It negatively impacts the quality of life

 

      for patients who actively seek medical care, and

 

      many constipated patients are dissatisfied with

 

      available treatments.

 

                Let's stop for a moment and think about

 

      that last statement, and look at the randomized,

 

      controlled trial data about traditional therapies

 

      for constipation to try to determine why

 

      constipated patients might not be satisfied with

 

      available therapies.

 

                This is a partial list of the commonly

 

      used treatments for constipation.  They include

 

                                                                97

 

      surface-acting agents like dioctyl sodium

 

      sulfosuccinate--I had to practice saying that and

 

      hereafter I will refer to it as Colace; bulking

 

      agents like psyllium; stimulant laxatives and

 

      osmotic laxatives like PEG-3350.  These are all

 

      FDA-approved treatments for constipation.

 

                Dr. Prizont, in his efficacy section in

 

      the FDA briefing document, provided a brief but

 

      very balanced review about traditional therapies

 

      for constipation.  He specifically noted that there

 

      are some randomized, controlled trials looking at

 

      the benefits of traditional therapies for

 

      constipation but many of these were conducted under

 

      deficient designs.  In other words, many of these

 

      studies did not meet the Rome committee criteria

 

      for appropriate design of a functional GI disorder

 

      trial.  They had inappropriately small sample

 

      sizes.  They had inadequate blinding.  They had

 

      very vague or imprecise criteria to identify

 

      patients with constipation.

 

                Now, in the briefing document Dr. Prizont

 

      concluded that these trials revealed little

 

                                                                98

 

      differences between laxatives and modest

 

      improvement over placebo.  He actually referenced

 

      the most recent and most comprehensive

 

      meta-analysis about traditional therapies for

 

      laxatives, conducted by Jones and Nick Talley and

 

      colleagues.  In fact, the actual title of that

 

      meta-analysis is "The Lack of Objective Evidence of

 

      Efficacy of Laxatives in Chronic Constipation."

 

      That is quite a provocative title.

 

                Let's delve into that study a little bit

 

      further to see how they came up with that.  In

 

      brief trials of 4 weeks or less in duration, they

 

      found that laxatives increased stool frequency by

 

      about 2 stools per week compared to baseline.

 

      Placebo increased stool frequency by about 1 stool

 

      per week compared to baseline.  But as you note,

 

      the 95 percent confidence intervals here for

 

      placebo and laxatives are superimposed, not clearly

 

      demonstrating a difference in efficacy.

 

                For trials of 5-12 weeks in duration the

 

      results are less impressive.  Laxatives increased

 

      stool frequency by only 1 bowel movement per week

 

                                                                99

 

      versus placebo-treated patients who had an increase

 

      in stool frequency of 1.5 bowel movements per week.

 

                Now, I think we should be cautious about

 

      interpreting these results.  This is a

 

      meta-analysis that provides a single summary

 

      statistic and combines the results from bulking

 

      agents, stimulant laxatives and osmotic laxatives.

 

      So, it might be more beneficial to look at a

 

      systematic review that at least separated out

 

      bulking agents from other types of laxatives.

 

                That is actually available.  The other

 

      well-designed, systematic review about traditional

 

      therapies for constipation comes from Tramonte and

 

      Cindy Mulrow and colleagues, at the Cochrane Center

 

      in San Antonio, Texas.  They separated out bulking

 

      agents versus laxatives and found that bulking

 

      agents increase stool frequency by about 1.4 stools

 

      per week compared to baseline and laxatives

 

      increase stool frequency by about 1.5 stools per

 

      week compared to baseline.  So, their study

 

      conclusions were that fiber and laxatives do appear

 

      to modestly increase stool frequency over placebo. 

 

                                                               100

 

      They also concluded that it was unknown if these

 

      agents would improve general well being or global

 

      satisfaction because this endpoint wasn't examined

 

      in many of these trials.

 

                Now, it is beyond the scope of my

 

      presentation to individually review each of the

 

      randomized, controlled trials looking at

 

      traditional therapies and I am sure you wouldn't

 

      want to sit through all of that.  But I will

 

      conclude by noting that the randomized, controlled

 

      trial evidence for psyllium, PEG-3355 and lactulose

 

      consistently demonstrates significant increases in

 

      stool frequency versus placebo.  On the other hand,

 

      other commonly used and FDA-approved treatments for

 

      constipation, such as bisacodyl, Surfak, Colace,

 

      consistently do not demonstrate a significant

 

      increase in stool frequency versus placebo.  It

 

      doesn't necessarily mean that these drugs are

 

      ineffective.  As Dr. Prizont noted, most of these

 

      RCTs were carried out under deficient designs and

 

      if appropriately designed studies that met the Rome

 

      committee criteria were conducted, we might be able

 

                                                               101

 

      to demonstrate efficacy.  Nevertheless, when I am

 

      selecting a treatment for constipation I have to

 

      consider not just my clinical experience but also

 

      the randomized, controlled trial data of efficacy

 

      as well as the clinical trial data of safety.

 

                There are several other issues for

 

      discussion today.  First, whether or not the

 

      clinical trial data are adequate with respect to

 

      the chronic constipation population that is likely

 

      to be treated with tegaserod.  I would just

 

      reemphasize part of Dr. Dennis' presentation, the

 

      two Novartis randomized, controlled trials

 

      contained inclusion criteria that are very similar

 

      to the Rome II committee criteria for functional

 

      constipation.  In fact, in some ways they are more

 

      stringent.

 

                Patients had to have greater than 6 months

 

      of symptoms by the Novartis criteria, whereas the

 

      Rome criteria require only 12 weeks, which need not

 

      be consecutive, of symptoms in the previous year.

 

      The Novartis criteria required that patients have

 

      fewer than 3 spontaneous bowel movements per week. 

 

                                                               102

 

      That is not an actually requirement to meet the

 

      Rome committee criteria for functional

 

      constipation.  A patient, for example, who just had

 

      straining and lumpy, hard stools for 12

 

      non-consecutive weeks would meet the Rome committee

 

      criteria for functional constipation.

 

                Certainly, I think it is very true that 78

 

      percent of the patients in these RCTs appear to

 

      have chronic constipation while as many as 22

 

      percent had some symptoms of abdominal discomfort

 

      that might have led them to be classified as IBS

 

      with constipation.  Nevertheless, Miss Mealey, the

 

      FDA statistical reviewer, in her very thorough and

 

      comprehensive statistical review noted that the

 

      responder rates for the constipated patients in

 

      these trials who didn't have IBS-like symptoms were

 

      similar to the overall responder rates.  In fact,

 

      they tended to do better than the overall response

 

      rates that were recorded.

 

                Certainly, the issue has been raised about

 

      whether or not we may have subtypes of patients

 

      with slow transit constipation included in this

 

                                                               103

 

      trial.  As a clinician, my main point about that

 

      would be that the AGA's medical position statement

 

      about that provides essentially identical treatment

 

      algorithms whether somebody has normal transit

 

      constipation or slow transit constipation.  So, my

 

      choice of therapy wouldn't necessarily differ based

 

      on whether or not there might have been some

 

      patients with slow transit constipation included in

 

      these trials.

 

                Another issue for discussion is the

 

      appropriateness of a primary endpoint of an

 

      increase of 1 or more complete spontaneous bowel

 

      movements per week compared to baseline versus the

 

      percentage of patients who attained 3 or more

 

      complete spontaneous bowel movements per week.

 

      This is a difficult issue.  The Rome II committee

 

      actually couldn't come to a consensus about what

 

      was the most appropriate endpoint for trials of IBS

 

      and functional constipation.  They recognized that

 

      there are multiple symptoms present in patients

 

      with these lower GI functional disorders.  They

 

      actually stated that in addition to whatever

 

                                                               104

 

      primary endpoint is chosen, there should be a

 

      select number of a priori defined secondary

 

      endpoints that reflect the multiple symptoms that

 

      are present in patients with these functional GI

 

      disorders.

 

                In fact, Sander Van Zanten and his

 

      colleagues, who were on the subcommittee of the

 

      Rome committee who laid out the appropriate design

 

      of a trial of a functional GI disorder, actually

 

      stated that global improvement in satisfaction may

 

      be the most appropriate endpoint.  That is an a

 

      prior defined secondary endpoint in the 2 Novartis

 

      randomized, controlled trials, that patients on

 

      tegaserod 6 mg BID were significantly more likely

 

      to be responders for global satisfaction than

 

      patients that were on placebo.  This is not only a

 

      significant difference but, in my opinion, a

 

      clinically important difference where the magnitude

 

      of benefit is 9-12 percent more for patients on

 

      tegaserod 6 mg BID who were responders for global

 

      satisfaction compared to patients on placebo.

 

                Again, there were a select number of a

 

                                                               105

 

      priori defined secondary endpoints included, to try

 

      to contrast that with traditional therapies that

 

      patients on tegaserod 6 mg BID had 1.9 to 2 more

 

      spontaneous bowel movements per week compared to

 

      patients on placebo who had about 0.9 to 1 more

 

      spontaneous bowel movements per week.  These are

 

      statistically significant differences.

 

                If we do decide to apply the FDA's

 

      criteria that patients have to have 3 or more

 

      spontaneous bowel movements per week, and we look

 

      at the proportion of patients who attained what is

 

      a pretty high therapeutic goal, we still see that

 

      almost twice as many patients on tegaserod

 

      experienced 3 or more complete spontaneous bowel

 

      movements per week compared to patients on placebo

 

      and the magnitude of this difference, whether we

 

      look at 4 weeks or the entire 12-week trials, is

 

      approximately 10 percent.  Again, in my opinion,

 

      that is a clinically important difference.

 

                So, in conclusion for efficacy, I would

 

      state that the randomized, controlled trial data

 

      about the efficacy of tegaserod is very robust and

 

                                                               106

 

      precise.  These are the best designed, most

 

      comprehensive trials about treatments for

 

      constipation that are available among all the

 

      treatments that we have available for constipation.

 

      The study population does reflect patients with

 

      chronic constipation and the a priori defined

 

      primary and secondary endpoints do reflect the

 

      multiple symptoms that patients with constipation

 

      have, and these RCT data consistently demonstrate

 

      that tegaserod produces significant and clinically

 

      important improvement in the multiple symptoms of

 

      constipation.

 

                Let's move on to safety.  Unfortunately,

 

      there is very little data about the safety of

 

      traditional therapies for constipation.  The most

 

      recent and comprehensive meta-analysis by Jones,

 

      Nick Talley and colleagues actually didn't even

 

      address the issue because the data were so scant.

 

      If we do go back to the systematic review performed

 

      by Tramonte and Cindy Mulrow and colleagues from

 

      the Cochrane Center in San Antonio, Texas, they

 

      specifically noted that few studies used

 

                                                               107

 

      standardized techniques to assess adverse events.

 

      They also did note that they did not identify any

 

      significant differences in adverse events between

 

      laxatives and placebo.  So, they concluded that

 

      although there is no evidence that laxatives are

 

      unduly harmful, the data available are very limited

 

      and short-term.

 

                Thus, we are really left with looking at

 

      the prescribing information and case report data to

 

      try to get an idea about what adverse events are

 

      associated with commonly used laxatives.  We see

 

      for bulking agents that fecal impaction and large

 

      bowel obstruction have been reported, and even

 

      acute esophageal obstruction when bulking agents

 

      aren't taken with adequate amounts of water.

 

      Anaphylaxis has been reported with psyllium.  Among

 

      osmotic agents all different types of electrolyte

 

      abnormalities have been reported, specifically with

 

      magnesium-based agents that are used on a regular

 

      basis.  Stimulant laxatives have been associated

 

      with both electrolyte imbalances as well as

 

      abdominal cramps.  All of these agents have been

 

                                                               108

 

      reported to have been associated with diarrhea.

 

                So, another issue for discussion is

 

      whether or not the clinical trial data and

 

      postmarketing surveillance data provide adequate

 

      evidence of safety.  I pause here for a moment,

 

      looking at the title of this slide, to just note

 

      that the clinical trial safety data where patients

 

      are followed per protocol probably provides at

 

      least the most precise safety data that we have

 

      available to us.  When we look at the clinical

 

      trial safety data available for tegaserod we see

 

      that in the Novartis 2 randomized, controlled

 

      trials over 2,600 patients with constipation were

 

      enrolled.  Over 1,700 received tegaserod.  In the

 

      whole clinical trial safety database you have over

 

      11,000 patients treated with tegaserod and over

 

      3,400 patient-years of tegaserod use followed

 

      within the context of clinical trials.  I would

 

      suggest that infers that there is very robust and

 

      precise clinical trial safety data for tegaserod,

 

      certainly more robust and precise clinical trial

 

      safety data than what we have available for any

 

                                                               109

 

      other treatment of constipation.

 

                That very precise data allows us to

 

      estimate what is the likelihood of serious adverse

 

      events for constipated patients using tegaserod or

 

      placebo.  We see essentially similar rates.  And,

 

      that very robust and precise safety data let's us

 

      quantify the likelihood of diarrhea as an adverse

 

      event.  Among constipated patients we see that it

 

      is reported as an adverse event in 5 percent of

 

      patients in clinical trials versus 3 percent in

 

      patients on placebo.  We see that 0.6 percent of

 

      patients treated with tegaserod actually

 

      discontinued the medication because of the severity

 

      of their diarrhea.  When we look at the entire

 

      clinical trial database we can estimate that the

 

      likelihood of clinically serious consequences of

 

      diarrhea--going to the emergency department because

 

      of dehydration and getting IV fluids, virtually

 

      being hospitalized because of syncopal

 

      episode--occurs in 0.04 percent or 1 in 2,500

 

      patients treated with tegaserod.

 

                To conclude, let's turn to the safety

 

                                                               110

 

      issue about ischemic colitis.  Obviously as

 

      gastroenterologists, as primary care providers for

 

      patients, we are concerned about the issue of

 

      ischemic colitis because it has been brought to our

 

      attention by our clinical experience with

 

      alosetron.  Alosetron, again, is an antagonist of

 

      the 5-HT                                            3 serotonin receptor

as opposed to

 

      tegaserod that is an agonist of the 5-HT                                 

                                                                4 serotonin

 

      receptor.  We know from the clinical trial data

 

      that there were 17 cases of ischemic colitis among

 

      the 10,805 alosetron-treated patients in those

 

      clinical trials.  That calculates out to a rate of

 

      5.9 cases of ischemic colitis per 1,000

 

      patient-years based on the clinical trial data.

 

                I would also like to point out the fact

 

      that among placebo-treated patients with IBS the

 

      rate of ischemic colitis was 1.1 cases per 1,000

 

      patient-years.  Even in the context of this

 

      clinical trial, there was a background rate of

 

      ischemic colitis among patients treated with

 

      placebo.

 

                So, what can we do about comparing the

 

                                                               111

 

      issue of ischemic colitis with tegaserod patients

 

      treated for constipation versus other patients

 

      treated for constipation?  The only other treatment

 

      for constipation that has any breadth of clinical

 

      trial safety data is PEG-3350.  In their new drug

 

      application to the FDA they reported a rate of

 

      ischemic colitis in their clinical trial safety

 

      data of 3 cases per 1,000 patient-years.  I want to

 

      emphasize that that is an extrapolation.  The exact

 

      number is that there was 1 case of ischemic colitis

 

      among 300 patient-years of clinical trial safety

 

      data when they submitted their new drug

 

      application.  That is the only other treatment for

 

      constipation where we have any breadth of clinical

 

      trial safety data to estimate the likelihood of

 

      patients experiencing ischemic colitis.

 

                What is the data for tegaserod?  Zero

 

      cases among 11,640 tegaserod-treated patients

 

      studied over 3,400 patient-years of exposure

 

      versus, among all the clinical trial database for

 

      placebo-treated patients, 1 probable case of

 

      ischemic colitis among 4,267 placebo-treated

 

                                                               112

 

      patients followed for 780 patient-years of

 

      exposure.

 

                Now, the FDA officials wanted to identify,

 

      based on that clinical trial data--zero cases among

 

      all the patients followed in the clinical trial

 

      database--what would be the maximal rate of

 

      ischemic colitis that still could be occurring

 

      within 95 percent confidence intervals.  So, they

 

      did their statistical analysis based initially on

 

      the 7,000 tegaserod-treated patients in clinical

 

      trials that they had reviewed and they came up with

 

      a maximal ischemic colitis rate, within the

 

      confines of 95 percent confidence intervals, of 1

 

      case in approximately 2,000 patients, based on the

 

      fact that there were zero reported cases among over

 

      7,000 patients.

 

                If we give the up to date analysis based

 

      on all 11,640 tegaserod-treated patients, then a

 

      similar statistical analysis would shoe that the

 

      maximal rate within 95 percent confidence

 

      intervals, considering there are zero cases among

 

      11,640 patients, would be 1 case in 3,883 patients.

 

                                                               113

 

                In order to be balanced, I think we should

 

      consider the placebo patients too.  The same

 

      statistical analysis shows that their maximal rate

 

      would be 1 case in 867 placebo-treated patients.

 

                This analysis is still based on very few

 

      cases of ischemic colitis.  So, I certainly

 

      understand the need to look at postmarketing

 

      surveillance data.  In the U.S. over 2 million

 

      prescriptions, accounting for over 233,000

 

      patient-years of use; 26 reported cases of possible

 

      ischemic colitis, equating to a rate of

 

      approximately 12 cases per 100,0000 patient- years.

 

                Again, as pointed out during Dr.

 

      Joelsson's presentation, patients with irritable

 

      bowel syndrome seem to be diagnosed with ischemic

 

      colitis more often than the general population.  It

 

      may be an ascertainment bias because these patients

 

      tend to be scoped more frequently.  It may be due

 

      to an unknown pathophysiologic factor.  Obviously,

 

      there is recent research to indicate there are true

 

      pathophysiologic differences among IBS patients.

 

      But regardless of which epidemiologic study we look

 

                                                               114

 

      at, all the available epidemiologic data indicates

 

      that patients with IBS are 3-4 times more likely to

 

      be diagnosed with ischemic colitis than is the

 

      general population, and the rates vary depending on

 

      the age of the population that is examined.

 

      Obviously, the Medi-Cal population tended to be

 

      older than the patients studied in the United

 

      Health Care study and, thus, we are seeing a higher

 

      rate of ischemic colitis both in the general

 

      population and in the IBS population.

 

                I certainly comment Dr. Brinker.  He did a

 

      very interesting analysis of the United Health Care

 

      base and identified that, clearly, when a patient

 

      is diagnosed with IBS their rate of getting

 

      subsequently diagnosed with ischemic colitis within

 

      the next 3 weeks is very high.  Those patients

 

      almost certainly are patients that are misdiagnosed

 

      with IBS when they really have ischemic colitis.

 

      Nevertheless, the same analysis found that patients

 

      who had a stable IBS diagnosis for over 1 year

 

      still had a rate of 53 cases per 100,000

 

      patient-years compared to the general population

 

                                                               115

 

      where it was 7 cases per 100,000 patient-years.

 

                I do want to make particular note here.

 

      When I talked about the clinical trial data my

 

      denominator was 1,000 patient-years.  We have now

 

      shifted.  All the postmarketing surveillance data

 

      is based on a denominator of 100,000 patient-years

 

      of use.

 

                Postmarketing surveillance data for IBS

 

      patients treated with tegaserod is 12 cases per

 

      100,000 patient-years, which is 4- to 15-fold lower

 

      than the expected rate, although I certainly

 

      understand there may be some under-reporting, and

 

      it very difficult to get an estimate for how often

 

      that occurs.

 

                So, in conclusion, I certainly think that

 

      the clinical trial safety data for tegaserod is

 

      more robust and more precise than it is for any

 

      other treatment that we have available for

 

      constipation.  This safety data allows us to have a

 

      very precise estimate of the likelihood of

 

      clinically serious consequences of diarrhea, but

 

      the evidence doesn't support an association between

 

                                                               116

 

      tegaserod and ischemic colitis.

 

                When I do a risk/benefit analysis I see

 

      the benefits being this robust clinical trial data

 

      that demonstrates that tegaserod is efficacious for

 

      the treatment of constipation, especially the

 

      multiple symptoms of constipation, and that the

 

      safety data is more robust than it is for any other

 

      treatment I might choose and that safety data from

 

      clinical trials demonstrates to me that there is a

 

      very low but finite risk of clinically serious

 

      consequences of diarrhea.

 

                So, that analysis demonstrates to me that

 

      tegaserod has a very favorable risk/benefit profile

 

      in the management of chronic constipation, and that

 

      it compares very favorably with the risk/benefit

 

      analysis for any other therapy that I might choose

 

      to use to treat patients with constipation.  Thanks

 

      very, very much for your attention and I will turn

 

      the program back over to Dr. Fogel.

 

                       Questions on Presentations

 

                DR. FOGEL:  I would like to thank the

 

      presenters for their informative presentations.  At

 

                                                               117

 

      this juncture we turn the meeting over to the

 

      committee for questions to the presenters.  Dr.

 

      D'Agostino I think had his hand up first, and then

 

      Dr. Sachar.

 

                DR. D'AGOSTINO:  When I saw there was a

 

      two-hour presentation I said, my God, they will

 

      never take that long but it actually was a great

 

      presentation.  Thank you very much.

 

                I have a comment about the subset

 

      analysis, which we will have to address later.  I

 

      understand that you look at subsets for consistency

 

      and not necessarily expecting to see significant

 

      results, but shouldn't we be concerned that we are

 

      not seeing the effect lying on the right side with

 

      the elderly greater than or equal to 65 and the

 

      males, and the Blacks?  Can you give us some words

 

      on how we can feel comfort that you aren't seeing

 

      the effect in greater than or equal to 65 year-old

 

      individuals and also males, and I would like

 

      something on the Blacks also.

 

                DR. DENNIS:  Thank you for that question.

 

      Yes, absolutely.  Can I have slide AQ-16, please? 

 

                                                               118

 

      We will start off with the elderly population since

 

      that was the question that you asked initially.  As

 

      you know, we only randomized 13 percent of our

 

      patients that were 65 years or older, and this is

 

      the responders by age group looking at our primary

 

      efficacy analysis.

 

                What we can see in the group that is 65

 

      years and older is that we are seeing a treatment

 

      effect in the patients that are on Zelnorm.  We are

 

      also seeing an effect in patients on placebo as

 

      well.  So, the interesting thing though is that we

 

      can break this down further by looking at the older

 

      population by age and by gender.

 

                If I could have the next slide, please,

 

      which is AQ-17, let me show you what happens when

 

      we break it down into further subsets.  On the top

 

      row we are seeing female patients and on the bottom

 

      row we are seeing male patients.  The patients that

 

      are less than 65 years old--if we start with that

 

      column on the left-hand side, we can see that the

 

      effect in the younger female population is similar

 

      to the effect in the younger male population. 

 

                                                               119

 

      Remember that we have much fewer numbers in terms

 

      of the male group so we don't reach statistical

 

      significance because, as I said before, these

 

      subgroup analyses are not powered to detect

 

      statistical significance.  So, I think we are

 

      seeing a consistent effect in the men that are 65

 

      years and younger that we are seeing in the female

 

      population.

 

                If we look at the slide on the right-hand

 

      side, and let's turn to the elderly population, we

 

      do see an effect in female population.  Of course,

 

      the effect size is slightly smaller--again, small

 

      numbers of patients, and when we will look at the

 

      male patient population that are 65 years and older

 

      we are seeing that there really is no effect

 

      looking at it on this particular analysis.

 

                But I am going to take it one step further

 

      and take out those patients that we felt were

 

      probably IBS-like because, if you remember, in our

 

      overall efficacy analysis when we took that group

 

      out the efficacy was slightly more robust.

 

                So, if I can have the next slide, which is

 

                                                               120

 

      AQ-18, this shows you what happens when we take out

 

      those patients that are IBS-like.  I am going to

 

      focus your attention on that male population that

 

      is 65 years and older.  You can see that in the

 

      previous analysis--here we have really small

 

      numbers of patients.  We are dealing with 20

 

      patients in that group that are on 6 mg BID.  So,

 

      the responders that we saw in the previous analysis

 

      were all chronic constipation patients and when we

 

      take out the other patients that have IBS obviously

 

      our denominator changes and, you know, we see a

 

      much more different effect looking at these

 

      numbers.  But I do want to caution that these are

 

      very small numbers when we are looking at these

 

      subgroup analyses.

 

                But if we look at the four different

 

      quadrants I think we can see the effect in the

 

      patients less than 65 is similar in men as it is in

 

      women.  I think we are seeing an effect in elderly

 

      females, and I think we are seeing an effect in

 

      elderly males when you take out the IBS-like

 

      subset.

 

                                                               121

 

                DR. FOGEL:  Dr. Sachar?

 

                DR. SACHAR:  With the permission of the

 

      chair, if I could address some questions to each of

 

      the four major presenters, Dr. Schoenfeld, when you

 

      presented your efficacy data in slides 13 and 14

 

      you appeared to have limited your analysis only to

 

      the highest dose tegaserod of 6 mg BID.  Yet, when

 

      you discussed the adverse effects you combined the

 

      2 mg and the 6 mg doses.  It would seem to me if

 

      you really want to look at a benefit/risk ratio we

 

      really ought to look at a comparison for the same

 

      doses.  If we were to do that, we would find in

 

      your slide 21 that it really isn't 5.4 percent of

 

      patients but is actually 6.6 percent of patients

 

      who had some adverse effect with diarrhea at the

 

      equivalent dose, at the 6 mg dose.

 

                I am not a professional statistician but

 

      if we go a little further we might say that since

 

      the number needed to treat--to get some benefit,

 

      some demonstrated benefit from this drug is

 

      approximately 10.  It ranged between 9-11 in all

 

      the analyses.  It is approximately 10.  The number

 

                                                               122

 

      needed to treat to see some adverse effect from

 

      diarrhea is actually about 2.8 at the equivalent

 

      dose.  So, would it be fair to say that for every 3

 

      patients who get some benefit from this drug 1 will

 

      experience some diarrhea?

 

                DR. SCHOENFELD:  No, I would not go along

 

      with that and I think there are multiple points

 

      there to address.  The first one is that all of us

 

      have conducted clinical trials and, as we

 

      recognize, reporting an adverse event in the

 

      context of a clinical trial is not the same as

 

      suffering a clinically important adverse event.

 

      When these patients are followed in the context of

 

      clinical trials, to paraphrase, your study nurse

 

      may say, "anything unusual happen in the past

 

      week?"  And, if the patient says, "I had a little

 

      bit of diarrhea last Thursday," that becomes an

 

      adverse event.  What is probably a much more

 

      appropriate adverse event category to assess,

 

      clinically important adverse events, is how often

 

      patients stop their medication due to diarrhea.

 

      Obviously, here it is 0.6 percent.

 

                                                               123

 

                Having said that, I certainly take your

 

      comment appropriately, that if you look at the 6 mg

 

      BID dose the rate at which diarrhea was reported as

 

      an adverse event is about 6.6 or 6.7.  For the

 

      broader issue though of safety, my own

 

      experience--and there are other experts here that

 

      have far more experience in safety issues--is that

 

      when we look at efficacy we want to look at what is

 

      going to be most likely the dose that is utilized.

 

      But in safety we tend to look at multiple different

 

      dose ranges to find out what the benefit is.

 

                Having said that, I think a subgroup

 

      analysis about what the rate would be for 6 mg BID

 

      versus 2 mg BID would be helpful, although I will

 

      mention for the most serious adverse events that we

 

      are concerned about here, which in my mind are

 

      really ischemic colitis, when you look at 6 mg BID

 

      or 2 mg BID it is still going to be zero events.

 

      You are just going to change your denominator a

 

      bit.  And, the majority of patients in these trials

 

      were treated with 6 mg BID.

 

                DR. SACHAR:  Agreed.  When you talk about

 

                                                               124

 

      the diarrhea issue that brings me to the one

 

      question for Dr. Joelsson, and that is simply that

 

      you did discuss the physiologically serious

 

      consequences and those were obviously very, very

 

      low.  Did anybody record whether any patient with

 

      diarrhea had any episode of incontinence?

 

                DR. JOELSSON:  We have not that recorded.

 

      I cannot answer that.

 

                DR. SACHAR:  Because that is sort of an

 

      impact thing.

 

                DR. JOELSSON:  Yes.

 

                DR. SACHAR:  And for Dr. Dennis, in slide

 

      46--

 

                DR. DENNIS:  I will flash it up on the

 

      screen.

 

                DR. SACHAR:  Yes, it is very important, as

 

      everybody has indicated, that when you excluded IBS

 

      from the analysis you still showed efficacy.  I

 

      think that is a very important point.  But you

 

      showed us the data for doing that only at week 1-4.

 

                DR. DENNIS:  Yes.

 

                DR. SACHAR:  Do you have any data on that

 

                                                               125

 

      for the 12-week point?

 

                DR. DENNIS:  It looked similar.  I don't

 

      have the data on a slide but it does look similar

 

      over the 12-week treatment period.

 

                DR. SACHAR:  It is the same approximately?

 

                DR. DENNIS:  Yes.

 

                DR. SACHAR:  Great, fine.  In slide 13 you

 

      showed us that, in terms of the inclusion criteria,

 

      they had to have a bowel evaluation within the past

 

      5 years.  Do I take that to mean that if some

 

      patients had early constipation symptoms 3 years

 

      ago or 4 years ago or 5 years ago and they had a

 

      barium enema, and then more recently the symptoms

 

      persisted or worsened and they represent that they

 

      would be eligible to go in this study without any

 

      new reexamination?

 

                DR. DENNIS:  If they had had a bowel

 

      evaluation that was after the onset of symptoms and

 

      the symptoms remained the same within the past 5

 

      years there was no need for them to have a

 

      reevaluation.  However, if there was any change in

 

      the symptoms or if there were any alarm features,

 

                                                               126

 

      as I said, anything that suggested rectal bleeding,

 

      hemorrhage, anemia or any change in the pattern,

 

      those patients would have had to have a new

 

      evaluation.  But it was stable patients who had

 

      been having symptoms that had remained the same

 

      within the time they had the evaluation.

 

                DR. SACHAR:  Great!  My last question is

 

      for Dr. Prather.  I am not actually familiar with

 

      the Canadian study of Pare et al., but you

 

      indicated it was a population study.  Does the

 

      population in that study represent the group

 

      receiving and taking medications for chronic

 

      constipation?  Is it a clinic-based or a true

 

      population-based study?  Because if it is truly

 

      population based it doesn't reflect people who are

 

      taking medications for their constipation.

 

                DR. PRATHER:  It was, indeed, a

 

      population-based study but that would include

 

      all-comers with constipation that were actually in

 

      the population.  So, it didn't discriminate against

 

      individuals who may or may not have seen a

 

      physician for their constipation.

 

                                                               127

 

                DR. SACHAR:  Right, so that means that in

 

      Larry Schiller's study that you showed in slides 19

 

      and 20 with all the dissatisfaction, that included

 

      patients who had taken over-the-counter

 

      preparations or had seen a GP, or something, and

 

      had been perfectly satisfied?  Or, was it only the

 

      dissatisfied patients who sought out GI specialists

 

      who were in that study?

 

                DR. PRATHER:  This included

 

      individuals--it was a study that was done through

 

      the Internet that was representative of the U.S.

 

      population, but with the initial questions,

 

      actually to get into the study they had to have

 

      seen a physician within the past 12 months for

 

      constipation.

 

                DR. SACHAR:  A physician or a

 

      gastroenterologist?

 

                DR. PRATHER:  Actually, these were primary

 

      care physicians predominantly, yes.

 

                DR. FOGEL:  To increase the number of

 

      questions that we can ask during our time frame, I

 

      would like the members of the committee to keep

 

                                                               128

 

      their comments brief.  I am going to take the

 

      prerogative of the chair and ask my questions of

 

      Dr. Dennis.

 

                Can you provide us additional details

 

      regarding the question that you asked for

 

      subjective global assessment, and can you tell us

 

      how the data was analyzed and whether responders

 

      had a persistent response over the 12 weeks of the

 

      study?

 

                DR. DENNIS:  We asked the question how

 

      satisfied were you with your bowel habits over the

 

      past week?  And, the responses were a very great

 

      deal satisfied; a good deal satisfied; moderately

 

      satisfied; hardly satisfied; and not at all

 

      satisfied.  We defined a responder as having a

 

      decrease of 1 on the satisfaction score.

 

                I am going to first show you some data on

 

      the persistence of satisfaction response and then I

 

      will call one of the statisticians to actually come

 

      up and explain to you the statistical analysis that

 

      was done.

 

                If I could have slide AQ-58, please?  This

 

                                                               129

 

      is an analysis that we did where we said to those

 

      patients that met the score of a very great deal

 

      satisfied and a good deal satisfied, so zero and 1,

 

      for at least 50 percent of the weeks of the whole

 

      trial, which is 12 weeks.  What we can see on the

 

      study is definitely a significant benefit of

 

      Zelnorm versus placebo when we look at patients

 

      that had satisfaction over 6 weeks of the 12-week

 

      treatment period.  So, I think we are seeing

 

      persistence of the satisfaction result.

 

                I am going to call upon Dr. Jeen Liu, who

 

      is our statistician, to come and respond to your

 

      question about how these were actually calculated.

 

                DR. LIU:  My name is Jeen Liu.  I am the

 

      statistician from Novartis responsible for this

 

      project.  The slide that Dr. Dennis just showed was

 

      a response rate that we defined--actually, she

 

      showed two slides for two time intervals, weeks 1-4

 

      weeks and 1-12.  What we did was we took the

 

      patient score at each week, averaged them over the

 

      respective time intervals, either 4 weeks or 12

 

      weeks, and compared that with the baseline score

 

                                                               130

 

      that each patient had during the 2 weeks prior to

 

      treatment, and got the difference and compared with

 

      it was a decrease of 1 or more.  If it is 1 or

 

      more, it is a responder; otherwise the patient was

 

      a non-responder.  Thank you.

 

                DR. FOGEL:  Thank you.  Dr. Metz?

 

                DR. METZ:  Great, thanks.  Just in the

 

      interest of time, I am going to float a few

 

      questions to you.  I want to thank you for a nice,

 

      comprehensive presentation.  Three areas to

 

      address, first of all, the problem with the

 

      subgroup analysis, as has been alluded to.  Can you

 

      perhaps tell me why you chose 65 years?  I would be

 

      more interested in actually seeing a median age

 

      above and below, perhaps divided into quartiles

 

      above that and see where you actually see your

 

      cut-off.  I am not sure why 65 is necessarily

 

      relevant.

 

                The second question will be a little bit

 

      about the loss of efficacy in one of your two

 

      pivotal trials in the 2 mg group.  It appears to me

 

      more because of the placebo effect increasing up to

 

                                                               131

 

      reach the 2 mg, but it makes one wonder a bit about

 

      a tolerance response, and that brings me to why you

 

      really chose the first 4 weeks.  This is something

 

      people are going to be using way beyond 12 weeks.

 

      So, why the first 4 weeks; why not 12 weeks and

 

      beyond as your primary outcome measurement?

 

                The third question is use of surrogate

 

      measurements, which you actually have in your

 

      binder but didn't talk about at all today.  That is

 

      the use of rescue medication and seeing any

 

      difference there as a sort of idea of, you know,

 

      you are seeing an effect because of using less

 

      rescue?  Can you address those three points,

 

      please?

 

                DR. JOELSSON:  While Dr. Dennis is

 

      thinking about the second question I can take the

 

      first question.  The analysis of patients above 65

 

      years and below 65 years is a very traditional

 

      analysis that we do, which is based on what the FDA

 

      wants us to do.  This is kind of the cookbook thing

 

      you do.  So, it is not that it was anything that we

 

      came up with; this is the traditional way of doing

 

                                                               132

 

      it, and we don't have the data the way that you

 

      describe.  I am sorry about that.

 

                DR. METZ:  Do you think that would be a

 

      useful examination to go through?

 

                DR. JOELSSON:  Yes, I agree.

 

                DR. DENNIS:  let me address the other

 

      questions.  I am first going to tackle the question

 

      that you asked about loss of efficacy.  I think

 

      what we see in these clinical studies is that the

 

      treatment effect of Zelnorm was sustained

 

      throughout the entire treatment period.  We did not

 

      see a decrease in the number of responder rates.

 

      There is certainly nothing to suggest that we saw a

 

      loss of efficacy in terms of the drug response

 

      itself.  Placebo responses, as we know, are not

 

      uncommon in clinical trials and we see them in all

 

      clinical trials.  You know, the issue is in some

 

      clinical trials placebo responses continue to rise.

 

                If I could go back to my core slide CE-28,

 

      this shows you the weekly responder definition over

 

      the 12-week treatment period, and I just want to

 

      really point out again that we are seeing that the

 

                                                               133

 

      efficacy is sustained throughout the entire

 

      treatment period.

 

                Maybe I can get a clarification, Dr. Metz.

 

      Were you referring specifically to the 2 mg dose in

 

      the 2301 study?

 

                DR. METZ:  That is correct.  Clearly, you

 

      don't see that in the 2302 but you do see it in the

 

      2301.

 

                DR. DENNIS:  Absolutely.  You know, I

 

      think the 6 mg BID dose has emerged consistently as

 

      being more efficacious and that is why we are going

 

      for that dose as an indication.  We have actually

 

      looked at what are the reasons that could have, you

 

      know, determined why we are seeing this in 2301 and

 

      not 2302 because these two studies were essentially

 

      identical in the core period.  The only differences

 

      that we can find are geographical.  2301 was done

 

      mainly in Europe and 2302 was done in North and

 

      South America.

 

                To address the question of why we chose a

 

      4-week duration period, I think that was because

 

      when physicians prescribe the drug they want to

 

                                                               134

 

      look at the effect size within 4 weeks.  They want

 

      to know is this drug going to work within 4 weeks

 

      or not.  So, we looked at 4 weeks as our primary

 

      endpoint but we also looked at it over 12 weeks to

 

      make sure that we would see sustained efficacy.

 

      So, we have the data for both of those two

 

      endpoints.

 

                DR. METZ:  Right, but the point I am

 

      making is that this is a chronic problem.  You are

 

      defining chronic constipation as something that has

 

      been around for more than 6 months--

 

                DR. DENNIS:  Sure.

 

                DR. METZ:  --and you are not going to

 

      treat for 4 weeks and then stop.

 

                DR. DENNIS:  And that is why we have a

 

      12-week treatment duration.

 

                The last question that you had was

 

      laxative use.  There were very strict guidelines

 

      for laxative use in these studies.  Patients were

 

      only allowed to take laxatives if they had not had

 

      a bowel action for 96 hours.  So, they had to wait

 

      96 hours from the time of their last bowel action

 

                                                               135

 

      before they could have a laxative.  When we looked

 

      at laxative intake in these particular studies, we

 

      measured how many patients took at least one dose

 

      of a laxative throughout the entire 12-week

 

      treatment period, and we found that about 50

 

      percent of patients in the study took a laxative at

 

      some point during the study.  But when we really

 

      break this down and we say how frequently were

 

      laxatives actually being taken, we find that

 

      laxative intake, in fact, was quite infrequent.

 

                This slide I am going to show you is going

 

      to show you laxative use by mean number of days.

 

      If you look at the baseline period, we see that

 

      laxatives were used about once every 11-12 days.

 

      In the double-blind, placebo group we see that

 

      laxatives were used about once every 14 days and

 

      about once every 18 days on Zelnorm.

 

                If I could have the next slide, which is

 

      AQ-62, this is going to show you the median days

 

      data.  Here we are seeing by median data of use

 

      that the baseline laxative use was about 14 days a

 

      week.  The median use of laxatives in the placebo

 

                                                               136

 

      group goes down to 0.11, which translates to 1

 

      every 64 days.  When you look at the

 

      Zelnorm-treated group we are seeing that that goes

 

      down to 0.08, which translates to once every 88

 

      days.  So, when you really look at it, laxative

 

      intake is really very infrequent.

 

                However, to speak to your point, we are

 

      seeing that there is more laxative use in the group

 

      on placebo than there is on Zelnorm, and if we are

 

      expecting to see a confounder because of that, we

 

      would expect to see it more in the placebo than we

 

      would in the Zelnorm.

 

                DR. FOGEL:  Dr. Cryer?

 

                DR. CRYER:  Dr. Dennis, I would just like

 

      to follow-up on this theme of the subgroup analysis

 

      in those who were greater than 65 and those who

 

      were men.  You very strongly make the point that

 

      Zelnorm, as you just showed us, has maintained

 

      efficacy over the 12-week period.  However, all of

 

      your slides that you showed us to support its

 

      observations in the subgroups of those who were

 

      greater than 65 or those who were men were the

 

                                                               137

 

      4-week data points.  So, I am wondering whether you

 

      can show us that, in fact, the sustained 12-week

 

      data in that subgroup of men and those who were

 

      greater than 65.

 

                DR. DENNIS:  Right.  The reason why we did

 

      the subgroup analysis on the 4-week data initially

 

      was because that was our primary endpoint and so

 

      that is why we determined to do that.

 

                I don't actually have the slides with me

 

      right now to show you the actual week 12 but I will

 

      just confer with my colleagues and make sure we

 

      have those before the end of the presentation.

 

                DR. CRYER:  I think this is a very

 

      important point because when you consider the

 

      potential target group for therapy, many of them,

 

      as we have learned from Dr. Prather, are going to

 

      be greater than 65 year-old age population.  So, I

 

      think in the assessment that we are making today it

 

      would be very, very helpful for us to specifically

 

      look at the effects in a target population.

 

                DR. DENNIS:  Right, and I will make sure

 

      we have those slides and we will come back to that.

 

                                                               138

 

                DR. FOGEL:  You can present those slides

 

      later.

 

                DR. DENNIS:  Right, thank you.

 

                DR. FOGEL:  The next question is by Dr.

 

      Buchman.

 

                DR. BUCHMAN:  To further follow-up on the

 

      12-week issue, letting aside the 4-week issue,

 

      number one, I am wondering what the rationale was

 

      for the chosen 12-week interval rather than 52

 

      weeks for example, given that this is a problem

 

      that your patients had for an average of at least 6

 

      years.  That is the first question.

 

                Secondly, I want to know if you have any

 

      data on either on-demand or intermittent use

 

      because for a benign problem, outside of a clinical

 

      trial, compliance for medication use is very poor.

 

      So, what I am wondering is whether with

 

      intermittent use does tolerance develop, for

 

      example, and is there a loss of efficacy at that

 

      time.

 

                In regard to the first question, and I do

 

      have a few others, my sub-question to that is if,

 

                                                               139

 

      indeed, you have efficacy at 12 weeks, is your

 

      indication really only for 12 weeks use rather than

 

      long-term use, because you have not shown long-term

 

      use data?

 

                DR. DENNIS:  Absolutely.  We chose the

 

      12-week treatment duration in keeping with the Rome

 

      committee guidelines, and the Rome committee gives

 

      us guidelines for chronic functional GI disorders,

 

      and their recommended length for treatment trials

 

      was 8-12 weeks.  So, we were within the Rome

 

      committee guidelines for doing this, and the

 

      indication that we would be seeking is for 12 weeks

 

      treatment.

 

                DR. BUCHMAN:  And what about the

 

      "on-demand" therapy?  Do you have any data on that?

 

                DR. DENNIS:  We do not have any data for

 

      "on-demand" therapy in chronic constipation.

 

                DR. JOELSSON:  Maybe I can add to that.

 

      Luckily enough, we just did a study in IBS with

 

      constipation and we did show that if we had a good

 

      effect during the first treatment period it was

 

      just as good, or maybe even better, on the second

 

                                                               140

 

      treatment period when they had a relapse.  So,

 

      there is no evidence from our data that you don't

 

      respond just as well the second time as you did the

 

      first time.

 

                DR. BUCHMAN:  One quick question, and I

 

      understand that other people have to ask some other

 

      questions, there is some question whether the

 

      increase in bowel movement by one per week is

 

      clinically significant.  So, my questions for that

 

      are, number one, what is the data that you have to

 

      indicate a priori that that increase of one is

 

      clinically significant?  Number two, what is your

 

      data on patients who had an increase of two or more

 

      bowel movements per week?

 

                DR. DENNIS:  I showed you the slide from

 

      my core presentation that looked at the association

 

      between responders and non-responders, and we

 

      showed a clear-cut difference in terms of the means

 

      when you had a non-responder versus a responder

 

      looking at the primary endpoint and comparing it to

 

      the secondary variables.

 

                Can I go back to the slides from my core

 

                                                               141

 

      presentation, please?  Do we have a slide from the

 

      core presentation?  I am looking for the

 

      association between the endpoints.  Here we are.

 

      So, this is the slide where we looked at the

 

      association to say the mean changes from baseline

 

      were quite different in the responders versus the

 

      non-responders, and this is significant at all time

 

      points.

 

                I think what I am going to do to really

 

      delve into your question further is to say, well,

 

      is what we are seeing clinically relevant for the

 

      patient population, and I think we see this is a

 

      clinically relevant response looking at this

 

      particular analysis but I am going to ask Dr.

 

      Prather to come up and give her opinion as to

 

      whether she thinks, you know, a change of one CSBM

 

      per week is clinically relevant, bearing in mind

 

      that at baseline these patients had 0.5 CSBMs by

 

      mean values and zero CSBMs by median values at

 

      baseline.  So, seeing an increase of one CSBM per

 

      week, in our minds, we felt was clinically

 

      relevant, but I will let Dr. Prather give her

 

                                                               142

 

      opinion.

 

                DR. PRATHER:  Thank you.  It is always

 

      difficult when I have my patient in the office to

 

      figure out how am I going to translate this

 

      research data to the patient in my office.  What I

 

      have to remember is that I am being presented with

 

      means, meaning that there are some patients who

 

      responded well and some patients who didn't.  When

 

      you are talking about constipation, for my group of

 

      patients anyway, going from having no bowel

 

      movements that are spontaneous per week or half a

 

      bowel movement per week that is spontaneous and

 

      increasing that to, you know, one or more

 

      spontaneous bowel movements, that is going to be a

 

      significant finding in my patient.

 

                The other thing to realize is that when we

 

      are talking about bowel function we have to

 

      actually recognize that there is a balance, that we

 

      want to make them better but we can't make them too

 

      much better because too much better turns them into

 

      diarrhea, and that is just as difficult as it is to

 

      have constipation.  At least, that is what my

 

                                                               143

 

      patients tell me.  So, I would rather see something

 

      that has, you know, a modest by definite effect

 

      than something that is a bit too powerful that I am

 

      going to have difficulty managing.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  Thanks.  I would like to first

 

      congratulate the group on a superb series of

 

      presentations and a really very impressive pair of

 

      studies.  I have three questions.  One is on age

 

      breakdown.  You cut it at age 65.  Age 65 is

 

      becoming younger every day.  Many of the people who

 

      are going to suffer from the problem who are going

 

      to use it, in fact, are a lot older than that.  So,

 

      both in terms of your population data, Canadian

 

      data or other population data,  and in terms of

 

      your clinical trial can you show us the breakdown

 

      of people over age 65?  For example, what

 

      proportion of people over age 75 or 80 have

 

      constipation in the general population, and how

 

      many of those people do you have in your study?

 

      That is the first question.

 

                DR. DENNIS:  I think the first thing to

 

                                                               144

 

      address is the fact that constipation, as we have

 

      defined it, is not a condition of the elderly.  I

 

      mean, I think Dr. Prather showed you the data that

 

      came from the epi study and from the Pare study

 

      that really showed that constipation, as we have

 

      defined it, is actually a disorder of all ages.

 

                DR. STROM:  That is what I would like to

 

      see, to see those data greater than 65 broken down

 

      more finely in order to confirm that statement.

 

                DR. DENNIS:  For the population-based

 

      studies?

 

                DR. STROM:  I would like to see it both

 

      for the population-based studies--I mean, to make

 

      the claim that it is not a problem in the elderly I

 

      don't want to see 6 year-olds, I want to see 80

 

      year-olds.

 

                DR. DENNIS:  Yes.  I am going to ask Dr.

 

      Prather to comment as well, but would you like to

 

      see the age distribution for our particular

 

      clinical studies?  This is a slide which shows you

 

      the pooled data from 2301 and 2302, looking at the

 

      breakdown of ages that we studied in the clinical

 

                                                               145

 

      studies.  As you can see, as I said, the mean age

 

      was 46 and 47 years but we did have representation

 

      of different ranges.

 

                DR. STROM:  But just to get a gestalt,

 

      over age 75, it looks like you had 10 patients?

 

                DR. DENNIS:  We had very few patients in

 

      this age group.

 

                DR. STROM:  Ten percent, sorry.  And, how

 

      does that compare to the population data?

 

                DR. DENNIS:  Dr. Prater will come up and

 

      respond to that question.

 

                DR. PRATHER:  Thank you for asking that

 

      question because I actually have a special interest

 

      in GI motor and functional disorders that are

 

      associated with aging, and I have looked carefully

 

      at the epidemiologic data and, unfortunately, they

 

      are fairly flawed when it comes to taking a look at

 

      elders.  For instance, the Drossman Householder

 

      study actually cut it off at age 45.  The ones that

 

      actually used the Rome I or the Rome II criteria

 

      cut it off at 65.  So, those were strict criteria.

 

      We really don't have a good breakdown above the age

 

                                                               146

 

      of 65.

 

                Now, we do have information about

 

      self-report constipation.  We need to be a little

 

      bit careful when we talk about self-reports.  Again

 

      thinking of my own patient population, some of my

 

      elders that don't have a bowel movement every day,

 

      or if they don't have their bowel movement in the

 

      morning and instead have it after lunch, they may

 

      not be satisfied and they may actually report that

 

      as constipation.

 

                We do know in general from the

 

      epidemiologic studies that there appears to be an

 

      increase in self-report constipation over the age

 

      of 70.  The studies that we have and, again, I

 

      don't have a slide for this but I do have

 

      information from a review--in a couple of the

 

      studies that took a look at individuals over the

 

      age of 70 we see that self-report

 

      constipation--again, not using the strict criteria

 

      but what patients think--that at the age of 55-59

 

      it is 28 percent; 60-64, 29.7 percent; 65-69, 32.8

 

      percent; 70-74, 37.3; 75-79, 42; 80-84 is up to 48.

 

                                                               147

 

      But, again, we are getting very small numbers in

 

      those larger groups and, again, this is self-report

 

      constipation and, again, this isn't really a forum

 

      for me to talk about my research interests but,

 

      again, when we talk about functional bowel

 

      disorders and constipation and aging, there are

 

      also frailty issues that go along with that,

 

      locomotion, motor issues that contribute to the

 

      difficulties that these individuals do have with

 

      their bowel function.

 

                DR. STROM:  Thank you.  That is very

 

      helpful because obviously it is self-report

 

      constipation that is likely to lead to treatment.

 

                The second question--you have enormously

 

      rich data on different types of diarrhea and

 

      symptoms at baseline as well.  When you see a very

 

      consistent pattern of efficacy like this but a very

 

      small increment over placebo, that sort of smells

 

      like you have some people who respond a lot and

 

      other people who don't respond at all and, in fact,

 

      we heard that as a comment.  Can you give us

 

      predictors of who is going to be a responder and

 

                                                               148

 

      who is not?  You have shown us some data--age,

 

      gender race.  How about baseline symptoms?  Can you

 

      tell within your very rich database which baseline

 

      symptoms will lead to people likely to be

 

      responders and which will not?

 

                DR. DENNIS:  Let me show you a couple of

 

      slides.  If we can start with slide AQ-81?  Let's

 

      look at the responders looking at baseline

 

      characteristics, and we are going to start by

 

      looking at those patients by number of complete

 

      spontaneous bowel movements a week.  So, let's look

 

      at this particular analysis.

 

                This is responders broken down by the

 

      number of complete spontaneous bowel movements per

 

      week at baseline.  We can actually see that Zelnorm

 

      is equally efficacious in all of these treatment

 

      groups.  The very right-hand group obviously is

 

      very small numbers of patients and those would have

 

      been protocol violators.

 

                If we go to slide number AQ-82, this will

 

      look at the responders by duration of constipation.

 

      So, here we are looking at whether people have had

 

                                                               149

 

      constipation for 6-12 months all the way up to, you

 

      know, 12 years of constipation.  Again we are

 

      seeing efficacy in all of these different

 

      subgroups.

 

                The next one that we can look at as well

 

      would be responders by baseline constipation

 

      assessments.  So, if we could have AQ-83, remember,

 

      we asked those bothersome questions, how bothersome

 

      was your constipation, and we broke it down by

 

      looking at baseline and whether these patients had

 

      moderately bothersome constipation or good deal

 

      bothersome constipation or a very great deal

 

      bothersome constipation and, again, we saw no

 

      difference in efficacy amongst those treatment

 

      groups.

 

                We can also look at efficacy by looking at

 

      patients that took laxatives at baseline, if we

 

      could have AQ-67.  Again we saw no difference

 

      whether patients take laxatives or don't take

 

      laxatives at baseline.  So, in fact, we didn't

 

      really find any predictors to say there was one

 

      particular group in any of these baseline

 

                                                               150

 

      characteristics that would be more likely to say,

 

      you know, Zelnorm would work more effectively in

 

      that particular group or not.

 

                DR. STROM:  How about people whose major

 

      complaint was frequency, versus people whose major

 

      complaint was straining, versus people whose major

 

      complaint was hard, lumpy stools, versus abdominal

 

      pain, versus bloating, looking at the very rich

 

      symptom data to see how well that predicts

 

      response?

 

                DR. DENNIS:  We have looked at that data

 

      as well and we haven't seen any clear-cut

 

      predictors of response looking at those baseline

 

      symptoms.

 

                DR. STROM:  The last question relates the

 

      database studies.  A big point was made that it was

 

      irritable bowel syndrome that causes ischemic

 

      colitis or is associated with ischemic colitis

 

      rather than the treatments.  As someone who has

 

      been using these databases for 25 years, I am very

 

      skeptical.  Those are not people with irritable

 

      bowel syndrome; those are people with claims for

 

                                                               151

 

      irritable bowel syndrome.  Did you get the medical

 

      records on those patients who had irritable bowel

 

      syndrome and who had ischemic colitis and their

 

      bowel syndrome before that to be able to see

 

      whether that was really an established diagnosis or

 

      was, in fact, people who were being misdiagnosed?

 

                DR. JOELSSON:  Well, these are not studies

 

      that we have performed.  These are published

 

      studies but, as far as I understand, at least in

 

      one study there was a subset of patients that were

 

      reviewed with medical records which was consistent

 

      with the overall data.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  I have some concerns about a

 

      lack of or presence of a dose response.  First a

 

      point of information, in your IBS study initially,

 

      where you got approval, was there any difference

 

      between 2 mg and 6 mg?

 

                DR. DENNIS:  In our IBS studies 6 mg BID

 

      was consistently more efficacious for all the

 

      variables so we are seeing a consistent pattern.

 

                DR. LEVINE:  But in the current studies,

 

                                                               152

 

      symptomatically you may have seen some differences

 

      when you pooled the data, as shown in slide 31

 

      where you state that there is effective treatment

 

      of multiple symptoms of chronic constipation, but

 

      when you go back to looking at the weekly stool,

 

      the stool data, etc. you find a weakness in 2301

 

      versus 2302.  It is very hard for me, going through

 

      this and looking through all the data to discern

 

      whether you really think there is a difference

 

      between 2 mg and 6 mg through everything, including

 

      this particular data, page 14 and page 17 for

 

      instance, the stool change from baseline where,

 

      indeed, there is a big difference between the two

 

      suggesting perhaps dose response, and then again

 

      2301 on page 14 where there is no difference in

 

      2302 and there is a slight difference in 2301.  So,

 

      I wondered across the board, besides symptoms, did

 

      you actually see dose response in every aspect that

 

      you looked at?

 

                DR. DENNIS:  I think we saw a more

 

      consistent dose response in study 2301.  As I said

 

      earlier, we went back to say, well, what were the

 

                                                               153

 

      reasons that we were seeing this dose response in

 

      2301 and we didn't see it in 2302 and we looked at

 

      a number of parameters, baseline parameters, to

 

      say, well, were there any differences in the

 

      patient population because the studies were

 

      identical in design, and the only differences we

 

      could come up with were really geographic.  2301

 

      was done in Europe mainly and 2302 was done in

 

      North and South America.  Beyond that, we haven't

 

      got any explanation for why we see it in one study

 

      and not in the other study, but the bottom line is

 

      that the 6 mg BID dose is consistently efficacious

 

      across both studies, and that would be the dose

 

      that we would be looking at.

 

                DR. STROM:  Thank you.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  I have a brief question for

 

      Dr. Dennis about baseline matching.  There is a

 

      table on page 21 of the Novartis briefing document,

 

      entitled Table VI-2.  My question relates to the

 

      category percent SBM with sensation of complete

 

      evacuation.  It looks like they are not balanced at

 

                                                               154

 

      baseline and I would just like to hear your comment

 

      about whether these groups were balanced and

 

      comparable at baseline because the numbers look

 

      different, for example, 8 versus zero versus zero;

 

      1.4 versus 9.1 versus 8.3.  They seem to be wildly

 

      different there, and would that confound any

 

      results that we have already seen?

 

                DR. DENNIS:  I have the table up here.

 

      So, we are looking at the percentage of SBMs with

 

      the sensation of complete evacuation.  I think what

 

      we have to bear in mind is that when we look at

 

      this particular analysis, percentage of SBMs, it

 

      really is a ratio.  So, we are saying of the number

 

      of SBMs that you are having, how many of those are

 

      actually complete spontaneous bowel movements?  I

 

      think when we looked at patients coming into the

 

      study the criteria for them to get into the study

 

      was less than 3 complete spontaneous bowel

 

      movements per week.  Looking at the percentage of

 

      SBMs with sensation of complete evacuation doesn't

 

      tell us very much about how these patients are

 

      doing.  For example, you could have 2 SBMs and you

 

                                                               155

 

      could have 1 of those being complete and your

 

      percentage would be 50 percent.  You could have 4

 

      SBMs and you could have 2 of those complete and

 

      your percentage would be 50 percent.  So, I think

 

      looking at just the percentage is not a very

 

      reliable statistic on its own.  We should really

 

      look more at the number of SBMs and the number of

 

      CSBMs at baseline.

 

                DR. LAMONT:  So, in terms of that bottom

 

      rank there, you consider those to be matched?

 

                DR. DENNIS:  I don't think it is relevant

 

      when we look at the other members--

 

                DR. LAMONT:  You are saying it doesn't

 

      matter.  I have a second question for Dr. Joelsson

 

      regarding cholecystectomies.  Looking at page 20

 

      and page 21 of your slides, it looks like there is

 

      an increase in cholecystectomies in patients that

 

      are on Zelnorm, if I am interpreting this

 

      correctly.  Can you tell us then that the 14

 

      cholecystectomies in the Zelnorm-treated patients

 

      versus 1 in the placebo is not different?

 

                DR. JOELSSON:  I think I said it was

 

                                                               156

 

      different.  I tried to say that we tried to find

 

      out does this drug really affect gallbladder or is

 

      this a chance finding.  So, we did this very

 

      thorough study looking at gallbladder function and

 

      we could see no effect of tegaserod on gallbladder

 

      function.

 

                Also the second point I would like to make

 

      is that patients with IBS do have a higher rate of

 

      cholecystectomies so the rate we have seen in our

 

      clinical trials is not higher than you would expect

 

      in patients with IBS or in our postmarketing

 

      experience.  So, if anything, the placebo group is

 

      a bit low.

 

                DR. LAMONT:  On the other hand, this might

 

      be something we would want to warn clinicians

 

      about, that in fact it might increase the rate of

 

      cholecystectomy because, first of all, a comment

 

      about this statement that Zelnorm does not affect

 

      gallbladder motility, I accept your data here but

 

      don't forget that patients who have gall stones

 

      have already abnormal motility.  Virtually 90

 

      percent of them have delayed gallbladder emptying

 

                                                               157

 

      by any clinical criteria, and I assume that this

 

      test, Fisher et al., in press is on normal

 

      subjects.  Is that correct?

 

                DR. JOELSSON:  It is patients with IBS,

 

      not with gall stones.

 

                DR. LAMONT:  Right.  So, you could make

 

      the case then that patients with preexisting gall

 

      stones who take Zelnorm may have an increase in

 

      contractility because of the drug that you wouldn't

 

      see in normals, and that that would force a stone

 

      into the neck of the gallbladder into the cystic

 

      duct which is the definition of what happens with

 

      acute cholecystitis and is the usual cause for

 

      cholecystectomy.

 

                DR. JOELSSON:  This issue is actually

 

      already in our prescribing information.  It is not

 

      a warning but it is mentioned there as one of the

 

      issues we had at the earlier application.

 

                DR. FOGEL:  My timekeeper indicates that

 

      we already way behind schedule.  There will be an

 

      opportunity for additional questions this

 

      afternoon.  Are there any questions that remain to

 

                                                               158

 

      be asked right now that cannot wait until the

 

      afternoon?

 

                [Laughter]

 

                Why don't we take a ten-minute break and

 

      then we will continue with the FDA presentation?

 

                [Brief recess]

 

                DR. FOGEL:  I would like to call everybody

 

      back to their seats.  Ready?

 

                       FDA Efficacy Presentation

 

                DR. PRIZONT:  My name is Robert Prizont,

 

      and Implementation an FDA medical officer in the

 

      Division of Gastrointestinal and Coagulation Drug

 

      Products.

 

                DR. PEREZ:  Excuse me, Robert, can you

 

      hold on one second?  We are trying to get your

 

      slides up.

 

                DR. PRIZONT:  Ready?  For those of you who

 

      don't know me and that is the majority of you, I am

 

      Robert Prizont.  I am an FDA medical officer in the

 

      Division of Gastrointestinal and Coagulation Drug

 

      Products.

 

                Zelnorm oral tablets at a dose of 6 mg

 

                                                               159

 

      twice a day are approved for the treatment of women

 

      with constipation-predominant irritable bowel

 

      syndrome, abbreviated C-IBS.  The indication for

 

      treatment was not extended to men with

 

      constipation-predominant irritable bowel syndrome.

 

      Novartis is now seeking approval for Zelnorm use at

 

      a dose of 6 mg twice a day for the treatment of

 

      chronic constipation in both women and men.  To

 

      support the proposed indication Novartis submitted

 

      a prospective study protocol and results from two

 

      multicenter placebo-controlled pivotal clinical

 

      trials.

 

                In sequential order, my presentation will

 

      review a definition of constipation, relevant

 

      issues of the prospective study protocol; provide a

 

      brief summary of the sponsor's efficacy results;

 

      discuss the patient representation for the

 

      selective constipation subtype; comment on the

 

      chosen primary efficacy endpoint; and finalize with

 

      concluding remarks.

 

                For the last 39 years the core of defining

 

      constipation has relied on the frequency of bowel

 

                                                               160

 

      movements.  In 1965 a study on variation in bowel

 

      habits was reported in the British medical journal.

 

      In this study between 83 percent to 99 percent of

 

      655 women and 400 men who were free of

 

      gastrointestinal symptoms had a frequency of bowel

 

      movements ranging from 3 bowel movements per week

 

      to 3 bowel movements per day.  These results

 

      suggested that more than 3 bowel movements per day

 

      or fewer than 3 bowel movements per week are

 

      unusual.

 

                The 1975 Federal Register on

 

      over-the-counter laxatives included the results of

 

      the English survey.  In 1988 worldwide experts met

 

      in Rome to set guidelines for the diagnosis of

 

      functional bowel disorders and published what is

 

      now known as the Rome criteria for the diagnosis of

 

      functional bowel disorders.  The criteria for the

 

      diagnosis of constipation included fewer than the 3

 

      bowel movements per week parameter.

 

                In 1989, the large U.S. NHANES, National

 

      Health and Nutrition Examination Survey, on bowel

 

      habits was published.  This U.S. survey was

 

                                                               161

 

      conducted in two phases.  The initial phase lasted

 

      four years, from 1971 to 1975, and included 14,407

 

      subjects.  The second phase or follow-up lasted two

 

      years, from 1982 to 1984.  The results on number of

 

      bowel movements revealed that over 85 percent of

 

      the U.S. men and women surveyed had 3 or more bowel

 

      movements per week.

 

                In 1999, the Rome II criteria were

 

      published.  The Rome II criteria also included

 

      fewer than 3 bowel movements per week bowel

 

      movement frequency in the definition of

 

      constipation.

 

                In 2000, the American Gastroenterological

 

      Association published a technical report on

 

      constipation and stated as limits of normalcy the

 

      frequency range established in the first English

 

      study, i.e., 3 bowel movements per week to 3 bowel

 

      movements per day.

 

                According to the protocol design,

 

      eligibility to participate in the Novartis studies

 

      required compliance with components included in the

 

      Rome II criteria definition of constipation.  The

 

                                                               162

 

      passage of fewer than 3 bowel movements per week

 

      and the perception of completeness in bowel

 

      evacuation were the objective and subjective

 

      components required to define patients as

 

      constipated and eligible to enter the studies.

 

      Straining was an additional subjective component

 

      included in the requirement.

 

                Rather than applying the established

 

      definition of constipation, the protocol's primary

 

      efficacy endpoint was based on the increase of a

 

      single spontaneous and complete bowel movement per

 

      week.  Moreover, efficacy response was limited to

 

      the first month of a 3-month study period.

 

                The protocol stated that the aim of

 

      performing these studies was to demonstrate the

 

      effect of Zelnorm on bowel habits in patients

 

      suffering from chronic idiopathic constipation.

 

      Idiopathic constipation is a subtype of chronic

 

      constipation.  It has generally been known as

 

      functional constipation.

 

                The other subtypes are outlet obstruction,

 

      slow peristalsis constipation and the constipation

 

                                                               163

 

      associated with irritable bowel syndrome, or IBS.

 

      Slow peristalsis has also been referred to as

 

      idiopathic slow transit constipation.

 

      Differentiation between slow transit constipation

 

      and outlet obstruction constipation requires

 

      specialized techniques, such as measurement of

 

      colon transit time.  A potential concern in

 

      conducting clinical trials with the use of Zelnorm

 

      in idiopathic or functional chronic constipation

 

      was the inclusion of constipation-predominant IBS

 

      subjects.

 

                The trials on Zelnorm in women with

 

      constipation-predominant IBS were conducted long

 

      before the chronic constipation trials and were

 

      initially submitted to this agency in December of

 

      the year 2000.  The design of the studies for use

 

      of Zelnorm in constipation-predominant IBS had

 

      already included the Rome criteria.  The Rome

 

      diagnostic criteria for irritable bowel syndrome

 

      provide the elements and parameters to separate the

 

      constipation-predominant IBS from other types and

 

      subtypes of constipation.  Yet, the prospective

 

                                                               164

 

      protocol for the Novartis studies for chronic

 

      constipation lacked any provision to exclude

 

      patients with constipation due to irritable bowel

 

      syndrome.  As mentioned, since July, 2002 Zelnorm

 

      is approved for women with constipation-predominant

 

      IBS.

 

                Novartis performed two pivotal studies.

 

      Study 2301 was conducted in Europe with

 

      contributions from centers in Australia and South

 

      Africa.  Study 2302 was conducted in the U.S.,

 

      Canada and a few South American centers.  And, 416

 

      to 451 patients were enrolled in each of 3

 

      treatment groups, namely, 6 mg BID, 2 mg BID or

 

      placebo.

 

                The first month results revealed that

 

      40-43 percent of those assigned to Zelnorm 6 mg met

 

      the protocol's definition of efficacy.  The Zelnorm

 

      response was statistically superior to 25-27

 

      percent placebo response, and provided a

 

      therapeutic gain ranging between 15-18 percent.

 

                Two doses of Zelnorm were tested in the

 

      trials, 2 mg BID and 6 mg BID.  The average

 

                                                               165

 

      efficacy in 12 weeks revealed a dose response in

 

      only one of the two studies.  It should be noted

 

      that the Zelnorm efficacy over placebo was

 

      translated in an average weekly increase of less

 

      than one complete spontaneous bowel movement.

 

      Intermittently, 50 percent to 60 percent of treated

 

      patients, including those treated with Zelnorm,

 

      were helped by a well-known laxative, bisacodyl.  A

 

      number of patients exceeded the protocol's

 

      specified use of laxatives, including between 15

 

      percent to 25 percent of the patients treated with

 

      Zelnorm 6 mg BID.

 

                The results from the studies raise the

 

      first question, was the treated patient population

 

      representative of idiopathic constipation?  This

 

      graph illustrates the gender distribution in the

 

      various subtypes of constipation.  The figure is

 

      from a large study on 10,000 subjects with various

 

      subtypes of constipation.  Starting on the right

 

      side of the graph, we can see that the mixed IBS

 

      outlet obstruction subtype, the outlet obstruction

 

      subtype and the constipation IBS subtypes have a

 

                                                               166

 

      preponderance of women, particularly the subtype of

 

      outlet obstruction constipation. This is in

 

      contrast to the almost equal proportion of men and

 

      women observed in functional or idiopathic

 

      constipation shown on the left bars of the slide.

 

                This, in other studies, revealed

 

      considerable symptom overlap amongst subtypes.

 

      Investigators also differ on where slow peristalsis

 

      is a part of outlet obstruction or a separate

 

      subtype of constipation.  Despite the overlap and

 

      differences in subtype nomenclature, there is

 

      overall concurrence that gender is the

 

      characteristic of outlet obstruction, while the

 

      predominance of abdominal symptoms distinguishes

 

      constipation-predominant irritable bowel syndrome.

 

                The Zelnorm studies enrolled 90 percent

 

      women with a mean age of 47 years.  Men 65 years

 

      and older represented around 13 percent of the

 

      patient population.  The addition of completeness

 

      to the spontaneous bowel movements allowed

 

      enrollment of a large proportion of patients who

 

      otherwise would not have met the definition of

 

                                                               167

 

      constipation based just on number of spontaneous

 

      bowel movements.  Just to illustrate this point,

 

      about 50 percent of patients had an average of 3

 

      spontaneous bowel movements per week that were not

 

      perceived as being complete.  These patients would

 

      have not qualified for a constipation trial.  The

 

      introduction of a complete bowel movement in the

 

      definition of constipation transformed these

 

      patients from not being constipated into being

 

      constipated.  It is noteworthy that up to 45

 

      percent of patients entering the studies referred

 

      to abdominal symptoms as the main complaint of

 

      constipation.

 

                As a consequence of a lack of provision in

 

      the protocol to exclude IBS patients the studies

 

      did include irritable bowel syndrome patients.

 

      Novartis estimated that 23 percent of patients had

 

      IBS-like symptoms.  Actually, a few patients

 

      already carried the medical diagnosis of IBS prior

 

      to entry to the studies.  Though it is difficult to

 

      estimate retrospectively the characteristics of

 

      enrolled patients, it is likely that the proportion

 

                                                               168

 

      of patients with IBS-like symptoms was higher than

 

      23 percent, particularly if we consider the main

 

      complaint of abdominal distention as part of the

 

      constipation-predominant IBS.

 

                Let's now examine the protocol's primary

 

      efficacy endpoint.  A relevant question pertains to

 

      whether the protocol's primary efficacy endpoint

 

      represents efficacy based on the established

 

      definition of constipation included in the Rome

 

      criteria.

 

                As mentioned, the Rome criteria defines

 

      constipation by less than 3 spontaneous bowel

 

      movements per week with a perception of

 

      completeness in less than 25 percent of bowel

 

      movements.  It follows that efficacy based on the

 

      average increase of just one complete spontaneous

 

      bowel movement per week would include as responders

 

      constipated patients.  Perhaps not surprisingly,

 

      estimates of efficacy by the 3 or more complete

 

      spontaneous bowel movements resulted in a drop of

 

      the proportional responders. Post study, and at the

 

      agency's request, the sponsor included efficacy

 

                                                               169

 

      analysis based on established frequency of 3 or

 

      more bowel movements.

 

                This table shows the results for the first

 

      month in study 2302, analyzed by the 2 endpoints.

 

      Efficacy, based on the 3 bowel movements per week

 

      rule cuts in half the proportion of responders, and

 

      there is a parallel drop in the therapeutic gain in

 

      treatment with Zelnorm 6 mg, from 18 percent when

 

      analyzed by the protocol's endpoint to 9 percent

 

      when efficacy is based by the traditional endpoint

 

      of 3 or more spontaneous bowel movements.

 

                Although the studies were of 12 weeks

 

      duration, the sponsor's efficacy for chronic

 

      constipation was based on the first month of study

 

      results.  Efficacy in the 12-week study period was

 

      the average increase of one complete spontaneous

 

      bowel movement per week extended to the 12 weeks,

 

      regardless of whether dose responders had actual

 

      participation in efficacy for the 12 weeks.

 

                By the sponsor's analysis, the comparison

 

      of efficacy reached a 45 percent response rate in

 

      Zelnorm 6 mg if efficacy is the average increase in

 

                                                               170

 

      one complete spontaneous bowel movement but

 

      decreases to 22 percent if efficacy is the average

 

      of 3 or more complete spontaneous bowel movements.

 

      We, therefore, decided to calculate efficacy based

 

      on the response for each one of the three months,

 

      as shown in the numerator, with participation in

 

      each one of the three months, as shown in the

 

      denominator.

 

                This table is our analysis of responders

 

      for a 3-month study period in patients who

 

      participated in all 3 months.  The first point to

 

      make is that the requirements of participation plus

 

      efficacy response to all 3 months decreases Zelnorm

 

      6 mg efficacy to 26 percent even if calculated by

 

      the protocol's endpoint of an increase of 1

 

      complete spontaneous bowel movement.  The

 

      combination of full 3 months of participation and

 

      efficacy, analyzed by the 3 or more complete

 

      spontaneous bowel movement rule, drops the 6 mg

 

      response to a very low 12 percent.

 

                Efficacy based on 3 or more complete

 

      spontaneous bowel movements plus full participation

 

                                                               171

 

      results in a uniformly lower response to Zelnorm 6

 

      mg expressed in 1-month efficacy, 2-month efficacy

 

      or efficacy for the entire 3 months of the study

 

      period.

 

                We conclude that the clinical significance

 

      of an efficacy endpoint for constipation based on

 

      the increase of 1 complete spontaneous bowel

 

      movement per week is uncertain.  Based on the

 

      definition of 3 or more complete spontaneous bowel

 

      movements per week, the proportion of responders

 

      for all 3 months is small.  The intermittent use of

 

      bisacodyl, a well-known laxative, further confounds

 

      the assessment of effectiveness.

 

                There is a plethora of laxatives presently

 

      available over-the-counter.  From 1975 until 2003 6

 

      monographs on laxative use and abuse were published

 

      in the Federal Register.  I counted over 25

 

      laxative products just in the first monograph.  A

 

      few laxatives are given under prescription but so

 

      far all remedies are for occasional constipation.

 

      The sponsor now proposes the use of Zelnorm for

 

      chronic constipation seemingly for all subtypes

 

                                                               172

 

      though the protocol aim was to study the idiopathic

 

      subtype.

 

                It is unclear which constipation subtype

 

      benefited from Zelnorm.  The contribution to

 

      efficacy of the constipation-predominant IBS and

 

      outlet obstruction patients is unresolved because

 

      90 percent were women, many with a predominance of

 

      abdominal symptoms.  A benefit of Zelnorm for

 

      laxative abusers, heralded as one reason for the

 

      studies, is unknown for laxative abusers were

 

      excluded from the trials.

 

                Men were under-represented.  In subset

 

      analyses no statistical differences between

 

      treatments were observed in men.  Patients 65 years

 

      of age and older, frequent sufferers of chronic

 

      constipation, were similarly under-represented.

 

      The few treated in the studies, 10-13 percent of

 

      all patients, revealed no statistical or numerical

 

      differences between treatments.  Patient

 

      representation, in whom it should be prescribed,

 

      the rationale for the indication, those

 

      inappropriately included or excluded are issues to

 

                                                               173

 

      be resolved by this expert advisory panel.  Thank

 

      you.

 

                       Questions on Presentation

 

                DR. FOGEL:   Are there questions for Dr.

 

      Prizont?  Dr. Cryer?

 

                DR. CRYER:  Dr. Prizont, you make the

 

      comment that about 50-60 percent of the subjects

 

      were taking concomitant bisacodyl.  I am trying to

 

      get a sense of what the response rate would be in

 

      the Zelnorm only users.  Did you do an analysis

 

      which removed the bisacodyl subpopulation?

 

                DR. PRIZONT:  I did not do that analysis.

 

      Let me check with the statistician first.  Dr. Joy

 

      Mele, maybe she can help.

 

                DR. MELE:  I did do an analysis where I

 

      just looked at the patients who never took a

 

      laxative at any time during the trial, and I am

 

      trying to get to that page.  It is in my review

 

      that is in your packet.  It is on page 31 of my

 

      review.  The treatment effects were about 11

 

      percent difference between the Zelnorm 6 mg and

 

      placebo--16 percent, actually, in the 2302 study

 

                                                               174

 

      and 11 percent in the 3201 study.

 

                DR. SACHAR:  Just a point of information,

 

      apparently laxative use here is defined as

 

      bisacodyl use--

 

                DR. PRIZONT:  Right.

 

                DR. SACHAR:  --but there was no exclusion

 

      for the use of bulk laxatives throughout this.  So,

 

      is there any information at all as to what was

 

      happening with the use of bulk laxatives during the

 

      study?  I am not even sure it was recorded.

 

                DR. PRIZONT:  You mean bulk-forming

 

      agents?

 

                DR. SACHAR:  Bulk-forming agents, yes.

 

                DR. PRIZONT:  The proportion of patients

 

      who took bulk-forming agents was very, very small

 

      and, you know, those who took bulk-forming agents

 

      prior to entering the studies continued to use

 

      bulk-forming agents but the proportion was very

 

      small.

 

                DR. FOGEL:  Dr. Metz?

 

                DR. METZ:  Thank you.  My earlier question

 

      to the sponsor was why they didn't divide this by a

 

                                                               175

 

      median age and then maybe go into quartiles.  I was

 

      told that that was an FDA mandate for the 65-year

 

      cut-off.  Now, they managed to slice and dice

 

      everything else by all sorts of other combinations

 

      but I still haven't yet seen anything sliced by

 

      decade using the median.  Do you have any kind of

 

      information for that from a statistical point of

 

      view??

 

                My other concern, as an aside but also

 

      quite important, is that it seems to me there has

 

      been a lot of goalpost moving in this situation.

 

      Usually what happens is you will submit a protocol

 

      for review.  The agency will have a look at it and

 

      say we like this protocol or we don't like this

 

      protocol.  Somewhere along the way here it seems

 

      there has been a disconnect and we have a

 

      definition that should have been, I assume, agreed

 

      on up front which is now being criticized.  So, can

 

      you give me a bit of the history of how that

 

      developed?

 

                DR. PRIZONT:  Let me clarify, you are

 

      talking about the efficacy endpoint?

 

                                                               176

 

                DR. METZ:  Yes.

 

                DR. PRIZONT:  Let me first go to the

 

      mandate.  Dr. Justice, Dr. Beitz, do we have a

 

      mandate on 65 and older, and can we break it up?  I

 

      am transferring it to management.

 

                [Laughter]

 

                DR. BEITZ:  I would just say that 65 is

 

      the regulatory definition of elderly, over 65.  So,

 

      that tends to drive analyses to look at over and

 

      under 65 but there isn't any reason why folks

 

      couldn't look at over 75 or over 80.

 

                DR. FOGEL:  Dr. Justice?

 

                DR. JUSTICE:  Dr. Mele has done an

 

      analysis on other age groups.  I don't know if she

 

      would like to comment.

 

                DR. MELE:  I did look at the results by

 

      the median age and we still see an age effect even

 

      when we cut it at the median, such that the

 

      treatment effect for the patients over 46 is 10

 

      percent.  This is comparing 6 mg to placebo.  For

 

      instance, for the patients under 46, the treatment

 

      effect is 21 percent.

 

                                                               177

 

                DR. PRIZONT:  Yes, but my understanding is

 

      that they are talking about 65 years old, not 46

 

      years old.

 

                DR. MELE:   But he asked about the median

 

      so cutting it at the median--

 

                DR. METZ:  What I would like to see is

 

      whether there is an effect--in quartiles, say, is

 

      it possible that the first quartile has a great

 

      effect, the second quartile doesn't so well and you

 

      see a decline as time goes on.  I mean, I think

 

      that 65 is an arbitrary number and my concern here

 

      is that the agency seems to be saying elderly

 

      patients aren't properly represented.  I want to

 

      get a feel for the distribution, number one and,

 

      number two, I want to see does the effect fall off

 

      progressively in response as you go up in decades.

 

                DR. MELE:  For the cut points I used it

 

      does.  I mean, when you look at 46 as a cut point

 

      the treatment difference is 10 percent.  When you

 

      use 60 as a cut point it is 8 percent.  When you

 

      use 65 it is 2 percent.

 

                DR. PRIZONT:  So, basically the response

 

                                                               178

 

      is that the higher we go in age the lower the

 

      response.  Now let me address the second part of

 

      your question.  You are right, four years ago the

 

      agency somehow agreed with the protocol and I

 

      suppose with the endpoint.  But whether we agree or

 

      disagree, we still have two points to make.

 

                The first point is that this endpoint of

 

      the increase of one spontaneous bowel movement has

 

      not been validated, at least has not been validated

 

      independently.  You know, somebody may say, well, I

 

      see patients and I think that one complete

 

      spontaneous bowel movement has a clinical

 

      significance but we don't have a trial, an

 

      independent trial or two trials validating that

 

      particular endpoint.

 

                The other point to be made is that when we

 

      compare the prospective endpoint, the increase of

 

      one complete spontaneous bowel movement which we

 

      consider not validated, to established three bowel

 

      movements per week endpoint the results are

 

      completely different.  The proportion of responders

 

      starts to drop rather markedly.  Those are the two

 

                                                               179

 

      points I can make to respond to your question.

 

                DR. METZ:  There still was statistical

 

      significance for a number of those, right?

 

                DR. PRIZONT:  Let me clarify before I go

 

      on.  There was statistical significance between

 

      Zelnorm and placebo in most of the analyses, you

 

      know, with the exception of the elderly and men.

 

      But the question is are we going to rely only on

 

      the statistical significance and not placing it in

 

      light of the clinical significance of laxation?  We

 

      are talking here about laxation.  Ten percent of

 

      responders for a laxative would be rather small, to

 

      say the least.  But, you know, that is my view;

 

      perhaps the committee has a different view.

 

                DR. FOGEL:  Dr. Mangel?  Dr. Prizont, I

 

      have two questions.  The first is for your slides

 

      on the primary efficacy endpoint--

 

                DR. PRIZONT:  Yes?

 

                DR. MANGEL:  --I agree with your point

 

      that the more common definition of constipation is

 

      hovering around the 3 per week.

 

                DR. PRIZONT:  Right.

 

                                                               180

 

                DR. MANGEL:  However, if I am

 

      understanding the slides correctly, and I think

 

      that is going to impact greatly upon the absolute

 

      magnitude of the numbers, these are all cut on

 

      greater than or equal to 3 complete spontaneous

 

      bowel movements per week.

 

                DR. PRIZONT:  That is correct.

 

                DR. MANGEL:  Do you have those same data

 

      for spontaneous bowel movements per week?  Because

 

      the reason I am concerned is when I look at the

 

      sponsor's briefing document, page 30, and there was

 

      not a slide on that, I guess I actually see a

 

      robust response.  They are looking at spontaneous

 

      bowel movements per week.  Their baseline is

 

      hovering, as you said, around 3 and I think your

 

      comment was that the median was less than 3 but

 

      their baseline is hovering around 3, and with

 

      treatment it looks like it goes up to about 5.

 

                DR. PRIZONT:  You mean with completeness?

 

                DR. MANGEL:  No, just spontaneous.  So, if

 

      you are going to impose the criteria of 3 being

 

      your cut-off, would it be more appropriate to look

 

                                                               181

 

      at spontaneous bowel movements than complete

 

      spontaneous?

 

                DR. PRIZONT:  I am going to refer to Dr.

 

      Mele about the spontaneous bowel movements.  Let me

 

      answer the question in a different way.  We have

 

      now the Rome II criteria.  The Rome II criteria

 

      include at least 25 percent or at least less than

 

      25 percent of completeness in order to make the

 

      diagnosis of constipation and 3 bowel movements per

 

      week or less and straining as well since the

 

      baseline.  The sponsor already defined that

 

      baseline.  What is constipation?  They picked two

 

      elements of the Rome criteria, which were frequency

 

      of bowel movements and completeness.  I follow that

 

      particular definition set by the protocol.  You

 

      know, that is a little bit of the paradox here that

 

      I see, that we have one definition of constipation

 

      for baseline and a different definition of no

 

      constipation-predominant for a responder.

 

                DR. MANGEL:  But the Rome criteria

 

      actually don't mandate complete spontaneous bowel

 

      movements.  You know, of the criteria, straining is

 

                                                               182

 

      one of the criteria that could be met greater than

 

      25 percent of the time; lack of complete evacuation

 

      less than 25 percent; or the bowel frequency.  It

 

      seems like a harder hurdle and, therefore, I am not

 

      surprised that the absolute responder rates go down

 

      when the entities are combined.  If you would have

 

      the data cut also for your slides for spontaneous

 

      bowel movements, you know, independent of complete

 

      spontaneous--

 

                DR. PRIZONT:  Yes, you have a point, of

 

      course.  Probably if I selected spontaneous bowel

 

      movements the numbers would be a little bit higher

 

      than what complete spontaneous bowel movements

 

      show.  The Rome criteria state that selection of

 

      two of the elements or parameters of the list that

 

      they have in their own criteria will define

 

      constipation.  The sponsor selected two criteria,

 

      completeness and frequency of bowel movements.

 

      Now, they could have selected something else but

 

      that is what they selected and I follow that

 

      selection.

 

                DR. MANGEL:  Dr. Prizont, before we move

 

                                                               183

 

      on, the survey and epidemiology data in which you

 

      are looking at 95 percent of responders being

 

      within 3 bowel movements per day to 3 per week is

 

      talking about spontaneous bowel movements, not

 

      complete spontaneous.  So, if you are coupling to

 

      the 3 number, the 3 number is derived for

 

      spontaneous bowel movements.

 

                DR. PRIZONT:  Yes.

 

                DR. MANGEL:  And that is what the Rome

 

      criteria actually use.

 

                DR. PRIZONT:  You are talking about the

 

      survey of NHANES, the one with 14,000 patients?

 

                DR. MANGEL:  Well, there have actually

 

      been several.

 

                DR. PRIZONT:  There have been several but

 

      that is probably one of the largest.  The reason

 

      that they placed that is to exemplify that, other

 

      than the British study, there was a newer study

 

      which was large and had two phases, as I mentioned,

 

      and they defined, or they found because that was a

 

      survey, that most of the people responding to the

 

      survey had normal people, had between 3 or more

 

                                                               184

 

      bowel movements per week, basically almost the same

 

      as what the British study found.

 

                DR. MELE:  Can I make a comment on this

 

      question?  About half the patients, remember, had 3

 

      spontaneous bowel movements at baseline.  So, to do

 

      an analysis where you look at an increase to a

 

      level of 3 or more spontaneous, you could only do

 

      it on half the patients.  What we did do is look at

 

      the baseline spontaneous bowel movements and cut it

 

      using those and looked at the primary and secondary

 

      endpoints that we have been discussing.  The

 

      sponsor did this also and found significant

 

      results, statistically significant results.

 

                DR. PRIZONT:  But do you have the numbers?

 

      Because my understanding is--

 

                DR. MELE:  There are a lot of different

 

      numbers.

 

                DR. PRIZONT:  --looking at the numbers, if

 

      there was a difference between the numbers in the

 

      complete spontaneous bowel movements and the

 

      spontaneous bowel movements.

 

                DR. MANGEL:  Well, I think my point was

 

                                                               185

 

      that you are absolutely correct when you go from

 

      greater than 1 to greater than 3, the rate of

 

      responders dramatically drops because it is a

 

      harder hurdle.

 

                DR. PRIZONT:  It is still statistically--

 

                DR. MANGLER:  Still statistical but the

 

      absolute rate, but I am not convinced that the

 

      proper comparison is comparing greater than 1 to

 

      greater than 3 complete spontaneous.  If you wanted

 

      to look at greater than 1 complete spontaneous or

 

      just greater than 3 spontaneous, and I think that

 

      is what your statistician just said, but I guess

 

      the question is does the responder rate for those

 

      with less than 3 at baseline--what type of

 

      responder rates are we looking at for a primary

 

      analysis?

 

                DR. MELE:  For patients with less than 3

 

      spontaneous bowel movements at baseline and looking

 

      at which endpoint?

 

                DR. MANGEL:  Well, it would be greater

 

      than or equal to 3 per week for spontaneous.

 

                DR. MELE:  Yes, we didn't look at it that

 

                                                               186

 

      way.  We looked at 3 or greater for complete

 

      spontaneous.

 

                DR. PRIZONT:  But, you know, I think the

 

      comparison in some ways may not be fair because we

 

      are comparing an increase of 1 complete spontaneous

 

      bowel movement to just a spontaneous bowel

 

      movement.  So, I think the comparison may not be

 

      completely fair in that sense because we are

 

      including complete in one of the arms of the

 

      comparison and not in the other one.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  Regardless of whether we use

 

      spontaneous or complete spontaneous bowel

 

      movements, there is still obviously a difference

 

      between someone who goes from zero bowel movements

 

      a week to 3 bowel movements and someone who goes

 

      from 2 bowel movements to 3.  So, my question for

 

      you is if we just take the responders to Zelnorm,

 

      what was the mean number of increase in bowel

 

      movements versus placebo?  For example, was the

 

      mean 1; was it 2; was it 3?  This would give us

 

      some sense of perhaps the clinical significance. 

 

                                                               187

 

      Rather than just looking at the percent of

 

      responders, what was actually the mean number of

 

      increase in bowel movements?

 

                DR. MELE:  I can answer that question.

 

      The average increase over the 12 weeks was 1.3

 

      complete spontaneous bowel movements in the 6 mg

 

      group versus 0.7 complete spontaneous bowel

 

      movements in the placebo group.

 

                DR. PRIZONT:  This is for the 12-week

 

      response.  The difference was 9 percent.

 

                DR. BUCHMAN:  This is actually looking at

 

      the percentage but I am actually looking at a

 

      different figure, which is the mean.  But I think

 

      that is what we were just told.  The difference was

 

      0.7 versus 1.3.

 

                DR. MELE:  And that is averaged over the

 

      whole treatment period.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  Some of the questions

 

      that I was interested in have been asked but one

 

      still remaining question is I hear what you are

 

      saying in terms of the magnitude, and so forth, but

 

                                                               188

 

      give us a feel for what clinical significance there

 

      is because you are not talking about statistical

 

      significance because it is there.  So, you are

 

      moving the discussion to the clinical significance.

 

      Could you give us some reference numbers so we can

 

      judge these, why aren't they good or why are they

 

      satisfactory?  Given the fact that we are moving to

 

      a different endpoint, we have this complete

 

      spontaneous, and so forth, so give us a context,

 

      please.

 

                DR. PRIZONT:  My response has to be based

 

      on what we know what is normal and what we know

 

      about constipation.  The problem with my response

 

      is what I mentioned about subtypes.  Not all

 

      subtypes of constipation are the same.  The

 

      functional type of constipation is sort of the less

 

      severe of the types of constipation.  In those

 

      cases, I would expect that 3 or more bowel

 

      movements could be clinically significant.

 

                Now, if you take the other subtypes of

 

      constipation, if you take the outlet obstruction

 

      constipation, which is usually in women, younger

 

                                                               189

 

      women, they have more severe type of constipation,

 

      then, you know, we can discuss but there is no

 

      uniformity.  There is no universal agreement on

 

      what is the improvement for all constipation.

 

                DR. D'AGOSTINO:  Yet you are telling us,

 

      if I hear you correctly, that you are not satisfied

 

      with these numbers, that they don't show us

 

      clinical significance.

 

                DR. PRIZONT:  Because I don't know what it

 

      means, that endpoint of increase of 1 complete

 

      spontaneous bowel movement.  Therefore, I am not

 

      sure how much improvement there is in the

 

      constipation.

 

                DR. FOGEL:  We all like counting bowel

 

      movements because it is easy.  We have great

 

      difficulty when it comes to dealing with subjective

 

      symptoms like straining, incomplete evacuation and

 

      symptoms like that.  In his work, Drossman tries to

 

      get around that issue by talking about subjective

 

      global assessment and whether or not you feel

 

      better.  I mean, I think that is the important

 

      clinical outcome that we are interested in.  You

 

                                                               190

 

      haven't presented on this global assessment as to

 

      whether or not you are better by taking therapy.

 

      Do you have any information about that?

 

                DR. PRIZONT:  Well, the sponsor has

 

      information about the global assessment.

 

                DR. FOGEL:  Is there any analysis though

 

      that was done by the FDA?

 

                DR. PRIZONT:  The sponsor did an analysis

 

      on what they call secondary endpoints.  They have

 

      abdominal discomfort, and so on.  Referring to the

 

      secondary--

 

                DR. FOGEL:  No, not the individual

 

      endpoints, but this global assessment.  Are you

 

      better taking the medication than not taking the

 

      medication?  Or, are you better on tegaserod as

 

      opposed to taking placebo, and is that difference

 

      significant?

 

                DR. PRIZONT:  I will relinquish for that

 

      information to the sponsor.  I think they did the

 

      analysis.  I don't have any firm grasp of that.

 

                DR. FOGEL:  Dr. Beitz?

 

                DR. BEITZ:  We don't have an analysis on

 

                                                               191

 

      the global but we have some other endpoints that

 

      you might be interested in seeing.

 

                DR. PRIZONT:  But he is not interested in

 

      the other endpoints.  He is interested in the

 

      global, right?

 

                DR. MELE:  The global did show significant

 

      effects.

 

                DR. FOGEL:  Do you think that that is of

 

      clinical significance?

 

                DR. PRIZONT:  I may think that is of no

 

      clinical significance; you may think that it is of

 

      clinical significance.  That is the difference in

 

      what we are dealing with now in terms of

 

      constipation, which is a sensation of infrequent

 

      evacuation and difficult evacuation, as one

 

      dictionary has defined it.  That is the problem,

 

      that we don't have uniformity in terms of

 

      definition of constipation.

 

                DR. FOGEL:  Dr. Justice?

 

                DR. JUSTICE:  I think the point is we are

 

      really seeking the committee's advice on that.  You

 

      know, we would appreciate your input as to the

 

                                                               192

 

      clinical significance of these findings.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  It might be useful to

 

      consider the data as showing either complete

 

      response, that is, patients who are no longer

 

      constipated by the Rome criteria and that may have

 

      been shown, but I wonder if you could just remind

 

      us of those data again.

 

                DR. PRIZONT:  That was 3 or more bowel

 

      movements per week.

 

                DR. LAMONT:  But there are other criteria

 

      for constipation that were listed by the sponsor

 

      based on the Rome II criteria.  So, I guess my

 

      question is what percent of patients were no longer

 

      constipated by those criteria, either number or

 

      subjective symptoms, at the end of 4 or 12 weeks?

 

                The second comment I have is that in most

 

      clinical trials we look at things like partial

 

      response and complete response.  For example, in

 

      rheumatology trials they look at 20 percent

 

      response, 50 percent response and 70 percent

 

      response by American Rheumatology Society criteria.

 

                                                               193

 

      So, I wonder if we couldn't look here at complete

 

      response being no longer constipated by Rome

 

      criteria and some other partial response.

 

                DR. PRIZONT:  I am going to transfer the

 

      question you asked me to you.  You know, what is

 

      complete response?

 

                DR. LAMONT:  Well, by the Rome criteria

 

      that they used for entry, that they no longer

 

      qualify for constipation by those criteria, which

 

      are established and I think validated.

 

                DR. PRIZONT:  Well, according to their

 

      criteria an increase of one single bowel movement,

 

      complete one single bowel movement is not

 

      constipated per week.

 

                DR. LAMONT:  But that wouldn't apply to

 

      the Rome criteria though.  The Rome criteria

 

      wouldn't accept that as no longer being

 

      constipated, I don't think.

 

                DR. PRIZONT:  Right.  That is what I was

 

      trying--

 

                DR. LAMONT:  No, no, I understand.

 

      Therefore, greater than one complete spontaneous

 

                                                               194

 

      bowel movement per week is some sort of partial

 

      response.  But I am asking what about complete

 

      response, no longer constipated by Rome criteria?

 

                DR. PRIZONT:  The data is there and I

 

      cannot add too much to the data.

 

                DR. LAMONT:  I wonder if anybody else has

 

      parsed the data.

 

                DR. PRIZONT:  As I said, you know, the

 

      Rome II criteria--and I had a small contribution in

 

      that--included two parameters to define

 

      constipation.  You can pick and choose those two

 

      parameters.  They already picked the two parameters

 

      which were frequency and completeness.  Based on

 

      that, that is the data.

 

                DR. FOGEL:  Dr. Beitz has a comment.

 

                DR. BEITZ:  Oh, just that we were going to

 

      ask if the sponsor had done what you said.

 

                DR. FOGEL:  Does the sponsor have any

 

      comments?

 

                DR. DENNIS:  Could I have slide AQ-92,

 

      please?  Remember, we have to put all these into

 

      context in terms of definitions.  What we applied

 

                                                               195

 

      here was to say, okay, let's look at the

 

      definitions we applied at the beginning at the

 

      study and we said, okay, patients had less than 3

 

      complete spontaneous bowel movements and they had

 

      one of the others 25 percent of the time.  Right?

 

      We took out the patients that were IBS-like so they

 

      weren't confounding factors.  Then we said, okay,

 

      let's look throughout the course of the study with

 

      the week 12s and let's look at patients that met

 

      that definition at baseline and met that definition

 

      within the 12-week treatment trial.

 

                Remember, we did not set out to cure

 

      constipation in this trial.  We set out to improve

 

      constipation, and we have to look and see what are

 

      the placebo patients doing versus what the Zelnorm

 

      patients are doing.  We see that at weeks 12 86

 

      percent of patients on placebo are still

 

      constipated and on Zelnorm we have 72 percent of

 

      patients that would still meet that definition.

 

                So, to speak to the previous point about

 

      complete responders, we are seeing some people that

 

      are completely responding, looking at that

 

                                                               196

 

      reduction but, of course, we don't take into

 

      account with this definition improvement in the

 

      constipation symptoms which is what we have seen

 

      before.

 

                Remember, patients had at baseline a

 

      median number of CSBMs of zero and a mean of 0.5.

 

      So, really to get them over that was quite a high

 

      hurdle, and this is just looking at a number but it

 

      doesn't take into account the improvement in the

 

      symptoms that we see as well.

 

                DR. FOGEL:  Thank you.  One quick question

 

      and then we are going to move on.

 

                DR. BUCHMAN:  Just a quick question on

 

      that slide, why were not all the patients

 

      constipated at baseline?  How did you have 15

 

      percent of patients that were in a study on

 

      constipation that weren't constipated when they

 

      entered the study?

 

                DR. DENNIS:  Unfortunately, even though we

 

      have strict criteria for getting into the study,

 

      you always have protocol violators that come in.

 

      When you go back and analyze the data that is what

 

                                                               197

 

      we find by these definitions.

 

                DR. BUCHMAN:  So, wouldn't they have been

 

      excluded when the monitor went by to see them

 

      before they completed the study?

 

                DR. DENNIS:  Well, that should happen in

 

      most cases but you know that the challenge of a

 

      clinical trial design is that it doesn't always

 

      happen so we have to accept that this is what we

 

      have seen in our study.

 

                DR. BUCHMAN:  Because that is a pretty

 

      high number, 15 percent; it is not like 2 percent.

 

                DR. DENNIS:  I am going to ask our

 

      statistician to come and comment on how we handled

 

      that.

 

                DR. LIU:  Jeen Liu.  I am the

 

      statistician.  Actually, I can only add to what

 

      Eslie said, that for the baseline constipation

 

      criteria we had criteria as she had presented.  It

 

      is very difficult actually for the investigator to

 

      check that.  We tried our best.  The percentage

 

      that you see there, part of it comes from the fact

 

      that when we went back to double check the data

 

                                                               198

 

      some of the patients barely missed the criteria and

 

      some of them had too many missing values to be

 

      qualified for this rigorous analysis.

 

                DR. SACHAR:  But the therapeutic aim was

 

      4.8 percent.

 

                DR. LIU:  No, 14.

 

                DR. SACHAR:  No, no, no--

 

                DR. LIU:  I think you are looking at the

 

      wrong treatment.  We should really look at the

 

      first column--

 

                DR. SACHAR:  Right, which is 1.9 and the

 

      last column which is--oh, I see, 14, yes.

 

                DR. BUCHMAN:  Did you analyze patients

 

      separately by those who were constipated at

 

      baseline and exclude the 15 percent that didn't

 

      qualify?

 

                DR. LIU:  I am not following your

 

      question.

 

                DR. BUCHMAN:  If you excluded the 15

 

      percent of patients that were not constipated at

 

      baseline, that really failed study criteria, were

 

      they analyzed separately?

 

                                                               199

 

                DR. LIU:  No, no, we didn't do that.  I

 

      think you are going to get almost the same result

 

      because you basically are just reducing the

 

      denominator by 15 percent.

 

                DR. FOGEL:  Thank you.  We will move on

 

      now.  The last presentation of the morning is by

 

      Dr. Della'Zanna.

 

                        FDA Safety Presentation

 

                DR. DELLA'ZANNA:  I have the benefit of

 

      being the last person presenting so I will try to

 

      keep things moving.  My name is Gary Della'Zanna.

 

      I am a medical officer in the Division of

 

      Gastrointestinal and Coagulation Drug Products.  I

 

      will be presenting some of the agency's concerns

 

      regarding safety issues that were identified during

 

      the postmarketing period.  For some of this

 

      presentation I will be referencing postmarketing

 

      data that was received through the agency's Adverse

 

      Event Reporting System and was analyzed by the

 

      Division of Drug Risk Evaluation.  At this time, I

 

      would like to acknowledge the work of Dr. Allen

 

      Brinker and Ann Corken Mackey who are members of

 

                                                               200

 

      that Division.  Following this presentation they

 

      will be available to answer any postmarketing

 

      questions.

 

                Through 15-day postmarketing safety

 

      reports the agency became aware of several adverse

 

      events that we defined as special interest.  These

 

      included serious consequences of diarrhea such as

 

      hypotension and syncope.  I will also present

 

      updated information on whether the use of Zelnorm

 

      is associated with an increased risk of abdominal

 

      and pelvic surgeries in humans.  I will then focus

 

      the remaining portion of the presentation on

 

      postmarketing reports of ischemic colitis and other

 

      forms of intestinal ischemia.

 

                As already stated by Novartis, Zelnorm is

 

      a 5-HT                                         4 partial agonist.  It

also has moderate

 

      affinity for the 5-HT                                                     

            1B receptor.  The therapeutic

 

      mechanism of action is believed to be based

 

      primarily on its 5-HT                                                    

            4 agonist properties.  The

 

      proposed dose for the chronic constipation

 

      indication is the same as the approved dose for the

 

      constipation-predominant IBS.  If approved, Zelnorm

 

                                                               201

 

      would be the first drug to be granted an indication

 

      specifically for chronic constipation.

 

                In response to postmarketing 15-day safety

 

      reports, the agency worked with Novartis to revise

 

      the Zelnorm package insert.  These revisions were

 

      finalized at the end of April, 2004.  The label now

 

      includes a warnings section about the serious

 

      consequences of diarrhea, including hypovolemia,

 

      hypotension and syncope.  A precautions section

 

      describes ischemic colitis and other forms of

 

      intestinal ischemia.  In addition to this labeling

 

      change, Novartis also mailed a "dear doctor" letter

 

      outlining these changes.  Both of these documents

 

      were included in your background package as

 

      Appendix 1 and 2.

 

                This table shows the most frequent adverse

 

      events during the 12-week portion of the chronic

 

      constipation trials.  These studies did not

 

      identify any new safety concerns.  The incidence

 

      and type of adverse events were similar to what is

 

      already included in the current label.  Other than

 

      diarrhea, there was no appreciated dose response to

 

                                                               202

 

      adverse events.

 

                The incidence of adverse events was higher

 

      during the 13-month extension study.  The increase

 

      in AEs was most likely due to an increase in time

 

      exposure.

 

                Many of the Division's safety concerns

 

      that were identified during the postmarketing

 

      period were not seen in the chronic constipation

 

      trials.  For the remaining portion of this

 

      presentation I will be focusing on adverse events

 

      identified during the postmarketing period as AEs

 

      of special interest.  I will be referencing

 

      spontaneous postmarketing reports received through

 

      the agency's MedWatch program.  This reporting

 

      program is a passive surveillance system that is

 

      designed to detect rare and unexpected events

 

      associated with drug therapy.

 

                To help define the safety profile of

 

      Zelnorm, I will present the postmarketing data as

 

      well as relevant safety data from the chronic

 

      constipation trials and other completed trials for

 

      different indications that had similar design.

 

                                                               203

 

                Because of the postmarketing reports,

 

      serious consequences of diarrhea were identified as

 

      an adverse event of special interest.  This

 

      included cases of diarrhea or complications from

 

      diarrhea that led to an emergency room visit or

 

      hospitalization.  You may notice that the numbers

 

      that we present differ from the sponsor's.  This is

 

      because cases were excluded from the analysis if

 

      the diarrhea was caused by another identifiable

 

      process such as infection.

 

                For this presentation the agency used

 

      April 15, 2004 as a cut-off data for analyzing

 

      postmarketing safety reports.  As of April 15, the

 

      Office of Drug Safety received 22 reports of

 

      serious complications of diarrhea.  Consistent with

 

      the prescribing patterns, the majority of the cases

 

      occurred in female patients.  These patients ranged

 

      in age from 24-82 years, with an average age of 56.

 

      The time to onset of the diarrhea ranged from 1 day

 

      to 210 days, with 5 of the cases occurring on the

 

      first day of therapy and half the cases occurring

 

      during the first week.  Fifteen of the 22 cases

 

                                                               204

 

      required hospitalization; 3 were described as

 

      life-threatening.  In addition to diarrhea, the

 

      complications from the diarrhea included

 

      dehydration, abdominal pain, hypotension,

 

      electrolyte disorders and shock.

 

                During the chronic constipation trials the

 

      frequency and severity of diarrhea was dose

 

      related.  These findings are not surprising

 

      considering Zelnorm's mechanism of action.  And,

 

      6.6 percent of the patients in the 6 mg group

 

      reported diarrhea as an adverse event.  This

 

      compares to 3 percent in the placebo group.  Eight

 

      patients in the 6 mg group discontinued from the

 

      study due to diarrhea compared to 2 in the placebo

 

      group.  Additionally, 7 patients in the 6 mg group

 

      developed severe diarrhea compared to 2 in the

 

      placebo group.

 

                There was an increase in the incidence and

 

      a slight increase in the severity of diarrhea

 

      during the 13-month extension study.  A total of

 

      840 patients continued in to the extension study.

 

      Patients who were receiving placebo during the core

 

                                                               205

 

      study were changed to Zelnorm 6 mg BID for the

 

      extension study.  Overall, 9.5 percent of the

 

      patients reported diarrhea as an adverse event

 

      during the extension study.  For the proposed 6 mg

 

      BID dose this incidence was 10.2.  This is relevant

 

      considering the proposed indication is for chronic

 

      therapy.

 

                There was also a higher incidence of

 

      diarrhea in older patients.  For the proposed 6 mg

 

      BID dose 12.5 percent of the patients 65 years and

 

      older reported diarrhea as an adverse event.  This

 

      compares to only 6 percent in patients younger than

 

      65.  Also, there was a higher proportion of older

 

      patients who discontinued treatment due to

 

      diarrhea.  This is significant considering the

 

      efficacy seen in this population and the potential

 

      number of elderly patients who will be treated for

 

      constipation.

 

                As part of the recent labeling changes,

 

      hypotension is now listed in the warning section of

 

      the current label as one of the serious

 

      consequences of diarrhea.  As of April 15, 2004 the

 

                                                               206

 

      agency received 15 reports of hypotension.  Many of

 

      these cases were confounded by underlying medical

 

      conditions and concomitant medications.

 

                One interesting case, however, occurred in

 

      a 45 year-old female with no past medical history

 

      of cardiac or blood pressure abnormalities.  Prior

 

      to starting Zelnorm, the patient's blood pressure

 

      was recorded at 138/80.  Approximately 2 weeks

 

      after initiating therapy the patient experienced 2

 

      syncopal episodes after standing.  The patient's

 

      blood pressure was recorded as 75/60 at the time.

 

      Additionally, it is worth mentioning that

 

      hypotension was reported in at least 2 other cases

 

      of ischemic colitis.

 

                During the Phase 1 development of Zelnorm

 

      rare cases of hypotension in healthy subjects were

 

      identified.  Because of this, hypotension was

 

      closely evaluated during Phase 3 trials.  The

 

      incidence of orthostatic hypotension was balanced

 

      between treatment groups in the IBS as well as the

 

      chronic constipation trials.

 

                This slide demonstrates the incidence of

 

                                                               207

 

      orthostatic hypotension during the chronic

 

      constipation trials.  This was defined as a drop in

 

      systolic blood pressure of 20 or more mmHg or a

 

      diastolic drop of 10 or more after standing.  Since

 

      hypotension is listed as a complication of diarrhea

 

      in the current label, it is worth noting that none

 

      of the cases of hypotension during the chronic

 

      constipation trials were associated with diarrhea.

 

                Syncope is another adverse event of

 

      special interest.  It is also listed in the

 

      warnings section of the current label as a serious

 

      complication of diarrhea.  As of April 15, 2004 the

 

      agency received 8 postmarketing reports of syncope

 

      or loss of consciousness in patients receiving

 

      Zelnorm.  Most of these patients had other

 

      confounding factors that may have contributed to

 

      the event, however, the role of tegaserod could not

 

      be completely ruled out.

 

                The chronic constipation trials did not

 

      identify any signal for syncope.  Four syncopal

 

      events were reported.  Two occurred in the Zelnorm

 

      group and 2 in the placebo group.  Again, it is

 

                                                               208

 

      worth noting that none of the patients who

 

      developed severe diarrhea during the chronic

 

      constipation trials experienced a syncopal episode.

 

                At the time of the original approval,

 

      there remained questions of whether the use of

 

      Zelnorm was associated with an increased risk of

 

      abdominal and pelvic surgeries.  Nine cases of

 

      symptomatic ovarian cysts were reported during the

 

      IBS trials.  Eight of the 9 cases occurred in

 

      patients treated with Zelnorm.  Only 1 occurred in

 

      the placebo group.  Five of the 9 cases required

 

      surgery, all from the Zelnorm group.

 

                An analysis also identified an imbalance

 

      in the number of cholecystectomies performed in

 

      patients receiving Zelnorm.  These differences,

 

      however, were not statistically significant.

 

                To help identify whether the use of

 

      Zelnorm is associated with an increase in abdominal

 

      or pelvic surgeries, Novartis committed to a Phase

 

      4 pharmacoepidemiology study which is presently

 

      ongoing.  They created an adjudication board

 

      consisting of independent consultants who review

 

                                                               209

 

      all surgeries in a blinded fashion.

 

                As stated earlier, the agency's Adverse

 

      Event Reporting System is designed to detect rare

 

      safety signals.  It is not designed to track

 

      postmarketing reports of common surgeries.  Looking

 

      at the clinical trials, the number of abdominal and

 

      pelvic surgeries performed under chronic

 

      constipation trials were too small to identify an

 

      imbalance.  Two ovarian cyst surgeries were

 

      performed, one in the Zelnorm group and one in the

 

      placebo group.  There was also one patient in the 6

 

      mg Zelnorm group who had a hysterectomy due to

 

      hypermenorrhea.  Only one cholecystectomy was

 

      reported.  This occurred on the 12-week study in a

 

      patient receiving 6 mg Zelnorm BID.

 

                Novartis also analyzed the incidence of

 

      surgery for all completed placebo-controlled

 

      clinical trials of similar design.  The frequency

 

      of abdominal and pelvic surgeries in this pooled

 

      indication population was comparable across

 

      treatment groups, but there was an imbalance in the

 

      number of cholecystectomies.  Looking at all cases

 

                                                               210

 

      of cholecystectomies, the incidence was 4 times

 

      higher in the Zelnorm treatment group.  Even after

 

      the adjudication board excluded 4 cases from the

 

      Zelnorm treatment group, the incidence in the

 

      Zelnorm group was still twice the placebo group.

 

      The clinical significance of this is uncertain.

 

                Due to postmarketing reports of ischemic

 

      colitis and other forms of intestinal ischemia,

 

      they have been identified as adverse events of

 

      special interest.  From the time of approval

 

      through April, 2004 an estimated 2 million

 

      prescriptions for Zelnorm have been filled in the

 

      United States.

 

                As stated earlier, for this presentation

 

      the agency will present cases of intestinal

 

      ischemia that were reported through April 15, 2004.

 

      As of April 15, the agency received 24

 

      postmarketing reports of bowel ischemia.

 

      Considering the "dear doctor" letter was not

 

      finalized until the end of April, this cut-off date

 

      does not allow for the increased reporting which

 

      typically occurs when physicians become aware of a

 

                                                               211

 

      problem.  For example, the agency received 9

 

      additional cases of intestinal ischemia between

 

      April 15 and June 1.  A summary of these cases was

 

      provided in the background packet under Appendix 3.

 

                For the safety review, the agency

 

      separated out ischemic colitis from other forms of

 

      intestinal ischemia, focusing on the 20

 

      postmarketing cases of ischemic colitis received

 

      through April 15.  Nineteen were female, ranging in

 

      age from 26-82 years, with an average age of 55.

 

      The time to onset of ischemic colitis ranged from 1

 

      day to almost 400 days.  As for the safety reports,

 

      the majority of the patients who developed ischemic

 

      colitis were treated for IBS.  Four patients were

 

      treated off-label, 2 for constipation, 1 for

 

      postoperative ileus and 1 for an unknown

 

      indication.

 

                Thirteen of the 20 patients required

 

      hospitalization.  One of these required surgery and

 

      one died.  The agency is concerned that these cases

 

      represent a drug-induced ischemic colitis.

 

      However, a causal relationship is difficult to

 

                                                               212

 

      prove.  But it is suggestive when one considers

 

      that these 5 of the 20 reported cases had no

 

      documented risk factors.  Three cases occurred on

 

      the first day of therapy and 2 of the 3 cases

 

      occurred in patients with no documented risk

 

      factors, as in case 6 and 8 on this slide.  The

 

      remaining 15 patients had 1 or more identifiable

 

      risk factor such as hormonal therapy, tobacco use

 

      or vascular disease, but that does not exclude the

 

      possible relationship with Zelnorm.

 

                The Division assigned the definition of

 

      other intestinal ischemia to cases of ischemic

 

      bowel that resulted from a large vessel process

 

      such as a mesenteric artery occlusion.  All 4 cases

 

      meeting this definition occurred in female patients

 

      ranging in age from 41 to 67 years.  Postmarketing

 

      reports described 3 of the 4 patients were treated

 

      for IBS.  One was treated off-label for

 

      constipation.  All 4 were hospitalized, with 3 of

 

      the patients requiring surgery.  One had a bowel

 

      resection.  The other 2 had exploratory

 

      laparotomies.  Three of the 4 patients died.  The

 

                                                               213

 

      Division acknowledges that all 4 patients had

 

      significant confounding medical conditions but the

 

      role of tegaserod cannot be completely ruled out.

 

                The Division concluded that a thorough

 

      review of the chronic constipation trials, as well

 

      as a focused review of the IBS studies and other

 

      completed clinical trials of similar design did not

 

      identify any cases suspicious for ischemic colitis

 

      out of approximately 12,000 patients.  Using the

 

      available data, the Office of Drug Safety estimated

 

      that approximately 7,000 patients were randomized

 

      to Zelnorm among the placebo-controlled trials that

 

      were at least of 3 months duration.  Based on

 

      application of Poisson distribution, it would

 

      suggest that, with 95 percent confidence, ischemic

 

      colitis occurs no more often than 1 in 2,000 in

 

      this type of patient.

 

                The agency is seeking the committee's

 

      advice on whether reference to ischemic colitis and

 

      other forms of intestinal ischemia should be moved

 

      to the warning section of the package insert.  It

 

      is the agency's position that the appearance of

 

                                                               214

 

      these events in young patients in close temporal

 

      association with Zelnorm is concerning.  These

 

      conditions are generally considered a disease of

 

      the elderly.  Consider 7 of the 20 cases occurred

 

      in patients less than 49 years of age, with 2 of

 

      the patients less than 30.  As stated before, 5 of

 

      the 20 cases had no documented risk factors.  Three

 

      cases occurred on the first day of therapy, with 2

 

      of the 3 cases occurring in patients with no

 

      reported risk factors.  In the month following the

 

      labeling change and "dear doctor" letter an

 

      additional 9 cases were reported.  Since June 1, 5

 

      more cases have been received.  This brings the

 

      total to 14 new cases reported since the labeling

 

      change.  These cases have not been formally

 

      adjudicated with the sponsor.

 

                The agency would also like the committee's

 

      opinion on whether the patients with IBS have a

 

      higher background incidence of ischemic colitis.

 

      Novartis argues there is no causal relationship

 

      between the use of Zelnorm and the development of

 

      ischemic colitis.  It is our position, based on

 

                                                               215

 

      several published studies conducted within

 

      administrative claims databases, that there is a

 

      higher background incidence of ischemic colitis in

 

      IBS patients.  The agency reviewed the available

 

      data Novartis used to support an association

 

      between ischemic colitis and IBS and found no

 

      compelling evidence to suggest that a clinically

 

      robust diagnosis of IBS is associated with any

 

      increased risk for ischemic colitis.

 

                In contrast, it is the agency's position

 

      that an association between IBS and ischemic

 

      colitis is attributable to the use of a

 

      non-specific ICD9 code used in the databases.  This

 

      code includes IBS and other bowel processes.  We

 

      believe this resulted in a misclassification or a

 

      misdiagnosis of patients who were actually

 

      undergoing a workup, the code representing an

 

      interim diagnosis.

 

                Novartis also defends their position

 

      stating that no mechanism of action has been

 

      identified in the animal models.  It is the

 

      Division's opinion that a mechanism of action has

 

                                                               216

 

      not been ruled out and that there may be cross

 

      reactivities with other receptors and ligands that

 

      have not been identified.  Zelnorm is a 5-HT4

 

      partial agonist with moderate affinity for the

 

      5-HT1B receptor.  There is recent medical literature

 

      proposing a link between Zelnorm and the develop of

 

      Raynaud's phenomenon, a vascular disorder that can

 

      affect the fingers and toes.

 

                The article presents a case history of a

 

      21 year-old female with no prior history of

 

      Raynaud's who developed painful discoloration of

 

      her fingertips after cold exposure.  This occurred

 

      2 days after initiating Zelnorm.  Symptoms

 

      disappeared completely after the drug was

 

      discontinued.  Although a mechanism of action for

 

      this process has not been identified, causality is

 

      strongly suggestive considering the patient had no

 

      prior history of Raynaud's, was not on any

 

      concomitant medications and the symptoms resolved

 

      after discontinuing Zelnorm.

 

                Another article discusses the potential

 

      risk for Zelnorm-induced coronary-artery spasm. 

 

                                                               217

 

      The article, titled, "Tegaserod-Induced Myocardial

 

      Infarction: Case Report and Hypothesis," proposes

 

      that since tegaserod has moderate affinity for the

 

      5-HT1B receptor, it is plausible that tegaserod

 

      could cause coronary-artery contraction and spasm

 

      similar to other 5-HT                                                    

            1 receptor agonists on the

 

      market, such as those used for treating migraines.

 

                Although these 2 articles are not

 

      conclusive, they do support the Division's position

 

      that a mechanism of action explaining an

 

      association between Zelnorm and ischemic colitis

 

      has not been completely ruled out.  In response to

 

      the agency's concerns, Novartis has agreed to

 

      perform additional mechanistic studies.

 

                In summary, chronic constipation trials

 

      did not identify any new safety concerns.  The

 

      Division is concerned that there are limited safety

 

      and efficacy data on male patients, as well as a

 

      questionable risk/benefit profile for patients 65

 

      years and older.  Only 12 percent of the patients

 

      enrolled in the chronic constipation trials were

 

      male.  The efficacy of Zelnorm in patients 65 years

 

                                                               218

 

      and older was similar to that of placebo.  These

 

      patients also had a higher incidence of diarrhea as

 

      an adverse event.  Additionally, considering how

 

      common constipation is in the elderly, only 13

 

      percent of the patients enrolled were older than

 

      65.

 

                Many of the Division's safety concerns

 

      that were identified during the postmarketing

 

      period have been addressed with the recent labeling

 

      changes.  Serious consequences of diarrhea are now

 

      listed in the warning section of the label.

 

      However, the chronic constipation trials

 

      demonstrated that elderly patients had little

 

      efficacy and may be at higher risk for developing

 

      complications from diarrhea.  The label should be

 

      revised to reflect this.

 

                The question of whether the use of Zelnorm

 

      is associated with an increased risk of surgery

 

      remains unknown.  Phase 4 studies are ongoing.  The

 

      background incidence of ischemic colitis in the

 

      general population, as well as the IBS population

 

      continues to be debated.  The Division questions

 

                                                               219

 

      whether the available data justifies placing

 

      ischemic colitis in the warning section of the

 

      label.

 

                I do have one update that I would like to

 

      share with you.  We got this from an AERS MedWatch

 

      report update yesterday.  It is case 25 in my

 

      background pack.  Initially I just had a

 

      description term of a young female with findings

 

      consistent with ischemic colitis and I had no other

 

      information.  We got an update.  That patient was

 

      31 years old.  She was treated for IBS.  Prior to

 

      therapy she had a clean upper and lower endoscopy.

 

      Approximately 5 months after initiating therapy she

 

      presented to the emergency room with rectal

 

      bleeding and had a colonoscopy performed that day

 

      that demonstrated superficial epithelial necrosis,

 

      acute hemorrhage, and the biopsies were consistent

 

      with ischemic colitis.  Stool cultures were

 

      performed.  They were negative.  Hypercoagulative

 

      workup was also negative.  The patient's medical

 

      history only included constipation, endometriosis

 

      and complete hysterectomy and GERD.  The patient

 

                                                               220

 

      was on no other concomitant medications.

 

                Also of interest that I would like to

 

      comment about, the month prior to this event the

 

      patient decreased her dose to 3 mg every other day.

 

      Any questions?

 

                       Questions on Presentation

 

                DR. FOGEL:  Are there any questions for

 

      Dr. Della'Zanna?  Dr. LaMont?

 

                DR. LAMONT:  Yes, has the agency or the

 

      sponsor collected any information from outside the

 

      United States on ischemic colitis?  Has everything

 

      we have seen here related to U.S. patients only?

 

                DR. MACKEY:  One of the ischemic colitis

 

      cases was from Canada, and we have had no other

 

      cases outside the U.S.

 

                DR. FOGEL:  Dr. Metz?

 

                DR. METZ:  Thank you very much for a very

 

      nice summary.  I am starting to realize that the

 

      older you get, the less the effect; the more

 

      concern for a confounding diagnosis that is going

 

      to end up like a secondary causal constipation or

 

      maybe, you know, not a true idiopathic constipation

 

                                                               221

 

      patient, and maybe more of a worry about potential

 

      diarrhea or ischemia.

 

                With the postmarketing data that is out

 

      there, I want to know how much exposure we really

 

      have to measure these patients.  The briefing

 

      document, unfortunately, photocopied very badly.

 

      The IMS is really the only data we got.  I mean,

 

      the other postmarketing stuff is isolated reports

 

      and it is not very robust, but with IMS you can

 

      actually get an idea.  How many patients, what

 

      percentage of patients at various age groups have

 

      actually received this drug for any length of time

 

      both split by gender and split by age?  That would

 

      be very useful to me.

 

                DR. DELLA'ZANNA:  I would like to

 

      introduce Dr. Allen Brinker.

 

                DR. BRINKER:  I will speak to that just

 

      briefly.  Yes, IMS can give us a very good handle

 

      on drugs.  The kicker with the use of Zelnorm is

 

      the short-term use.  So, it has been my position

 

      and I have argued that it is very difficult to

 

      model use at all because of the short-term use

 

                                                               222

 

      data.  So, I think this is akin to the triptans in

 

      that regard because some people are going to use it

 

      for a week.  It is indicated only for short-term

 

      use and people are going to stop it really quick.

 

      So, I am reluctant to try to tell you that I have a

 

      good handle on where the patient years are to help

 

      you with the denominator.  Perhaps the sponsor

 

      could try to outline--I mean, we have some profiles

 

      on prescriptions only but I am not going to tell

 

      you that I know that those distributions accurately

 

      reflect how patients end up taking the drug.

 

                DR. LAMONT:  With the IMS data you

 

      actually can see when the prescription is, repeat

 

      prescription as opposed to a new prescription, and

 

      you can get that information and you can get the

 

      ages of those patients too.

 

                DR. BRINKER:  There are databases where

 

      you can do that and with claims databases you can

 

      do that, that is correct.  But then you have to

 

      decide for yourself whether or not those are

 

      representative of the population at large, and we

 

      have chosen not to do that.  Most of our analyses

 

                                                               223

 

      have been qualitative.

 

                DR. FOGEL:  Dr. Joelsson, do you have a

 

      comment?

 

                DR. JOELSSON:  We have some data we can

 

      show you and we can discuss how relevant they are

 

      or not.  We have a pie chart here which shows the

 

      distribution of age.  As you can see, the majority

 

      is in patients under the age of 60--slightly young.

 

      Does that answer your question?

 

                DR. LAMONT:  Do you have it by gender as

 

      well?

 

                DR. JOELSSON:  I think so, yes.  Can we

 

      have the gender slide?  So, 7 percent male have

 

      tried this drug--mostly women.  So, 7 percent male

 

      and 93 percent women.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  I was curious about the

 

      motivation for the opinion requested and changing

 

      from a precaution to a warning, considering that

 

      the label change was just a few months ago.  Is it

 

      because you are concerned about the increased

 

      number of reports following the "dear doctor"

 

                                                               224

 

      letter and label change, or is it a convenience

 

      issue because the committee happens to be meeting

 

      now?  In your briefing document you mention that

 

      the first case came in, I believe, in March, 03 and

 

      the label change occurred in April, 04.  To make a

 

      change now, I am curious--

 

                DR. DELLA'ZANNA:  What is our motivation?

 

                DR. MANGEL:  yes.

 

                DR. DELLA'ZANNA:  To keep things on base,

 

      we were in negotiations for where we were going to

 

      put this in the label.  We were initially hoping to

 

      put it in the warning section.  We were in

 

      negotiations, that were prolonged, with the

 

      sponsor.  We could not reach an agreement but we

 

      also didn't want to be completely one-sided.  We

 

      agreed to meet and place it into the precautions

 

      section and discuss it at the advisory committee

 

      meeting.  This was a compromise on both of our

 

      parts.

 

                DR. MANGEL:  Could I ask a follow-up to

 

      that?  If there would be a label change--you

 

      probably might not have concluded this, would there

 

                                                               225

 

      be a "dear doctor" letter, etc.?  With increased

 

      communication about it, it may be confusing for the

 

      prescriber whether or not there has been a new

 

      signal in the next three months or with the

 

      original placement was just incorrect.  Have you

 

      thought in terms of there would be a label change

 

      what type of communications would accompany that?

 

                DR. DELLA'ZANNA:  Well, I don't know

 

      whether I would say that the placement was

 

      incorrect.  Okay?  This is a developing signal

 

      possibly.  We are looking at an increased number of

 

      cases which also might increase our concerns.  So,

 

      I don't know if I would agree with you that we

 

      didn't place it correctly the first time.  The goal

 

      was to come to an agreement; be able to get a "dear

 

      doctor" letter out to make the public aware and

 

      physicians aware of our concerns as soon as

 

      possible without having to go through any further

 

      delay of releasing this information.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  I would like to express my

 

      general unhappiness with the way the safety data

 

                                                               226

 

      have been presented, particularly by the sponsor.

 

      It is a very one-dimensional way, basically giving

 

      the cumulative frequency.  Adverse effects have

 

      other dimensions--very little about severity.  The

 

      other one would, for example, be pain.  They are

 

      equating a single episode of pain to constant pain

 

      for six weeks.  I wish we had a little bit more

 

      information about those aspects, the other

 

      dimensions, because I am unwilling to buy the fact

 

      that the drug has very few adverse effects just

 

      based on the cumulative frequency.

 

                DR. FOGEL:  Thank you.  Dr. Cryer?

 

                DR. CRYER:  As I think about this issue, I

 

      am really kind of focusing in on the subgroup

 

      analyses of the subpopulation where there was

 

      modest or no treatment effect shown, specifically

 

      again the older age and the men.  In kind of making

 

      that comparison, you showed us nicely a breakout of

 

      this adverse effect of diarrhea by age.  I was

 

      wondering if you have done a similar analysis by

 

      gender, the incidence of adverse effects or

 

      specifically diarrhea.

 

                                                               227

 

                DR. DELLA'ZANNA:  I do not have that with

 

      me.  I have it as part of my final review.  I don't

 

      remember it off the top of my head.

 

                DR. FOGEL:  Yes?

 

                DR. DENNIS:  This is a slide showing

 

      adverse events broken down by males.  So, this is

 

      the slide that shows you that in the male

 

      population the adverse event that was seen more

 

      frequently was diarrhea, which is what we saw in

 

      the female population where diarrhea was more

 

      frequent than in the placebo--the males and the

 

      females.

 

                DR. CRYER:  Thank you.  That answers my

 

      question.

 

                DR. FOGEL:  I would like to thank the FDA

 

      for their presentations.  We are going to break now

 

      for lunch.  We will resume again at 2:15.  For the

 

      committee, we are going to be taken across the

 

      street to Cafe Gallery.  We will start again at

 

      2:15.

 

                [Whereupon, at 1:10 p.m., the proceedings

 

      were recessed for lunch.]

 

                                                               228

 

                A F T E R N O O N  P R O C E E D I N G S

 

                          Open Public Session

 

                DR. FOGEL:  Good afternoon.  I would like

 

      to start the afternoon session, if I can have

 

      everyone's attention, please.  The first item of

 

      business this afternoon is the open public hearing

 

      and there are three presenters.  Before we call the

 

      presenters to the podium, there is a statement that

 

      has to be read.

 

                Both the Food and Drug Administration and

 

      the public believe in a transparent process for

 

      information gathering and decision making.  To

 

      ensure such transparency at the open public hearing

 

      session of the advisory committee meeting, FDA

 

      believes that it is important to understand the

 

      context of an individual's presentation.

 

                For this reason, FDA encourages you, the

 

      open public hearing speaker, at the beginning of

 

      your written or oral statement to advise the

 

      committee of any financial relationship that you

 

      may have with the sponsor, its product and, if

 

      known, its direct competitors.  For example, this

 

                                                               229

 

      financial information may include the sponsor's

 

      payment of your travel, lodging or other expenses

 

      in connection with your attendance at the meeting.

 

      Likewise, FDA encourages you at the beginning of

 

      your statement to advise the committee if you do

 

      not have any such financial relationships.  If you

 

      choose not to address this issue of financial

 

      relationships at the beginning of your statement,

 

      it will not preclude you from speaking.

 

                The first speaker will be Jeffrey Roberts.

 

                MR. ROBERTS:  Thank you.  I am Jeffrey

 

      Roberts, and I am here today representing patients

 

      and sufferers.  I have paid all my own expenses to

 

      be here.

 

                Members of the committee, thank you for

 

      the opportunity to appear before you.  I am the

 

      president and founder of the Irritable Bowel

 

      Syndrome Self Help and Support Group and founder of

 

      the Zelnorm Action Group.  The 10,000 member

 

      Irritable Bowel Syndrome Self Help Group has

 

      endeavored, since 1987, to educate and provide

 

      support for people who have functional

 

                                                               230

 

      gastrointestinal disorders, and to encourage both

 

      medical and pharmaceutical research to make our

 

      lives easier via a successful Internet website for

 

      sufferer.

 

                I have been a sufferer of

 

      diarrhea-predominant irritable bowel syndrome for

 

      over 25 years.  Much like chronic constipated

 

      individuals, there are challenges that I face each

 

      and every day in order to cope with my functional

 

      gastrointestinal disorder.  It affects my family's

 

      lives, my career and I am constantly reminded of my

 

      own physical limitations because of this very

 

      burdensome illness.

 

                Today I have the support of the Zelnorm

 

      Action Group, Irritable Bowel Syndrome Self Help

 

      Group and Irritable Bowel Syndrome Association.  I

 

      am privileged to act as the representative today

 

      for all those members who were too ill to travel

 

      here today.  I would also like to acknowledge all

 

      of the efforts today.

 

                Functional constipation is a common

 

      problem in our community, with its prevalence

 

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      rating from 2 percent to 28 percent.  Its diagnosis

 

      is made by careful delineation of its duration and

 

      characteristics.  Constipation classification into

 

      subtypes results in overlapping symptoms and

 

      blurring between the subtypes.  The distinction

 

      between IBS with constipation and functional

 

      constipation is important as a focus in treating

 

      functional constipation is to improve bowel habits

 

      alone.  In an IBS patient abdominal pain and other

 

      symptoms must also be addressed.  Most chronically

 

      constipated patients do not require diagnostic

 

      studies beyond a careful history and physical

 

      examination.  For clarification purposes, my

 

      presentation today refers to individuals with only

 

      functional constipation lasting longer than 6

 

      months, and widely given the name of chronic

 

      constipation.

 

                As I am a focus in the community for

 

      information about functional gastrointestinal

 

      intestinal disorders, I communicate with a great

 

      many people who have run out of options.  They do

 

      not know where to turn and their quality of life

 

                                                               232

 

      has greatly suffered.  Many current approaches to

 

      chronic constipation, including the use of fiber,

 

      osmotic and stimulant laxatives, biofeedback

 

      training and surgery, often fail to control the

 

      patient's symptoms adequately.  They produce

 

      problematic side effects or lose effectiveness with

 

      time.  Most available and approved drugs for

 

      constipation have been passed down from antiquity

 

      and have not been tested in modern well-designed

 

      studies.

 

                Primary care physicians and the sufferers

 

      believe there are very few other options available

 

      to them because chronic constipation is not usually

 

      deemed of clinical importance until it causes

 

      physical risks or impairs quality of life.

 

      Physicians often prescribe drugs for constipation

 

      with which they are familiar and comfortable and in

 

      most cases anything will do.

 

                Chronic constipation is a very unpleasant

 

      disorder and in some cases individuals who suffer

 

      from chronic constipation do not have a bowel

 

      movement for up to 21 days.  Their quality of life

 

                                                               233

 

      is greatly diminished by this basic impaired

 

      function that most individuals take for granted.

 

      They may pass hard stools; lack the ability to

 

      defecate on demand; or strain at every bowel

 

      movement.  I am here today to tell you that chronic

 

      constipation is a condition which cries out for

 

      more attention.  It demands the continued use of a

 

      medication, Zelnorm, already proven in treatment of

 

      functional constipation and IBS-predominant

 

      constipation.  This committee must provide clear

 

      indication to the medical community that Zelnorm

 

      should additionally be made available for the

 

      indication of chronic constipation without any

 

      further burden to the physician or patient in

 

      prescribing this medication or getting access to

 

      this medication.

 

                As with Lotronex, a drug with the opposite

 

      effect of Zelnorm, i.e., for severe functional

 

      diarrhea individuals, this committee listened to

 

      myself and others from the Lotronex Action Group in

 

      April, 2002 make presentations as to how difficult

 

      it is to live with gastrointestinal disorders. 

 

                                                               234

 

      Although many of us do now have access to Lotronex,

 

      we are challenged by physicians who lack the

 

      knowledge or are fearful of prescribing a

 

      medication because of a negative message about its

 

      use.

 

                Zelnorm has an admirable safety record in

 

      clinical trials in general use.  Its virtue should

 

      be celebrated and not limited in its usefulness as

 

      a medication to ease the suffering of a chronic

 

      constipation individual.

 

                An electronic survey was recently

 

      conducted by the Zelnorm Action Group.  Individuals

 

      were screened so that results were recorded only

 

      for those prescribed Zelnorm after indicating their

 

      symptoms of chronic constipation to their primary

 

      care physician.

 

                While taking Zelnorm, chronic constipation

 

      sufferers report a quality of life that is

 

      dramatically better.  Seventy-nine percent of those

 

      surveyed indicated that they had no significant

 

      side effects at all.

 

                The Zelnorm Action Group is prepared to

 

                                                               235

 

      place educational information about Zelnorm on

 

      their website in order to reach out to the chronic

 

      constipation community.  This provides an effective

 

      forum for educating chronic constipation sufferers

 

      about Zelnorm's proper use.

 

                In conclusion, the quality of life of

 

      constipation sufferers was dramatically improved

 

      with access to Zelnorm.  The medical community

 

      should be informed that a treatment is available

 

      which will improve the patient's outlook.  Adverse

 

      events should not deter either the pharmaceutical

 

      or the FDA from maintaining the drug's

 

      availability.

 

                Zelnorm has a place as an effective

 

      treatment for chronic constipation sufferers and

 

      should be indicated as such to the patient and

 

      medication community.  Thank you.

 

                DR. FOGEL:  Thank you.  The second speaker

 

      is Constance Hill.

 

                MS. HILL:  Good afternoon.  I also am here

 

      on my own behalf and I haven't been paid by anyone.

 

      Mr. Chairman and members of the committee, my name

 

                                                               236

 

      is Connie Hill and I have chronic IBS with

 

      constipation.  I have had this terrible disease

 

      since I was about 18.  Over the years my symptoms

 

      became increasingly worse and eventually became so

 

      severe and debilitating that I had to make

 

      significant life-altering changes to survive.

 

                In 1996, I had to quit my job as a legal

 

      assistant and stop working altogether.  My husband

 

      and I even moved from the hustle and bustle of

 

      Fairfax County, Virginia to the country, hoping

 

      that a slower pace of living would ease my

 

      symptoms.  Even these drastic life-style changes

 

      did not help.  Over the years I have consulted with

 

      many physicians and tried every remedy and drug

 

      that doctors recommended but none of the treatments

 

      worked.  The doctors seem to find IBS as baffling

 

      as do the millions of Americans who suffer daily

 

      from this disease.

 

                I was told by one well-known

 

      gastroenterologist that I have a terrible mental

 

      problem and until I came to grips with it I would

 

      never get well.  I was sent to a psychiatrist for

 

                                                               237

 

      several months, at the end of which I was no

 

      better.

 

                One department head at Fairfax Hospital

 

      told me I have a floating rib and prescribed muscle

 

      relaxers.  Others recommended biofeedback and

 

      acupuncture, which I also tried and failed.  But

 

      none of these treatments gave me any relief from

 

      the daily pain and discomfort that I had to endure.

 

      I became so desperate I even resorted to

 

      exploratory surgery to determine whether or not

 

      adhesions from an earlier surgery were causing the

 

      problem.  Unfortunately, this was not the case.

 

      The bottom line is the medical professionals don't

 

      really understand IBS and are very frustrated by

 

      their inability to effectively treat it.  I have

 

      sensed over the years that most physicians would

 

      rather not deal with difficult cases of IBS.  This

 

      was so discouraging to me, and I am sure other IBS

 

      victims encountered the same indifference from the

 

      medical community.

 

                Zelnorm is the one and only drug that has

 

      given me any relief and restored any part of a

 

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      normal life for me.  My life before Zelnorm was a

 

      living hell.  I suffered daily with pain and

 

      discomfort, reaching head-banging proportions.  I

 

      never got a day off from the pain and the misery.

 

      One weekend shortly after I got the definitive

 

      diagnosis, I sent my family away for the weekend

 

      and planned to kill myself.  I couldn't deal with

 

      the fact that I was told I would have this pain and

 

      suffering for the rest of my life.  I was working

 

      at the time.  I spent a lot of time either in the

 

      ladies' room or crying at my desk.  I couldn't

 

      explain to all the people at work what I was

 

      dealing with, it is so embarrassing that unless you

 

      own this problem you can't possibly understand what

 

      it does to you and your loved ones.  It is

 

      degrading and demoralizing.  It breaks your spirit

 

      and kills your ability to smile and enjoy anything

 

      normal.

 

                After getting through the workday you just

 

      want to go home, rip off your clothes and crawl

 

      into the fetal position.  I lived like this from

 

      1985 until I was forced to retire from the job that

 

                                                               239

 

      I loved, in 1996.  In 1997, we moved out of the

 

      city.  I became a couch potato.  I would rush to

 

      get dressed by 6:00 p.m. so that when my husband

 

      came home from work he wouldn't know I spent the

 

      entire day unable to do anything.  There are no

 

      vacations, movies, dinners, cookouts and other

 

      normal day-to-day activities for someone with IBS.

 

      It is not life-threatening per se but it leaves you

 

      riddled with pain, kills your spirit and makes you

 

      a prisoner in your own home.

 

                I have been a member of the on-line

 

      support group for many years.  I have tried

 

      everything that was suggested and failed.  When I

 

      first heard about Zelnorm, in late 2001, from the

 

      support group it was only available in Mexico.  I

 

      was planning to go there but then learned that it

 

      was also available by prescription from

 

      Switzerland.  I was able to make contact with a

 

      pharmacy in Switzerland.  I have a wonderful

 

      internist who agreed to write me a prescription and

 

      I received my first box of Zelnorm a few weeks

 

      later.  After working to get the correct dose, I

 

                                                               240

 

      started to be able to do a few things.  I didn't

 

      spend all day on my couch.  I actually had part of

 

      the day when things were relatively normal.  It

 

      wasn't the panacea I had dreamed of but it was a

 

      major step forward.

 

                I have taken Zelnorm now for two and a

 

      half years.  It is a dramatic improvement for me.

 

      Although not a complete cure, it has greatly

 

      enhanced the quality of my life.  Before Zelnorm

 

      was developed I prayed daily for guidance to help

 

      me out of the hell hole I was in.  I thank God for

 

      the guidance to the support group which helped me

 

      find this life-altering drug.

 

                I am not only speaking for myself but for

 

      the millions of people in the U.S. and all around

 

      the world who suffer daily with this terrible

 

      disease.  There is no other effective treatment for

 

      IBS with constipation.  If Zelnorm was ever taken

 

      off the market, you will be condemning me and many

 

      other IBS sufferers to the same torturous existence

 

      that we had to endure without hope before Zelnorm.

 

      If you do that, I don't know how I will be able to

 

                                                               241

 

      go on.

 

                I strongly object to the recommendations

 

      of some groups that a change in diet will relieve

 

      the suffering of constipation.  Their suggestions

 

      for alternative treatments are so naive.

 

      Obviously, they have not had to live with this

 

      disease and do not understand that these simple

 

      steps do not bring relief to people who suffer from

 

      severe IBS with constipation.  I have tried their

 

      suggestions and they don't work.  Zelnorm is the

 

      only treatment that makes a difference and I

 

      beseech you to enhance its certification.  Thank

 

      you.

 

                DR. FOGEL:  Thank you.  The third speaker

 

      is Linda Roepke.

 

                MS. ROEPKE:  Good afternoon, everyone.

 

      Mr. Chairman, thank you for allowing me to have

 

      time today to come up and say a few words about how

 

      Zelnorm has affected my life.

 

                Allow me first of all to introduce myself.

 

      My name is Linda Roepke and I am from St. Louis.  I

 

      am very blessed in that I work at St. Louis

 

                                                               242

 

      University and I work with a fine staff of

 

      different physicians.  I work with the Chairman of

 

      Internal Medicine.

 

                Today I am not only blessed but very lucky

 

      to have a very good GI doctor who has helped me

 

      through many years of a chronic problem with

 

      constipation.  Prior to finding my specialist in

 

      the GI division today, my primary care physician

 

      for the last 20 years of my life really did not

 

      know anymore how to treat my constant stomach

 

      aches, as I will refer to them because I don't know

 

      how else to describe to you--I am sure most of you

 

      have been constipated at one time or another and

 

      you know that heavy feeling that you have.  That

 

      was a very chronic thing for me.  Being bloated is

 

      supposed to be a "woman" thing so, you know, I will

 

      give the medical profession part of that.  However,

 

      that bloatedness can take the average waistline,

 

      whether you are male or female, from a 26 to a 30,

 

      or from a 32 to a 38 in no time.

 

                My general health is very good, with the

 

      exception of irritable bowel which has caused more

 

                                                               243

 

      chronic constipation than it has diarrhea.  It is a

 

      most serious condition to live with.  I tell you

 

      these things for two reasons.  Number one, during

 

      the years that I have suffered with constipation,

 

      as anyone else who has had the same problem will

 

      tell you, life is not real normal.  It is very

 

      miserable.  You have many low points.  You are not

 

      able to contend with a lot of daily normal life's

 

      instances.  I also tell you this to testify to my

 

      own credibility.

 

                As a child I not only knew, I had a lot of

 

      stomach aches, too much pain in my abdomen.  My

 

      parents certainly knew it.  I was a main topic of

 

      their conversation for years.  By the time I was 12

 

      my mother was telling me that, you know, once you

 

      start menstruating you are going to feel better.

 

      This feeling in your abdomen will get less and

 

      less.  During high school years I obviously had a

 

      written excuse for the majority of our PE classes

 

      because I didn't have the energy to really do them.

 

      My family doctor at the time, our family physician,

 

      eventually, in my senior year in high school, too

 

                                                               244

 

      me for an exploratory surgery, again, not knowing

 

      really what to do.  I hopes of finding something

 

      wrong for the sake of not having to have this

 

      embarrassing problem, I was hoping for just about

 

      anything.  Unfortunately, nothing was found.  My

 

      bowels just move slow, quote/unquote, is what is

 

      written in my charts going back to 1964.

 

                I had a spastic colon which would force me

 

      to go through surges of either diarrhea or then

 

      maybe five, six, seven days with not being able to

 

      go to the bathroom.  During those years my mother

 

      and our family doctor would give me little Elephon

 

      [?] pills from Walgreen's.  I don't know, I think

 

      most of you are of an age that you probably

 

      remember this.  That was their laxative of choice,

 

      both of them.  My bowels would straighten out for a

 

      while and then they would get wacky again.  The

 

      sluggishness and diarrhea made even dating

 

      difficult.  I continued with over-the-counter

 

      laxatives for the next 30 years, fighting abdominal

 

      pain, cramping, embarrassing situations, playing

 

      with laxatives, and I have tried them all.  Many of

 

                                                               245

 

      them have been prescribed, with it be from

 

      Metamusal, Duclolax, suppositories, it doesn't

 

      matter--been there; done that.

 

                This is not an easy thing to try to work

 

      with your doctor and being certain that you are

 

      keeping your body physically as fit as you can.

 

      Many times I walked around, looking at though I

 

      could be four months pregnant--always not.

 

      Everywhere I worked, most people have learned--I am

 

      always a topic of conversation, I guess I should

 

      say.  I have been the topic of more than one

 

      laughing piece of conversation about "don't follow

 

      her into the bathroom because you might hear just

 

      an explosion."  These are embarrassing things for

 

      any of us out there.  This is a delicate topic in

 

      the first place.  It certainly isn't one I choose

 

      to share with my co-workers.

 

                In 1994, I drove myself to an emergency

 

      room.  The final diagnosis was that I needed a

 

      series of tests again run.  I wonder how many blood

 

      samples I have had taken to find out that I am

 

      chronically constipated.  The doctor did a complete

 

                                                               246

 

      upper and lower GI series with the barium, hoping

 

      to find something.  Again, nothing was found.

 

      Again, I was referred to a nutritionist.  Again, I

 

      was told that I eat a far better diet than the

 

      majority of the people out here and my exercise

 

      content was pretty good.

 

                My doctor at that time prescribed Senokot,

 

      laxatives and more fiber--35-40 grams of fiber is a

 

      lot of fiber.  So, 40 years later I found myself in

 

      the same situation.  When I finally walked into--I

 

      didn't walk into our GI division, I barged into my

 

      doctor's academic office, embarrassed and knowing

 

      that working for the chairman of internal medicine

 

      I resent people who try to get past me, the guard,

 

      and, yet, I just pulled the same thing with her.  I

 

      had tears in my eyes.  She looked up from her

 

      computer, because this is not in a clinic setting,

 

      and said, "what's up?"  The tears rolled down my

 

      face, "can you help me?" to make a long story

 

      short.  She continued to say, yes, there is help

 

      and I do not need to keep suffering like this.

 

      This is ridiculous and she will get me into her

 

                                                               247

 

      clinic and she will get several tests set up for

 

      me.  So, for the next many months we went through a

 

      battery of different things because, again, it is

 

      important that we stress that constipation is just

 

      constipation.  I don't have cancer; I don't have a

 

      grapefruit in my stomach; I don't have a large

 

      cyst.

 

                So, I got very lucky.  I went through an

 

      anorectal manometry, colon transit and a

 

      colonoscopy.  Considering the many medications I

 

      was trying to take, it is with great thankfulness

 

      that I finally was able to find Dr. Prather.  At

 

      the age of 50 I finished college and I completely

 

      started a new career.  Today I am planning a

 

      wedding which has been many years in the making, to

 

      someone who is healthy as what I am.  My stomach

 

      feels and looks more normal, not swelled up like a

 

      puffer fish.  I no longer need to stay constantly

 

      constipated.  I can begin to enjoy life more today.

 

      I am looking forward to a huge mission trip through

 

      my church that I have wanted to go on for the past

 

      five years and have been too embarrassed to do

 

                                                               248

 

      this.  I could have gone last year; I look forward

 

      to it this year.  Zelnorm has helped to make this

 

      possible.

 

                Am I willing to risk any side effects from

 

      this drug today?  Absolutely.  I would like for any

 

      of you in this room to tell me of a drug out there

 

      that we do not have some side effects from.  I see

 

      many advertisements for many medications with much

 

      worse side effects than Zelnorm and they are still

 

      on the market, indeed.

 

                I also need to interject that I am

 

      definitely one of the few lucky ones.  I just went

 

      through with you how fortunate I am to have my

 

      career path in an area where I could barge into a

 

      GI doctor's office, a specialist at that.  What

 

      about these people who cannot and do not have that

 

      access, people that are in rural communities, which

 

      is probably why in 1994 my doctor didn't know what

 

      to do with me then?  Of course, Zelnorm wasn't out

 

      at that time.

 

                In conclusion, I just need to let you know

 

      that I have lived with chronic constipation for the

 

                                                               249

 

      majority of my life and Zelnorm has been the only

 

      thing which has provided consistent relief, and it

 

      has made an entirely new person out of me today,

 

      with lost less embarrassment and a lot more regular

 

      lifestyle.  Thank you so much.

 

                        Clarification of Issues

 

                DR. FOGEL:  Thank you.  At this juncture

 

      we are going to turn the meeting back to Novartis

 

      for some clarification of issues that were raised

 

      in the morning's discussion.

 

                DR. JOELSSON:  Thank you, Dr. Fogel.  I

 

      would like to clarify a few things that were raised

 

      during the presentations this morning.  First I

 

      would like to talk a little bit about Dr.

 

      Della'Zanna.  He said that we had some discussions

 

      about the label text and that in the end we agreed

 

      upon a precaution but that he felt maybe it should

 

      have been a warning.

 

                Can I have the first slide?  I would like

 

      to clarify why we think it should be  a precaution

 

      and not a warning.  It is really based on the

 

      regulatory definition of a warning.  The labeling

 

                                                               250

 

      shall be revised to include a warning as soon as

 

      there is reasonable evidence of an association of a

 

      serious hazard with a drug.  A causal relationship

 

      need not be proved.

 

                I think I made it pretty clear during the

 

      presentation earlier that we don't think there is a

 

      reasonable association of reasonable evidence of an

 

      association of a serious hazard.  So, we thought

 

      that a precaution would be adequate at this time

 

      point.  If things changed, we would have a

 

      discussion again.

 

                So, this is what the precaution looks like

 

      in our label today:  Ischemic colitis and other

 

      forms of intestinal ischemia have been reported in

 

      patients receiving Zelnorm during marketed use of

 

      the drug.  A causal relationship has not been

 

      established.

 

                So, this is part of the prescribing

 

      information.  It is part of the "dear doctor"

 

      letter that was sent out.  As you know, "dear

 

      doctor" letters are usually sent out when there are

 

      warnings but we suggested that we would include

 

                                                               251

 

      this into our "dear doctor" warning letter too

 

      because we think this is important information to

 

      have out there.

 

                Can I have the next slide, please?  In

 

      relation to whether something has happened or not

 

      since the label change, is there any reason for us

 

      to discuss a label change, this is what the monthly

 

      reporting rate of ischemic colitis looks like in

 

      the United States right now.  As you can see, after

 

      a slow uptake when the drug was marketed in August,

 

      2002, there have been no dramatic changes in the

 

      reporting rate of ischemic colitis during the last,

 

      let's say, year.  So, in my mind, nothing dramatic

 

      has happened since we had our label negotiations

 

      and currently we do see an increased reporting rate

 

      as a part of the "dear doctor" letter, and we know

 

      that is a well-documented effect of a "dear doctor"

 

      letter.  However, the increase of reporting has not

 

      been dramatic.

 

                Another point I would like to make is in

 

      relation to young patients getting ischemic

 

      colitis.  In addition to the fact that there is a

 

                                                               252

 

      background rate either in the general population or

 

      in IBS patients, misdiagnosed or not, it is also

 

      the case that some young people are diagnosed with

 

      ischemic colitis.  It is less common but it is

 

      still well known in patients who don't take

 

      medication.  For instance, in the United Health

 

      Care study 3 percent of the patients were between

 

      age 20-29 and 9 percent were between 30-39.

 

                I can also say that in the CORI database,

 

      the database where endoscopies are collected from

 

      all over the United States, there are patients

 

      reported there who are also between 20-29 years of

 

      age.  So, this is known.  So, it is not surprising

 

      that we do get cases, young cases, also with

 

      ischemic colitis.

 

                Next slide, please.  You saw this slide

 

      before, saying that we don't have any cases of

 

      ischemic colitis in our clinical trials in more

 

      than 11,600, but we have one patient on placebo

 

      that has ischemic colitis.  I would like to show

 

      you some details of that case.

 

                May I have the next slide, please?  I am

 

                                                               253

 

      showing this case just because Dr. Della'Zanna was

 

      talking about a young patient that was recently

 

      reported.  By the way, it is not a new report; it

 

      is an updating report so that is already included

 

      in the numbers--just to make sure we understand

 

      that.  But it is obviously a case that raises your

 

      eyebrow because there are no factors explaining

 

      this ischemic colitis in a young patient.

 

                This is our patient on placebo.  She was

 

      24 years old and she was part of our chronic

 

      constipation efficacy study.  She was basically

 

      healthy.  She had no other reasons to have an

 

      ischemic colitis.  She was reported as a segmental

 

      erosive colitis on colonoscopy.  We have discussed

 

      it together with Dr. Della'Zanna and we agreed that

 

      that is a probable case of ischemic colitis.  So,

 

      even on placebo you can get reports on young

 

      patients without any evident reasons for why they

 

      should have ischemic colitis.  So, it is not

 

      surprising that we also get such cases on tegaserod

 

      reported.

 

                Can I have the next slide, please?  Just

 

                                                               254

 

      in relation to Dr. LaMont's question, I just want

 

      to show this slide again.  After adjudication we

 

      had an imbalance, 0.03 percent versus 0.06 in the

 

      cholecystectomy indications population.  As you

 

      heard from Dr. Della'Zanna, we currently have a

 

      prospective study to study abdominal operations,

 

      including cholecystectomies.  There will be 10,000

 

      patients in each arm and that will tell us what the

 

      truth is.

 

                Finally, However, what I want to tell you

 

      is that currently there is a contraindication in

 

      our label for Zelnorm in patients with gall stone.

 

      So, it iq already there.  Thank you for that.  Are

 

      there questions about this?

 

                DR. LEVIN:  Could you comment on whether

 

      it wouldn't be prudent to include the postmarketing

 

      data in the precautions statement?  I mean, you are

 

      only presenting the clinical trial data which says

 

      there are no cases, but we have postmarketing

 

      experience that tells there are cases.  Without

 

      getting into the precautions versus the warning

 

      issue, it seems to me only reasonable to include in

 

                                                               255

 

      the precautions statement what we know about the

 

      drug to date in ischemic colitis and that would

 

      include the postmarketing reports through some

 

      cut-off date.

 

                DR. JOELSSON:  I think we could consider

 

      having a discussion with the FDA about that.

 

                DR. LEVIN:  Again, not getting into a

 

      debate of warning versus precautions, but if you

 

      are going to have a precautions statement that then

 

      says here is the experience and we have no cases,

 

      when we know there are cases--that is not a good

 

      precautionary statement.

 

                DR. FOGEL:  Is there a comment from the

 

      FDA?

 

                DR. LEVIN:  You said there are none out of

 

      7,000.

 

                DR. JOELSSON:  We are talking about giving

 

      numbers.  I understand what you are talking about.

 

      Thank you.  I think that is clear.

 

                DR. FOGEL:  Is there an FDA comment?

 

                DR. BEITZ:  Just that we think the first

 

      sentence does include postmarketing.

 

                                                               256

 

                DR. JOELSSON:  Yes, I think he is saying

 

      we should have numbers in there.  We will talk

 

      about that.

 

                DR. BEITZ:  Right, the difficulty with

 

      putting in numbers is that they are out of date as

 

      soon as we print the label.

 

                DR. BUCHMAN:  It is unfairly weighted the

 

      way that it is written because there are many more

 

      words associated with the fact that there aren't

 

      any.  When you read these quickly, it looks like it

 

      is a stronger emphasis that there aren't any cases.

 

      So, I would agree.  I think it just needs to be

 

      reworded so that it is equal.  If you have a

 

      multiple choice question, all the answers need to

 

      be the same length.  If you have one that is

 

      longer, it has actually been shown that that is the

 

      one that is picked most frequently.

 

                DR. FOGEL:  Dr. Cryer?

 

                DR. CRYER:  Thank you for that very nice

 

      explanation.  I would like to make a couple of

 

      comments just from my perspective after hearing

 

      your rebuttal to Dr. Della'Zanna's presentation. 

 

                                                               257

 

      That is that, you know, with respect to the comment

 

      that there have been no cases of ischemic colitis

 

      identified in the placebo-controlled trials,

 

      whether it be the 7,000 or the 11,600 patients, I

 

      would at least argue from my perspective that the

 

      risk in a younger female population may differ from

 

      a potentially older population with respect to

 

      their underlying co-morbidities.

 

                With regard to his comment about the

 

      mechanistic plausibility of this relationship,

 

      although there has not been a definitive

 

      cause-effect relationship shown, you had a slide

 

      earlier in your presentation, which I think was

 

      your slide CS-26, which talked about its effect on

 

      isolated coronary-arteries of non-human primates,

 

      suggesting the possibility of a mechanistic

 

      plausibility.  My comments about this is that, one,

 

      this would be non-human primates and so it doesn't

 

      really suggest to us what we might expect to see in

 

      a human trial, although I understand you couldn't

 

      do exactly this type of trial in human observation.

 

                The second comment that I have would be

 

                                                               258

 

      that my understanding of tegaserod's effects at

 

      plasma concentrations when clinically dosed is that

 

      in that slide I think the concentrations fall

 

      towards the right-hand side of the slide, at which

 

      point it looked like the two curves apparently

 

      seemed to separate from placebo.

 

                So, all this is just to say that I do

 

      think that there is at least some mechanistic

 

      plausibility and, secondly, that the lack of

 

      observations in the clinical trial experience is

 

      probably a different patient population than we are

 

      discussing.

 

                DR. JOELSSON:  Those are very good

 

      comments.  Actually, we do have data in humans

 

      also.  Can I show those data?  Can I get this on

 

      the screen?

 

                Maybe Dr. Pfannkuche, who knows so much

 

      more than I do about this, could come up.  He is

 

      our head of preclinical research and he has been

 

      responsible for these studies.  I only showed one

 

      of them; he has done many.

 

                DR. PFANNKUCHE:  Hans Pfannkuche, I am

 

                                                               259

 

      working in the preclinical pharmacology department.

 

      Actually, it is a very reasonable question.  Dr.

 

      Della'Zanna pointed out that triptans have been

 

      associated with cases of ischemia coronary

 

      problems.  I think Dr. Joelsson indicated in his

 

      slide that we did study in these monkey

 

      preparations coronary vessels, and there is no

 

      agonist activity associated with this drug.  In

 

      fact, it is a silent antagonist at this receptor

 

      subtype, defined as 1B receptor.

 

                As agreed upon with the FDA, we started

 

      looking into human preparations, and in this case

 

      human mesenteric arteries.  It is interesting to

 

      know that we find exactly the same pattern as we

 

      observed in the coronary vessels.  So, with the

 

      human mesenteric arteries, as you can see here, the

 

      first curve, which goes very up, is response to

 

      serotonin, our reference compound, and the second

 

      curve in between the X axis and the highest curve

 

      is the sumatriptan response that you would

 

      anticipate.  It is still a low number of samples

 

      here but you have some very high and some moderate

 

                                                               260

 

      responders here.  You may ask, okay, what about its

 

      affinity?  Actually, the affinity, again,

 

      translates into a silent antagonist property.

 

                Maybe on the next slide I can give you an

 

      example, slide PI-41.  On this slide you can see a

 

      parallel shift that you would expect from a

 

      competitive antagonist at this receptor site.  So,

 

      you can see that the affinity translates into

 

      inhibition of sumatriptan-induced contractions in

 

      this human mesenteric artery preparation.  In

 

      addition, I could show you another slide where we

 

      did the same for monkey mesenteric artery

 

      preparations.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  Yes, I just want to make a

 

      comment and then I have a question.  I guess I have

 

      an alternative opinion than some of the members of

 

      the committee.  I think the data that come from

 

      11,000 patients in the clinical trial are much more

 

      robust and allow much greater degree of

 

      quantitation than the postmarketing database,

 

      especially at this juncture of time and perhaps it

 

                                                               261

 

      won't be a question at the end of the day whether

 

      or not there is an increased incidence in IBS

 

      patients.  I mean, for the clinical trials the

 

      presumption is if there is a case, you capture it,

 

      especially if there is a case of ischemic colitis.

 

      The missed cases were probably covered by the near

 

      equal frequency of rectal bleeding between the

 

      placebo and the active group.  So, that is just an

 

      alternative opinion.

 

                I did have a question though, Dr.

 

      Joelsson, on your frequency over time of ischemic

 

      colitis slide that you just showed.  The question

 

      is from the FDA presentation and briefing document

 

      the impression I had is that there were 24 cases

 

      prior to April 15 reported and 7 or 9 cases

 

      afterwards.  I guess on that slide where the X axis

 

      did go to June, 04 I didn't see a bump reflecting

 

      that.

 

                DR. JOELSSON:  There is actually a small

 

      bump but it gets very small because of the big

 

      denominator.  But I can tell you that it is

 

      interesting what the effect of a "dear doctor"

 

                                                               262

 

      letter has.  Before the "dear doctor" letter we had

 

      between 0-4 cases maximum reported per month.

 

      During the month after the "dear doctor" letter we

 

      had 7 cases reported.

 

                DR. MANGEL:  I appreciate the fact that

 

      increased news coverage will increase reporting.  I

 

      just didn't appreciate on the graph--you know, to

 

      me it looked like the rate should have gone up by

 

      about 25-30 percent and I guess I wasn't seeing it

 

      on that, unless the denominator over those 2.5

 

      months markedly increased as well.

 

                DR. JOELSSON:  Yes, it does.  The

 

      denominator increases and the number of cases

 

      accumulate.  That follows each other very nicely.

 

      We don't see a quicker uptake of cases versus the

 

      use of the drug.  It is very parallel, as would be

 

      expected.

 

                DR. MANGEL:  And that was even after the

 

      "dear doctor" letter.

 

                DR. JOELSSON:  There is a small bump.  As

 

      I told you, it is a small bump but on that curve it

 

      doesn't look very big.

 

                                                               263

 

                DR. FOGEL:  Dr. Beitz?

 

                DR. BEITZ:  I just had a question

 

      regarding the preclinical data that were shown on

 

      the human mesenteric vessels.  Are those from

 

      patients or normals?  What is the source of that

 

      human material?

 

                DR. PFANNKUCHE:  This is patients who had

 

      to undergo surgery for colon cancer, with no

 

      history of IBS for example.  The report has been

 

      finished right now and will be submitted to the

 

      agency shortly.

 

                DR. BEITZ:  It may just be useful to see

 

      similar types of studies done in vessels from IBS

 

      patients, if they are available.

 

                DR. JOELSSON:  They are hard to get

 

      though.

 

                DR. BEITZ:  I agree, but if you wanted to

 

      look at the vasoreactivity of the IBS vasculature

 

      you would have to look at IBS patients.

 

                DR. FOGEL:  Dr. Sachar?

 

                DR. SACHAR:  I do have a request for a

 

      clarification but first I wanted to reinforce Dr.

 

                                                               264

 

      Cryer's comments and maybe take a little issue with

 

      Dr. Mangel.  All of the sponsor's safety

 

      presentations today have estimated the incidence of

 

      serious diarrhea and of ischemic colitis on the

 

      basis of all patients who have taken Zelnorm, but

 

      they have not presented their estimates on the

 

      basis of the populations at maximum risk, namely

 

      the oldest population.  The precaution statement

 

      refers to 7,000 patients.  The presentations today

 

      have referred to 11,000 trial patients and 3

 

      million marketed patients [sic], but I am not yet

 

      convinced that these figures accurately reflect the

 

      potential incidence in the elderly population and I

 

      think that some of those estimates ought to be

 

      recalculated on the basis of a different

 

      denominator.  That is just a point I might make.

 

                The request for the clarification has to

 

      do with the data on the extended trial.  We weren't

 

      given any efficacy data at 13 months.  It would be

 

      nice to have them.  Maybe they will come later.

 

      But we were told that 46 percent of patients

 

      discontinued the drug and evidently not because

 

                                                               265

 

      they were all better.  Did that 46 percent include

 

      the placebo patients?  If not, what percent of

 

      patients on the active agent discontinued for

 

      whatever reason within that year?

 

                DR. DENNIS:  The extension study was a

 

      double-blind study, but there was no placebo arm so

 

      it was uncontrolled.  Patients who had received 2

 

      mg and 6 mg BID in the study continued on those

 

      doses in the extension study, and those patients

 

      who had been on placebo went onto 6 mg BID in the

 

      extension study.

 

                DR. SACHAR:  Well, it says 842 patients

 

      entered the extension trial--

 

                DR. DENNIS:  Correct.

 

                DR. SACHAR:  --but only 518 were exposed

 

      to Zelnorm.  So, what were the other 324 taking?

 

                DR. DENNIS:  That number I gave you were

 

      exposed to Zelnorm for greater than 12 months.

 

                DR. SACHAR:  Oh, I see, the sentence

 

      continues.

 

                DR. DENNIS:  In that extension there were

 

      no patients on placebo.

 

                                                               266

 

                DR. SACHAR:  So, 46 percent of patients on

 

      Zelnorm stopped taking it within a year.

 

                DR. DENNIS:  We had discontinuations of 46

 

      percent throughout that treatment period.

 

                DR. SACHAR:  And they were getting it

 

      free?

 

                DR. DENNIS:  They were in the study.

 

                DR. SACHAR:  And they still stopped taking

 

      it.

 

                DR. DENNIS:  Well, I think the point is

 

      that in long-term studies of this nature, it is not

 

      uncommon to see these discontinuation rates.  One

 

      of the questions that you asked earlier on was for

 

      the efficacy.  Remember, this was a study we

 

      designed to do safety assessments.

 

                DR. SACHAR:  Oh, sure, and I see all the

 

      reasons--unsatisfactory response, withdrew consent,

 

      administrative, adverse effects.  I don't see

 

      anybody who stopped taking it because they were

 

      better.

 

                DR. DENNIS:  Patients who were better

 

      continued taking the drug.

 

                                                               267

 

                DR. SACHAR:  Exactly, and 46 percent

 

      stopped.

 

                DR. DENNIS:  Forty-six percent stopped.

 

                DR. FOGEL:  Before we begin our

 

      discussion--

 

                DR. JOELSSON:  Dr. Fogel, I have a few

 

      more points to clarify.  Is that okay?

 

                DR. FOGEL:  That will be fine.

 

                DR. JOELSSON:  Thank you.  Dr. Schoenfeld?

 

                DR. SCHOENFELD:  Thanks.  Could I have

 

      slide CB-12?  This is certainly an interesting

 

      process.  It is an enjoyable one to go through.

 

                I first wanted to try to clarify the point

 

      about appropriateness of endpoints for functional

 

      lower GI disorder studies, specifically about what

 

      the Rome committee says about those.  I want to be

 

      very clear about exactly what the Rome consensus

 

      document states, first author Dr. Whitehead.  It

 

      specifically stated that experts in this field

 

      recognize that people with lower functional GI

 

      disorders have multiple symptoms.  The specific

 

      quote from the paper says that no consensus could

 

                                                               268

 

      be reached on any single primary efficacy endpoint.

 

      It goes on to state specifically that they feel the

 

      best approach is to specify a primary endpoint with

 

      a few select a prior defined secondary endpoints to

 

      try to encompass the multiple symptoms in these

 

      functional lower GI disorders.

 

                Having said that, in the section of the

 

      Rome committee document on the appropriate design

 

      of a functional GI disorder, Sander Van Zanten and

 

      colleagues said, just as Dr. Fogel alluded to, that

 

      probably the best endpoint is global satisfaction

 

      with your functional GI symptoms.

 

                DR. PRIZONT:  I think I was one of the

 

      authors.

 

                DR. SCHOENFELD:  Actually, you were, Dr.

 

      Prizont.

 

                DR. PRIZONT:  I don't recall talking about

 

      common constipation as such.  We were talking about

 

      constipation-predominant irritable bowel syndrome

 

      in that particular quoting.  But, in any case, you

 

      are right.  Those who applied the Rome criteria had

 

      the choice of selecting the endpoints.  Like you

 

                                                               269

 

      said, you know, you can choose one endpoint,

 

      another endpoint and so on, and you chose them.

 

      You chose the 3 bowel movements with completeness.

 

      In your clinical trials in order to make the

 

      diagnosis of constipation, you said in the protocol

 

      patients will be considered constipated if they

 

      have less than 3 bowel movements per week; if those

 

      are incomplete; and if they have more straining

 

      than what is established in the Rome criteria.  So,

 

      you picked them.

 

                DR. SCHOENFELD:  I think that responds to

 

      a different point but I will go ahead.  Can you go

 

      to slide CB-10?  I just want to make sure we are

 

      very clear about what the Rome committee criteria

 

      are for functional constipation.  A patient need

 

      not have fewer than 3 bowel movements per week in

 

      order to meet the Rome committee criteria for

 

      functional constipation.  If a patient, for 12

 

      weeks which need not be consecutive in the past

 

      year, has some combination of straining, lumpy or

 

      hard stools, a sensation of incomplete evacuation,

 

      sensation of obstruction or blockage--if they have

 

                                                               270

 

      any 2 of those 4, even if they are having 4 bowel

 

      movements per week, that meets the Rome committee

 

      criteria for functional constipation.  I want to

 

      make sure we are clear on that point.  Go ahead,

 

      Dr. Sachar, please.

 

                DR. SACHAR:  Well, that is the Rome

 

      criteria.  I just want to be sure that you don't

 

      set up the Novartis criteria for your protocol and

 

      then dredge your outcome by the Rome criteria.

 

                DR. SCHOENFELD:  Absolutely.  I was just

 

      going to that point.  So, having said that, the

 

      criteria for Novartis studies, although they are

 

      not exactly as the Rome committee criteria, are

 

      certainly pretty darned close, and I would note

 

      also, going back to risk/benefit analysis of all

 

      laxatives, they come closer to meeting the Rome

 

      committee criteria for identifying patients with

 

      functional constipation than essentially any other

 

      randomized, controlled trial that has ever been

 

      done for a laxative.

 

                DR. PRIZONT:  I concur with that.  I said

 

      that in order to define constipation, Novartis used

 

                                                               271

 

      the wrong two criteria.  You just mentioned that

 

      you are applying the wrong two criteria to define

 

      constipation.  The question was not whether you

 

      defined constipation based on the Rome criteria.

 

      The question was how you define efficacy--

 

                DR. SCHOENFELD:  Absolutely, and I would

 

      like to go to that point.

 

                DR. FOGEL:  Actually, can I ask a question

 

      before you go to efficacy?  What about validation

 

      of outcomes?  We have a lot of data about the Rome

 

      criteria global subjective assessment, what about

 

      the Novartis outcome?

 

                DR. SCHOENFELD:  Well, what I would

 

      suggest is this, if we can go to slide CB-13, which

 

      goes back to your point which was to say are there

 

      any data about global satisfaction with bowel

 

      habits?  As we see here in both studies, we see

 

      that patients who are tegaserod 6 mg BID

 

      demonstrated a statistically significant, and, what

 

      is to me, a clinically important improvement in

 

      global satisfaction with bowel habits.  Now, what

 

      is that based on?  Obviously, the absolute

 

                                                               272

 

      difference is that between 9 and 12 percent more

 

      patients compared to placebo said they had global

 

      satisfaction with bowel habits.

 

                I do want to be very careful as we talk

 

      about placebo-controlled trials.  Sometimes we talk

 

      about using number needed to treat, which I am a

 

      huge proponent of, but it is probably best to use

 

      when you are comparing two alternative therapies.

 

      If I say the number needed to treat here because of

 

      an approximately 10 percent difference is a number

 

      needed to treat of 10, that infers that instead of

 

      prescribing a drug like tegaserod I am going to

 

      prescribe a placebo.  That is actually not an

 

      alternative for me.  Nevertheless, it gives us an

 

      idea about the incremental benefit over placebo.

 

                Second, going back to validation of this

 

      global satisfaction endpoint, responders were

 

      defined as patients who have had an increase of 1

 

      on a 5-point Likert Scale for their global

 

      satisfaction.  Now, what does that mean clinically?

 

      In other studies of functional disorders, including

 

      functional respiratory disorders, it has

 

                                                               273

 

      consistently been validated that an increase of 1

 

      point on a 5-point Likert Scale is a clinically

 

      important benefit.  But to be balanced, has that

 

      been validated?  Not specifically for functional

 

      constipation, not to my knowledge.  If you chose

 

      instead, though, to say what is the proportion of

 

      patients who get complete or near-complete

 

      satisfaction with the bowel habits, a score of 0-1

 

      on that 5-point scale, the proportion of patients,

 

      although it is small in both the tegaserod group

 

      and the placebo group, is still significantly

 

      higher in the tegaserod group than it is in the

 

      placebo group, although I would say this was a

 

      population of patients with fairly severe

 

      constipation and that is a fairly difficult

 

      threshold to get, that they had complete or

 

      near-complete satisfaction with their bowel habits.

 

                DR. FURBERG:  Could you explain the

 

      footnote?  I mean, you are really comparing

 

      baseline to any time between week 1 and 12, or are

 

      you doing it at the end of the study?

 

                DR. SCHOENFELD:  I think that question may

 

                                                               274

 

      be better answered by Dr. Dennis.

 

                DR. FURBERG:  This question relates to

 

      some other papers you have shown as well.  I mean,

 

      what is important to us is what is the global

 

      satisfaction at the end of the treatment period.

 

      You should not carryover and if you have some

 

      benefit early on take credit for that if the

 

      patient stopped taking the drug.

 

                DR. DENNIS:  Sure.  What we did when we

 

      did these calculations was an average but we did

 

      look at weekly satisfaction scores, and when we

 

      look at those weekly satisfaction scores we can see

 

      significance at all weeks as well.

 

                DR. FURBERG:  I would like you to show a

 

      graph where you have the baseline and the end after

 

      12 weeks.  We need to know what is the effect on

 

      global satisfaction after 12 weeks of therapy and

 

      no carryover.

 

                DR. DENNIS:  Right.  AQ-50, please.  This

 

      is really showing you the weekly response for

 

      satisfaction scores by study.  You can see

 

      significant difference throughout the trials.  You

 

                                                               275

 

      look at the beginning and you look at the end and

 

      we are still seeing a significant difference on

 

      these weekly analyses.

 

                DR. FURBERG:  It is hard to see the scale

 

      there.

 

                DR. DENNIS:  Remember, this was a 5-point

 

      scale and the responder improvement is shown by a

 

      decrease in the score.

 

                DR. FURBERG:  So, the improvement is less

 

      than half a point.

 

                DR. DENNIS:  We have done some statistical

 

      analyses to look at validation of these as well,

 

      and I would like to ask Dr. Gary Cook to come up

 

      and discuss the statistical significance of these

 

      results as well.

 

                DR. COOK:  Yes, I am Gary Cook from the

 

      Biostatistics Department, University of North

 

      Carolina.  One of the things I wanted to see is

 

      CE-37.  While that is being put up, the primary

 

      endpoint and many of the other endpoints are

 

      averages over periods so there are averages over 4

 

      weeks for the first 4 weeks or they are an average

 

                                                               276

 

      over 12 weeks for all 12 weeks.  An analysis of the

 

      primary endpoint was done as a continuous measure.

 

      As you recall, the responder variable is a success

 

      if the patient has a change of CSBM of greater than

 

      or equal to 1.  But that variable was also analyzed

 

      continuously as a continuous variable.  The

 

      background standard deviation is 2.  So, an

 

      improvement of 1 is half a standard deviation.

 

      Many times half a standard deviation is thought of

 

      as a meaningful effect size.

 

                In this particular display is an analysis

 

      that is addressing the extent to which the study

 

      validates the primary endpoint.  As was previously

 

      stated, there were not previous studies that

 

      address validation but these studies do address

 

      validation.  Now, what are the criteria for

 

      validation?  One criterion is, is the endpoint

 

      sensitive to detecting treatment effects,

 

      particularly when other criteria detect treatment

 

      effects?  In these studies other criteria did

 

      detect treatment effects and the primary endpoint

 

      did as well.

 

                                                               277

 

                Also, over here you are basically seeing

 

      the extent to which there are differences in means

 

      of some of these other criteria for responders and

 

      non-responders.  The magnitudes of those

 

      differences in means vary from roughly a half to 70

 

      percent of the standard deviation.  So, the

 

      differences in means for the responders and

 

      non-responders, again by being roughly 50-70

 

      percent of the standard deviation, are reflecting

 

      meaningful effect size differences and also

 

      reflecting the fact that the primary endpoint

 

      responder versus non-responder is, indeed,

 

      significantly correlated with other criteria.

 

                Now, I say correlated because whenever you

 

      have a dichotomous variable and you are forming the

 

      ordinary Poisson correlation coefficient between a

 

      dichotomous variable and a continuous variable,

 

      that correlation coefficient, if you do the

 

      algebra, is proportional to the difference in means

 

      for the dichotomous variable.  So, the differences

 

      in means that you are seeing here are, indeed,

 

      proportional to what the correlations would be. 

 

                                                               278

 

      The correlations are scaled by ratios of standard

 

      deviations.  These differences that you are seeing,

 

      as I said, are about 50-70 percent the background

 

      standard deviation and, as I said, the criterion of

 

      a change of 1 for the CSBM parameter relative to a

 

      background standard deviation of 2 was, indeed,

 

      about 50 percent of the background standard

 

      deviation.

 

                DR. FOGEL:  If we can go back to your

 

      previous slide, I think there are some other

 

      questions.  Dr. Metz?

 

                DR. METZ:  Thank you.  I think a lot has

 

      been made today about what the endpoints are and

 

      how you can vary what endpoints you are discussing

 

      and which one is actually going to be better or not

 

      better.  I will accept that the bottom line, as Dr.

 

      Fogel said, is if you are feeling better, you are

 

      feeling better and if you stop the drug you are

 

      feeling worse.

 

                Let's go back to that global figure that

 

      was shown a little earlier.  Do you have those sort

 

      of data divided by age?  Can you show me the global

 

                                                               279

 

      response in the elderly population?

 

                DR. DENNIS:  We don't have the analysis by

 

      age.  I just want to reiterate that when we do

 

      subgroup analyses the purpose of subgroup analyses

 

      is not to prove efficacy.  The purpose of subgroup

 

      analyses is to see that the effect that you are

 

      seeing within a subgroup is consistent with the

 

      overall effect and that there are no negative

 

      trends.

 

                DR. METZ:  That is exactly why it is so

 

      relevant.  The whole point for me here is that we

 

      know that the dangerous potential group are going

 

      to be the elderly people who don't necessarily have

 

      functional constipation, who have outlet

 

      obstruction, who have hypothyroidism that hasn't

 

      been realized--those are the people who are going

 

      to have a lower response rate but they are the

 

      people at most risk for potentially getting into

 

      trouble.  That is why I want to see that data.

 

                DR. DENNIS:  Right.  Can I get AQ-17?  I

 

      first of all just want to reiterate that we did not

 

      study this drug for treatment of patients who had

 

                                                               280

 

      secondary constipation.  So, that is not the

 

      patient population that we are indicated for.

 

                Let me address the data that we do have by

 

      age and gender because I told Dr. Fogel that we

 

      would get back to you with these data so you can

 

      have a look at that.  Just to remind you of what I

 

      showed you earlier this morning, this was our

 

      primary endpoint.  We looked at it by age and

 

      gender.  Females are in the top row, males in the

 

      bottom row.  If you look at the younger patient

 

      population, which is on the left-hand side and the

 

      older population is on the right-hand side, males

 

      and females under the age of 65 were seeing a

 

      treatment effect.  If we look at the older

 

      population, 65 years and older, what we see in

 

      these 65 year-old patient population is that there

 

      is a treatment effect but in each of those

 

      different treatment groups.  When we look at the

 

      males younger than 65, of course, we are not seeing

 

      any benefit in that group of patients, which is the

 

      smallest group of patients where we had 98

 

      patients.

 

                                                               281

 

                Can I have the next slide?  This is what

 

      happens when you take away the IBS-like patients.

 

      You can see what happens in that quadrant that

 

      looks at the male population.

 

                If we go to the next slide, this is

 

      looking at the cut of the data using the FDA

 

      responder definition of patients having greater

 

      than 3 CSBMs per week.  This was the fixed

 

      definition with no relation to the baseline.

 

                Let's focus on that younger patient

 

      population that are less than 65.  Females on the

 

      top and males on the bottom.  I don't think there

 

      is any doubt that we are seeing a significant

 

      effect in that male population even given these are

 

      smaller numbers of patients that we are seeing

 

      here.  So, I think when we are looking at that age

 

      group, males and females, the efficacy is

 

      consistent.

 

                Let's look at the older population.  The

 

      female population, the results that we are seeing

 

      for this particular responder definition are

 

      similar to what I have shown you for the primary

 

                                                               282

 

      efficacy variable as well.

 

                DR. PRIZONT:  Let's talk about

 

      extrapolation of results from females to males.

 

      The difference between placebo and the 6 mg is

 

      about 10 percent in females.  What is it in males?

 

      I think it is about 21 percent.

 

                DR. DENNIS:  Right.

 

                DR. PRIZONT:  Which, in some ways--this is

 

      my view--it may be showing that the response are

 

      different and the differences may be real.  You

 

      know, somebody pointed out that males may have a

 

      different response to placebo.  There was a higher

 

      placebo response.  That response may be real.  I

 

      see some sort of a danger of extrapolating the

 

      results that you have in females to the males

 

      because, you know, the results, although they seem

 

      to be the same, are different in some ways.

 

                DR. DENNIS:  But if we are going to look

 

      at comparing data and say we are going to accept

 

      that the negative data is real and we are not going

 

      to accept that the positive data is real--we are

 

      looking at these subgroup analyses to determine

 

                                                               283

 

      whether there are trends.  I think that is the

 

      issue.  Are we seeing negative trends?  I think on

 

      this slide that I am showing you we are seeing that

 

      in that older male population, yes, there is a

 

      difference between that group and the other groups

 

      that we are seeing here.

 

                DR. CRYER:  But, Dr. Dennis, I also recall

 

      from Dr. Fogel's earlier request that morning that

 

      we are interested in knowing the 12-week durable

 

      response and these, as I see it, are 4-week data.

 

                DR. DENNIS:  Yes, they are coming.  I just

 

      wanted to show you these because we hadn't shown

 

      them to you earlier on.

 

                Can I have the next slide, please?  This

 

      is what happens to that FDA responder definition

 

      when you take out the IBS-like patients.  Again, we

 

      see a similar effect to what happened with the

 

      primary endpoint.

 

                Slide AQ-160.  This is what happens over

 

      weeks 1-12.  This is in the overall patient

 

      population.

 

                If I can have 161, it shows you what

 

                                                               284

 

      happens when we take out that IBS-like group.

 

                DR. FURBERG:  But you are not showing the

 

      results at 12 weeks.  You are taking the average

 

      between 1 and 12.

 

                DR. DENNIS:  Correct.

 

                DR. FURBERG:  That is not the way to

 

      present the information.

 

                DR. DENNIS:  Dr. Cook is going to come and

 

      respond to that.

 

                DR. LEVIN:  Wasn't the previous slide 3

 

      SCBM and this is 1?  It is a different metric.

 

                DR. COOK:  I think your point is very well

 

      taken in terms of your concerns about average

 

      versus time point by time point.  Now, previous

 

      displays have given you results time point by time

 

      point.  There were any number of displays in the

 

      main presentation that went week by week.  Fixating

 

      on week 12 isn't necessarily that useful in the

 

      sense that the patient probably cares about how

 

      they are doing every week, and one particular week,

 

      like week 12, may or may not be that important

 

      compared to the other weeks.

 

                                                               285

 

                Now, if one only has one number to somehow

 

      describe what happens for every week, the average

 

      does that.  When one wants to know more about what

 

      is going on week by week, then one looks at the

 

      week by week figures, which are the types of

 

      displays that have been presented previously.

 

                DR. D'AGOSTINO:  I think the concern is

 

      are the 12-week data as you are presenting the week

 

      1-12 so overwhelmed by the early experience, and we

 

      want to get that end experience.

 

                DR. FURBERG:  Gary, the other thing is if

 

      we are talking about treatment for an extended

 

      period--this is a chronic condition, and you are

 

      mixing in the results after a week or two.  I find

 

      that misleading.  You can present it your way, that

 

      is fine, but in addition I think you should be

 

      honest and present the data at the end of the

 

      treatment period.  That is the standard in any

 

      treatment comparison.

 

                DR. COOK:  Well, again, the sponsor is

 

      going for a treatment period of 12 weeks, as I

 

      understand, and if a patient's condition is

 

                                                               286

 

      relieved after 12 weeks they would not receive

 

      continued treatment until again they requalified

 

      for treatment.  So, I do not believe they are

 

      asking for an indication where they would be

 

      treated continuously, although it is possible that

 

      they would be treated for 12 weeks and then, if

 

      their symptoms recurred 6 months later, they might

 

      get treated for another 12 weeks.

 

                Again, the analyses that showed the

 

      displays week by week, which Dr. Dennis can go back

 

      to, basically are looking at the real data week by

 

      week for each of the criteria.  There was an

 

      analysis that she showed for percent of people that

 

      had a CSBM greater than or equal to 1, a change

 

      greater than or equal to 1.  There were also

 

      analyses she showed that were for actually the mean

 

      change.  Perhaps maybe she should go back over the

 

      week by week displays that are in your handout.

 

      But that is addressing the comparisons at week 12.

 

      They were not highlighted in graphs like this.  But

 

      the week by week displays gave you the information

 

      at week 12.

 

                                                               287

 

                DR. BUCHMAN:  Could we have a

 

      clarification from Novartis actually as to what the

 

      indication was that was submitted?  Because on the

 

      slide that was shown it said nothing about limiting

 

      treatment to 12 weeks.  Has that changed since this

 

      morning?

 

                DR. JOELSSON:  No, nothing has changed

 

      since this morning, I hope.  The indication that we

 

      are seeking is for chronic constipation.

 

                DR. BUCHMAN:  So, not limited to 12 weeks.

 

                DR. JOELSSON:  Obviously, somewhere in the

 

      label it will be stated that clinical trials have

 

      been performed up to 12 weeks.

 

                DR. SACHAR:  Could somebody tell us

 

      whether there would be anything useful in taking

 

      the 12-week data and dividing it into the first

 

      half and second half at least, and seeing whether

 

      the first 6 weeks have efficacy and the second 6

 

      weeks have no efficacy?  That might be useful

 

      information.

 

                DR. JOELSSON:  We have shown week by week

 

      data--

 

                                                               288

 

                DR. SACHAR:  Right.

 

                DR. JOELSSON:  --and we have shown that it

 

      is very consistent all the way through the 3

 

      months.  We showed many of those slides earlier

 

      today.

 

                DR. CUTT:  There is one point I wanted to

 

      address.  The dosage and administration section of

 

      the label is where it clearly outlines the 6 mg BID

 

      dose for a period of 12 weeks.  The indication is

 

      what it is indicated for.  The rest of the label

 

      addresses that.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  You had a slide way back

 

      where you showed some global symptoms and you

 

      compared the two studies, and that was an example

 

      where it was difficult to see, in fact, if there

 

      was a dose response.  I think dose response is

 

      something we have to clarify.  I heard from

 

      Novartis that there was no significant dose

 

      response in this study as in the previous IBS study

 

      that originally got approved.  I heard from Dr.

 

      Della'Zanna that there was no difference.  Here you

 

                                                               289

 

      are saying there was a difference, 6 mg was more

 

      efficacious than 2 mg.  When I look back at the

 

      slide you showed a couple of times ago that was up

 

      there, that was one of the typical ones where I

 

      could not discern a difference between 2 mg and 6

 

      mg.  Dr. Della'Zanna said there is no dose

 

      response; you are saying there is a dose response.

 

      I think in a study like this where there are high

 

      placebo numbers and rather marginal changes, I

 

      think it is important that we know if there is or

 

      is not a dose response in all the various aspects

 

      that have been looked at.

 

                DR. JOELSSON:  Yes, when it comes to the

 

      primary endpoint, as you saw in the European study,

 

      6 mg BID did better than 2 mg BID.  In the American

 

      study there was no difference.  Now, if you look at

 

      the overall picture, if you look at all the

 

      secondary endpoints, 6 mg BID is more consistent.

 

      It is more consistent, significantly better than

 

      placebo.

 

                DR. LEVINE:  You pooled the difference?

 

      Is what we are seeing in the slides the pooled

 

                                                               290

 

      number--I assume the pooled number, the lumped

 

      number of everything when you say there is a

 

      difference in spontaneous improvement, etc. using

 

      both trials, not just the U.S. trials.

 

                DR. JOELSSON:  If you add them together

 

      there will be a small difference between 2 mg and 6

 

      mg.  I think what you need to do is to look at the

 

      overwhelming amount of data, as somebody said here,

 

      and if you look at all the endpoints that we have

 

      looked at 6 mg BID is more consistent from endpoint

 

      to endpoint.  That is why we are suggesting 6 mg

 

      BID.

 

                DR. FOGEL:  Before we deal with questions

 

      from the FDA, one last question for Dr. Dennis.

 

                DR. COOK:  We wanted to show this week by

 

      week display since a number of people have decided

 

      that they would rather the difference at week 12

 

      had been the primary endpoint rather than the

 

      average over weeks 1-4 or 1-12.  This display is

 

      showing [not at microphone; inaudible]... and there

 

      is no imputation of missing data; this is the

 

      actual data, as I understand, and this is the

 

                                                               291

 

      second study.

 

                PARTICIPANT:  You have to speak up.

 

                DR. COOK:  Sorry, but the discussion is

 

      sufficiently animated and it is easier for me to

 

      point sometimes.  In this particular display the

 

      data at week 12 is the head-to-head comparison of

 

      the arms at week 12 for the responder variable, not

 

      a pre-stated primary endpoint but a descriptive

 

      analysis of the time course, and the differences at

 

      week 12 are statistically significant.  So, had the

 

      primary endpoint been how did the treatment groups

 

      compare at week 12 for percent responder, which

 

      would be a change from baseline greater than or

 

      equal to 1 at week 12, this is the display that

 

      sought to address that.

 

                DR. STROM:  And you have comparable data

 

      on global satisfaction?  It goes back to what David

 

      was asking for before.

 

                DR. COOK:  I believe there was a backup

 

      display that showed that.  I believe statistical

 

      significance applied to that backup display.  The

 

      effect size was smaller in terms of the magnitude

 

                                                               292

 

      of the difference.  But, otherwise, statistical

 

      significance was still there.  It also depended

 

      upon whether you looked at the global satisfaction,

 

      I believe and maybe Dr. Dennis can clarify this, as

 

      the proportion who had at least a 1 unit

 

      improvement or whether you looked at it as a mean

 

      of the scale.  I think the former was probably more

 

      meaningful.  Can you clarify that, Dr. Dennis?

 

                DR. DENNIS:  I showed you some data

 

      earlier on where we looked at satisfaction, saying

 

      how many people belonged to those groups of a great

 

      deal satisfied and a very great deal satisfied for

 

      6 out of the 12 weeks and for 2 out of the 4 weeks

 

      and, again, we showed statistically significant

 

      benefit for those patients.

 

                DR. STROM:  But I am looking for what does

 

      it look like at 12 weeks.

 

                DR. SACHAR:  That is slide 33 and it is

 

      the only one that is a bar graph instead of a

 

      linear curve.

 

                DR. DENNIS:  Here we go.  So, this is the

 

      pooled data.  Just to speak to the question of what

 

                                                               293

 

      would this look like when we pool the data, we can

 

      still see that the 6 mg BID dose is more consistent

 

      with this.

 

                DR. BUCHMAN:  But in terms of this patient

 

      satisfaction though, it is interesting how subgroup

 

      analysis is only shown if it shows efficacy and it

 

      is not shown if it doesn't show efficacy.  If we go

 

      back to Dr. Prather's introduction statement, she

 

      showed what she said were the only three studies

 

      that looked at quality of life in patients with

 

      idiopathic constipation.  In two of the three they

 

      used the SF-36 and in one of the three they used

 

      the SF-12.  Why are you only doing a subgroup

 

      analysis here with one single outcome measure?  It

 

      is like looking at a tree instead of at a forest.

 

      So, the patients are happy with their bowel

 

      movements but are they happy with their life?  Has

 

      it changed their life?

 

                DR. COOK:  Typically, in a regulatory

 

      environment you have protocol-planned analyses, and

 

      all of the analyses have to be planned and one will

 

      produce a certain number of analyses on an

 

                                                               294

 

      all-patient basis for all the endpoints and on the

 

      primary endpoint one will do exploratory analyses

 

      across a variety of subgroups.  Indeed, it is

 

      possible to do all possible analyses all possible

 

      ways, but at some point one has to decide when one

 

      can extrapolate.

 

                DR. BUCHMAN:  Well, the bottom line is you

 

      didn't do a validated quality of life measure on

 

      these patients.

 

                DR. FOGEL:  Last comment?

 

                DR. DENNIS:  Let me answer that.  I think

 

      we have to remember that when we look at quality of

 

      life measures as an indication of treatment

 

      response, that is different to looking at what is

 

      the quality of life in a particular population at

 

      any one time.  When we look at quality of life as a

 

      measure of treatment response, disease-specific

 

      tools are far more sensitive.  All right?

 

                Now, at the time that we did these studies

 

      we did not have any disease-specific tools

 

      available to us looking specifically at quality of

 

      life.  So, we did look at the SF-36 and when we

 

                                                               295

 

      looked at the SF-36--as you know, SF-36 is generic;

 

      it is non-specific.  Our initial a priori analysis

 

      looked at the summary scores only, which is the

 

      broadest possible analyses for these scores.  On

 

      those analyses we did not actually see any

 

      significant difference between Zelnorm and placebo.

 

      However, we have gone back and looked at the

 

      analyses of the individual scores, and this is what

 

      you can see on here.  Bearing in mind this is a

 

      non-specific tool that is not designed to detect a

 

      treatment difference, we can see that we show a

 

      statistically significant benefit on three out of

 

      these eight domains for quality of life, and we see

 

      an improvement in all of the domains, albeit small,

 

      I give you that, but we are certainly seeing an

 

      improvement in quality of life as well.

 

                        Discussion of Questions

 

                DR. FOGEL:  Thank you.  I am going to stop

 

      the discussion now and we are going to deal with

 

      the questions.  the ground rules that we are going

 

      to follow are that every member of the committee

 

      who is voting is going to be asked for a yes or no

 

                                                               296

 

      on each question.  If you have a comment to make at

 

      that time, you can make it.  In the interest of

 

      time, please try not to repeat what others have

 

      said.

 

                Question number one with regard to

 

      efficacy, discuss the appropriateness of a primary

 

      efficacy endpoint of an increase of greater than 1

 

      complete spontaneous bowel movement per week versus

 

      a total of 3 or greater complete spontaneous bowel

 

      movements per week.  We will start with Dr. Cryer.

 

                DR. CRYER:  Well, that is not a yes or no

 

      question.

 

                [Laughter]

 

                DR. FOGEL:  Good point!

 

                DR. CRYER:  We have had a lot of

 

      discussion about these various endpoints.  You

 

      know, I have gone back and forth on this to reach

 

      my conclusion that ultimately, irrespective of

 

      which subgroup you look at or how you do an

 

      analysis and how it is defined, there was some

 

      improvement in constipation in the people who

 

      received Zelnorm.

 

                                                               297

 

                What I am more concerned with actually

 

      than the quantitative description of number of

 

      bowel movements which define this endpoint is the

 

      duration of therapy.  It is the more durable

 

      response of 12 weeks rather than their prespecified

 

      endpoint of 4 weeks because this is ultimately

 

      going to be a chronic treatment.

 

                So, my answer in brief is that I believe

 

      that they have demonstrated in a subpopulation that

 

      there is an improvement in constipation, albeit by

 

      some people's definition they remain constipated.

 

                DR. FOGEL:  Do you think this is an

 

      appropriate endpoint?  Yes or no?

 

                DR. CRYER:  Yes.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  Greater than 3 is obviously a

 

      more robust endpoint than greater than 1.  I

 

      believe greater than 1 is a suitable endpoint.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  In reality, actually the

 

      difference between the Zelnorm group responders and

 

      placebo is actually only 0.6.  So, it is actually

 

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      less than 1 if we look at the responders only.  But

 

      if it was greater than 1, I don't think that that

 

      is clinically significant at all because that is

 

      subject to variation.  If we look at the Rome II

 

      criteria, the definition was less than 3.  Of

 

      course, we can't turn that around and say, in terms

 

      of treatment, if you get over 3 you are not

 

      constipated but my personal opinion is simply

 

      having 1 more bowel movement a week is not

 

      sufficient on its own to eliminate constipation so

 

      my answer is no.

 

                DR. FOGEL:  Dr. Sachar?

 

                DR. SACHAR:  If we chose a total of equal

 

      or more than 3, I think the sponsor could say that

 

      Zelnorm relieved chronic constipation.  If we

 

      choose equal to or greater than 1, I think the

 

      sponsor can say patients with chronic constipation

 

      who take Zelnorm will still be constipated but it

 

      won't be as bad.  I would say it is not adequate.

 

                DR. FOGEL:  My vote is that it isn't an

 

      appropriate endpoint.  I think it is far from the

 

      optimal endpoint.  I would like to make a

 

                                                               299

 

      suggestion to the FDA, since this is a huge market

 

      and I am sure you are going to see many more

 

      functional bowel disease studies in the next months

 

      and years, that you consider making the appropriate

 

      primary endpoint being subjective global

 

      assessment.  Dr. Metz?

 

                DR. METZ:  I would agree entirely with

 

      those statements.  I am happy with 1; happy with 3.

 

      I like global assessment.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  I agree with Dr. Sachar.  I

 

      am not happy with 1 and I would be happier with

 

      greater than 3.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  I agree with that this is an

 

      adequate and appropriate endpoint, especially since

 

      it was discussed and apparently approved by the

 

      FDA.

 

                DR. D'AGOSTINO:  My comment is similar.

 

      It seems to have been prespecified.  It also does

 

      correlate fairly well with these other measures.  I

 

      also agree that the subjective global would have

 

                                                               300

 

      been a much better endpoint.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  Inappropriate.  I don't

 

      think it is fully standardized and its clinical

 

      relevance has been questioned.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  I am going to abstain, and the

 

      reason is I don't think it is a relevant question.

 

      I think, no matter how you look at it, we are

 

      seeing the same consistent results that the drug

 

      works and I think this was agreed upon beforehand

 

      and the criteria shouldn't be changed along the

 

      way.  I think it is an important general broader

 

      question, not to this regulatory decision, and we

 

      haven't seen the data to be able to answer that,

 

      but I think relevant to this regulatory question it

 

      is really a non-issue.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  I do believe these patients

 

      met the Rome criteria.  Actually, in some of the

 

      parameters they were stricter to enroll the

 

      patients in the study, and to evaluate the efficacy

 

                                                               301

 

      point they followed the guidelines of the protocol.

 

      I do believe that one complete spontaneous bowel

 

      movement in patients with this type of very severe

 

      constipation adds to their quality of life.  So, I

 

      do vote yes to the question.

 

                DR. FOGEL:  Thank you.  Dr. Levin?

 

                DR. LEVIN:  I would agree with Dr. Strom's

 

      answers.  I will pass on this or abstain.  I also I

 

      think look more favorably on the global assessment.

 

                DR. FOGEL:  Thank you.  Yes?

 

                DR. BEITZ:  Just a clarification on the

 

      recommendation for future studies to have as a

 

      primary endpoint a global satisfaction score, how

 

      would you also factor in the number of bowel

 

      movements?  We that be composite two co-primary

 

      endpoints or a secondary endpoint?  Could you say

 

      anything at this point?

 

                DR. FOGEL:  That is a very tricky question

 

      that take more thought than I can give it right

 

      now, but I would probably consider it a secondary

 

      endpoint.

 

                DR. STROM:  I think there needs to be

 

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      formal work developing that as a scale.  I also

 

      think global assessment or some equivalent category

 

      makes more sense, but I think there needs to be

 

      formal development like you would develop other

 

      things.  I don't have a problem that SF-36 or SF-12

 

      weren't used because they are not responsive

 

      instruments in this kind of situation.  You need a

 

      responsive constipation-based instrument and there

 

      needs to be the basic underlying quality of life

 

      work done to develop and validate it accordingly.

 

                DR. FOGEL:  Question 1(b), is the

 

      population studied representative of patients with

 

      chronic constipation?  If not, how do the

 

      populations differ?  We will start with Dr. Levin.

 

                DR. LEVIN:  I sort of half pass, but I

 

      think I would be remiss not to speak to the fact

 

      that in 2004 I am sort of dismayed that the

 

      participation by minorities as to race and

 

      ethnicity is not much larger in this study.  I

 

      think sensitivity to the inclusion of ethnic and

 

      racial majorities in research is critical and I

 

      think it is sort of dismaying, as I said, that

 

                                                               303

 

      there is so little participation by ethnic and

 

      racial minorities.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  During the discussion the

 

      point was made that people with IBS and

 

      constipation were not excluded from the study, and

 

      I think that was a point of contention.  However, I

 

      do know that it is very difficult sometimes to make

 

      the distinction because some people with IBS may

 

      not have the symptoms all along and may present

 

      with constipation, like functional constipation.

 

      Therefore, although I agree and I would like to see

 

      more men in the study and more minorities, I do

 

      vote yes to the question.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  I think the population is not

 

      representative of those with chronic constipation

 

      but that is always the case with a premarketing

 

      clinical trial so I wouldn't expect the company

 

      could have done anything differently from that

 

      perspective.  I do think there is a major issue in

 

      terms of missing--I think it is important to sort

 

                                                               304

 

      of change the question slightly and emphasize that

 

      it is patients with chronic constipation, that is,

 

      people who are going to be coming for medical care

 

      with chronic constipation and they are mostly going

 

      to be elderly, and there clearly was a dearth of

 

      elderly here but we will talk about that more in

 

      the next question.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  I agree with Brian, the

 

      population is not representative.  I think, in

 

      addition, it is not really well defined; it is a

 

      mixed bag.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  I am leaving for the next

 

      couple of responses the age and gender, and also

 

      the racial discussion, so I am taking this as being

 

      the type of constipation was the chronic

 

      constipation.  They did remove the IBS and it still

 

      seemed to be significant.  So, I think they have at

 

      least a subpopulation that corresponds to chronic

 

      constipation.

 

                DR. FOGEL:  Dr. LaMont?

 

                                                               305

 

                DR. LAMONT:  yes, I think that this does

 

      represent the type of patients that I see with

 

      chronic constipation.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVIN:  I too am waiting for the other

 

      questions on the elderly and on males.  I would say

 

      this does represent a large sub-cohort of patients.

 

                DR. FOGEL:  Dr. Metz?

 

                DR. METZ:  Yes, age and gender not

 

      withstanding, plus potential confounding with

 

      irritable bowel, I think this is the kind of

 

      patient that walks in the door and ends up in these

 

      studies.  I have no problem.

 

                DR. FOGEL:  I would agree with Dr. Metz.

 

      Dr. Sachar?

 

                DR. SACHAR:  I would have said no on the

 

      basis of age and gender and confounding with IBS,

 

      but I think it is a duplicative question and I am

 

      going to roll (c) and (d) into (b) and say no.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  I am younger than Dr. Sachar

 

      so I would say--

 

                                                               306

 

                DR. SACHAR:  Everybody is younger than me!

 

                DR. BUCHMAN:  It actually does fit with

 

      the patients that I would certainly see, but I want

 

      to add a caveat and I think this is much more

 

      important than the rest of the question.  That is,

 

      there is--if any--efficacy for 12 weeks, not for

 

      treatment of chronic constipation in any of these

 

      groups regardless of age, sex, gender, ethnic group

 

      or the planet that they are from.

 

                DR. FOGEL:  Dr. Mangel?/

 

                DR. MANGEL:  I agree with Dr. Prather's

 

      comment this morning that symptoms don't

 

      distinguish constipation subtypes, and Dr.

 

      Schoenfeld's comment that treatments are the same

 

      regardless, but I don't think this represents

 

      chronic constipation.  I think the population which

 

      was included was a subtype of chronic constipation.

 

      The have a functional constipation.  So, I say no.

 

                DR. FOGEL:  Thank you.  Dr. Cryer?

 

                DR. CRYER:  I also say no.  When you look

 

      at the demographic profile of the population that

 

      was studied here and then if you were to compare it

 

                                                               307

 

      to the Pare study, the Canadian study that Dr.

 

      Prather showed us earlier, the percentages were

 

      quite similar.  Fifteen percent of the people were

 

      older than 65.  However, the thing that really

 

      caught my attention was when Dr. Prather spoke

 

      about her recent experience of self-reported

 

      constipation in older populations.  If I remember

 

      correctly, it was 40-50 percent of the people in

 

      that older population who were self-reporting

 

      constipation.  So, my suspicion is that if these

 

      observations were generalized in clinical practice

 

      ultimately, that would be the target population

 

      that would frequently request this drug.

 

                DR. FOGEL:  Thank you.   The next

 

      question, only 9 to 16 percent of subjects were

 

      greater than 65 years of age and the treatment

 

      effect was significantly smaller in older

 

      populations.  Are these data adequate for an

 

      indication that is common in the elderly?  Yes or

 

      no, Dr. Cryer?

 

                DR. CRYER:  Following up on my recent

 

      comments, no, and I reached my conclusion when I

 

                                                               308

 

      saw Dr. Prizont's statistical evaluation of the

 

      data in which he concluded that in subjects greater

 

      than 65 there was no statistical or numerical

 

      difference seen.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  Yes, I need a clarification

 

      of the question, if I could.  I could read this

 

      question one of two ways.  The first is that those

 

      greater than 65 should be excluded,

 

      contraindicated, whatever, in the label.  The

 

      second interpretation of the question is because

 

      there is inadequate number of patients who were

 

      greater than 65 should, therefore, the drug not be

 

      approved for this indication?  And, I just can't

 

      tell which way the question is intended.

 

                DR. FOGEL:  Dr. Justice?

 

                DR. JUSTICE:  It is the former.

 

                DR. MANGEL:  I believe individuals greater

 

      than age 65 should be excluded.  So, I guess the

 

      answer is no.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  I would agree with that. 

 

                                                               309

 

      The incidence of diarrhea as a side effect was

 

      actually greater than the efficacy in these

 

      patients, at 10.5 percent.  So, I would actually

 

      exclude the elderly from the indication.

 

                DR. FOGEL:  Dr. Sachar?

 

                DR. SACHAR:  I vote no, which means yes,

 

      exclude them.

 

                DR. FOGEL:  I believe that the elderly

 

      should be excluded.  Dr. Metz?

 

                DR. METZ:  No.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  I would say no, but I would

 

      like to point out that over 65 is maybe the elderly

 

      but there are a few of us here that don't really

 

      want to be called the old-old rather than the

 

      early-old.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  I vote no.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  No.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  No, and there is nothing

 

                                                               310

 

      magic about 65.  I think you should run further

 

      analyses.  If you do your quartile analyses the

 

      cut-off maybe should be 55 or 60.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  I think the data are certainly

 

      not adequate to prove safety in those aged 65, and

 

      they are strongly suggestive of, in fact, safety

 

      problems there and lack of efficacy.  So, I would

 

      support that it should not be used in those over

 

      age 65, especially given that they are most of the

 

      market.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  I think Novartis should

 

      expand their studies to people that are over 65

 

      before they are given the green light so the answer

 

      is no.

 

                DR. FOGEL:  And Dr. Levin?

 

                DR. LEVIN:  No.

 

                DR. FOGEL:  The next question, only 9 to

 

      14 percent of the subjects were male and the

 

      treatment effect was smaller in males than females.

 

      Are these data adequate to support approval of

 

                                                               311

 

      Zelnorm for use in the treatment of chronic

 

      constipation in males?  Dr. Levin?

 

                DR. LEVIN:  Pass.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  This is a touch one because

 

      it was a small number, 220-plus men.  However, when

 

      they showed us the data this afternoon there was a

 

      statistical significance.  Actually, it was pointed

 

      out that there were more percentage points for the

 

      men than the women.  I would certainly hate to deny

 

      anything to my male counterparts--

 

                [Laughter]

 

                --that women would get.  But I do think

 

      they need to expand those numbers so I will say the

 

      answer is no.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  I agree completely.  I think

 

      the results are very different than in the elderly.

 

      There wasn't evidence of an increased risk.  There

 

      wasn't evidence of an affirmative difference in

 

      efficacy, in contrast to the elderly.  On the other

 

      hand, the numbers are still small in order to

 

                                                               312

 

      ensure safety so I too wouldn't want to deny access

 

      to men but I would prefer to see more data before

 

      affirmatively saying yes.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  No.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  No.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  No.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  No.

 

                DR. FOGEL:  Dr. Metz?

 

                DR. METZ:  I would include men but I think

 

      more data are required.  It is very interesting to

 

      me that in the subgroup analyses we did see

 

      differences amongst men but in a regional

 

      presentation the odds ratio was absolutely 1 and

 

      the confidence intervals went in both directions.

 

      So, I think we need more information here.  I don't

 

      think it is going to be dangerous and, therefore, I

 

      would be quite willing to accept it.

 

                DR. FOGEL:  I vote no for men.  The data

 

                                                               313

 

      that was presented this afternoon showed a

 

      significant effect in the 200 or so patients.  The

 

      placebo effect was only 6 percent, which is much

 

      lower than anything else we have seen.  At this

 

      moment I would say no but I think that with

 

      additional data the answer could be a yes.  Dr.

 

      Sachar?

 

                DR. SACHAR:  As long as we are excluding

 

      people over 65, I would say yes for the males

 

      because the data looked pretty good for the young

 

      men.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  I agree with Dr. Sachar on

 

      that.  I thought that there was actually some

 

      efficacy in the young males.  Obviously, the effect

 

      we saw in the subgroups this afternoon was a little

 

      bit different from the overall effect this morning

 

      but that included the elderly males which may have

 

      watered down the effect seen in the young males.

 

      So, I think young males would be appropriate.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  No.

 

                                                               314

 

                DR. FOGEL:  Dr. Cryer?

 

                DR. CRYER:  The data aren't there but the

 

      trends certainly are.  I didn't see a safety signal

 

      of concern in young men and so my sense is yes,

 

      consistent with what has been commented before.

 

                DR. FOGEL:  The next question, are the

 

      clinical trial data adequate with respect to the

 

      population of non-IBS patients with chronic

 

      constipation that is likely to be treated with

 

      Zelnorm?  Dr. Cryer?

 

                DR. CRYER:  In brief, yes.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  I would say yes with chronic

 

      constipation being substituted by functional

 

      constipation-predominant.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  I would say yes, although I

 

      still have some concern that 15 percent of the

 

      patients that entered and completed the trial

 

      didn't even have constipation.  So, I am not sure

 

      how representative everything is.

 

                DR. FOGEL:  Dr. Sachar?

 

                                                               315

 

                DR. SACHAR:  Strictly by the numbers,

 

      things didn't look bad when the IBS patients were

 

      subtracted, but this question specifies a

 

      population that is likely to be treated with

 

      Zelnorm and, because I think that the people who

 

      are going to get treated with Zelnorm are not going

 

      to be well distinguished between those with IBS and

 

      those without, I would have to say no.

 

                DR. FOGEL:  I would say yes.  Dr. Metz?

 

                DR. METZ:  I have a concern and perhaps I

 

      need a clarification of the question.  If we are

 

      talking about what is really going to go on in the

 

      big, wide world when people get their hands on this

 

      drug, I have a concern that it may potentially be

 

      given to people with other types of disease states

 

      and, therefore, I think that the answer would be

 

      no.  On the other hand, if I look at what the data

 

      is as was presented, if you just take the IBS-like

 

      patients out, I am quite happy that the drug worked

 

      within the definition of the study parameters.  So,

 

      I think I need a clarification on the question.

 

                DR. FOGEL:  FDA?

 

                                                               316

 

                DR. JUSTICE:  It is the population that is

 

      likely to be treated that we are concerned about.

 

                DR. BUCHMAN:  You mean including secondary

 

      causes of constipation?

 

                DR. JUSTICE:  Yes.

 

                DR. BUCHMAN:  You would be including

 

      secondary causes of constipation in that question

 

      then?  Is that correct?

 

                DR. JUSTICE:  Well, any off-label use

 

      would be considered--we are specifically concerned

 

      about the labeled indication.

 

                DR. BUCHMAN:  A lot of people with

 

      secondary constipation probably would be treated if

 

      it was approved for primary constipation.

 

                DR. FOGEL:  Let me just ask the FDA, I

 

      assume the assumption is made that if the patient

 

      is evaluated and diagnosed appropriately is the

 

      drug indicated?  You are not taking ownership of

 

      medical care across the country, are you?

 

                DR. JUSTICE:  That is correct.  No, we are

 

      not.

 

                DR. FOGEL:  Dr. Metz?

 

                                                               317

 

                DR. METZ:  Well, that still doesn't

 

      clarify it for me.  The bottom line is I can accept

 

      this label.  I think the safety side is going to

 

      have to be well strengthened.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  I certainly agree about

 

      safety.  I also have a concern about the robust

 

      amount--how robust this is and I am very

 

      disappointed in the figures.  So, I am going to

 

      abstain.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  I vote yes.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  Yes.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  Well, I am struggling.  I

 

      think for use over 12 weeks--is it 12 weeks?

 

                DR. FOGEL:  Yes.

 

                DR. BUCHMAN:  That is not correct.  It is

 

      chronic; it is not limited to 12 weeks.

 

                DR. FURBERG:  That affects my answer.

 

      They have data for 12 weeks.

 

                                                               318

 

                DR. BUCHMAN:  It was the statistician from

 

      North Carolina that said 12 weeks; he is the only

 

      one.

 

                DR. FOGEL:  Clarification from the FDA,

 

      please.

 

                DR. JUSTICE:  Well, I think the sponsor is

 

      proposing to limit treatment to 12 weeks.

 

                DR. BUCHMAN:  So, the label indication

 

      will be 12 weeks?

 

                DR. JUSTICE:  Well, in the dosage and

 

      administration.  In the indication section it will

 

      say for chronic constipation, and then in the

 

      dosage and administration section they are

 

      proposing to say for 12 weeks of treatment.

 

                DR. BUCHMAN:  The indication slide

 

      actually didn't say 12 weeks.  It just said chronic

 

      constipation.  That needs to be changed.

 

                DR. FOGEL:  No, no, no, the indication for

 

      the drug is chronic constipation.  The duration of

 

      treatment is 12 weeks.  So, the drug is only being

 

      approved for a 12-week course of therapy.  I

 

      believe that is correct.

 

                                                               319

 

                DR. CUTT:  That is correct because the

 

      indication usually addresses the population and the

 

      dosage and administration section in the label

 

      addresses how you administer the drug.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  Yes, for use over 12 weeks

 

      but I am concerned.  It should be pointed out that

 

      they have no data on long-term efficacy and safety.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  My answer is no and it is

 

      really for three reasons.  One is that those likely

 

      to be treated with Zelnorm are likely to be mostly

 

      elderly and we haven't seen that.  Second, most of

 

      the use I still think is going to be long-term use,

 

      regardless of what the label says, and we haven't

 

      seen the data on that.  The third is the issue of

 

      direct-to-consumer ads which are going to have all

 

      sorts of people coming out of the woodwork who are

 

      not now coming for medical attention for treatment

 

      for constipation and would not have been included

 

      in the clinical trials.

 

                DR. FOGEL:  Dr. Sjogren?

 

                                                               320

 

                DR. SJOGREN:  My answer is going to be yes

 

      if, indeed, the FDA is going to limit the age group

 

      of the patients to a population that is represented

 

      by the clinical trial.

 

                DR. FOGEL:  Dr. Levin?

 

                DR. LEVIN:  No for all the reasons that

 

      Brian stated.

 

                DR. FOGEL:  The next question is as

 

      follows, is Zelnorm effective for the treatment of

 

      chronic constipation and associated symptoms?  Why

 

      don't we start with Dr. Metz this time?

 

                DR. METZ:  Yes.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  As I said, I didn't think it

 

      was sufficiently robust but I am going to vote yes

 

      if we limit it to the kind of populations that we

 

      are all targeting.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  Yes.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  You know, we said we

 

      don't have data on the elderly and we talked about

 

                                                               321

 

      the males, and so forth, but all of those put

 

      aside, yes.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  I abstain.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  Yes, excluding the elderly.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  Yes.

 

                DR. FOGEL:  Dr. Levin?

 

                DR. LEVIN:  I abstain.

 

                DR. FOGEL:  Dr. Cryer?

 

                DR. CRYER:  It is a yes with a strong

 

      exclusion, and I think we really need to look very

 

      carefully at the exclusion of the elderly

 

      population because of lack of efficacy and of

 

      safety signal.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  Yes.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  I think there is a

 

      suggestion about some efficacy but not sufficient

 

      for me to vote yes.  I disagreed with the primary

 

                                                               322

 

      endpoints.  I wasn't involved when that was

 

      designed, but that is not my problem.  So, that is

 

      a no.

 

                DR. FOGEL:  Dr. Sachar?

 

                DR. SACHAR:  Well, coming from New York, I

 

      think I live in the real world and I am going to

 

      say no.

 

                DR. FOGEL:  I say yes, with the caveats of

 

      age and male gender.  Dr. Levine?

 

                DR. LEVINE:  I am switching my vote from

 

      yes to no.

 

                DR. FURBERG:  And so do I.

 

                DR. FOGEL:  Why don't we re-vote on this

 

      just to make sure.  You got it?  Okay.

 

                The next set of questions deal with

 

      safety.  Question number one, postmarketing cases

 

      of ischemic colitis and serious complications of

 

      diarrhea were not limited to patients with

 

      irritable bowel syndrome.  What are the

 

      implications of these adverse events for patients

 

      with chronic constipation?  Dr. Sachar?

 

                DR. SACHAR:  Is that a yes/no?

 

                                                               323

 

                [Laughter]

 

                I think the implications are that safety

 

      is not adequately established, especially in view

 

      of the lack of estimate with the population at

 

      highest risk being placed in the denominator.  So,

 

      I am going to say I don't think it is safe.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  Given the fact that new

 

      onset of diarrhea in an elderly person who was

 

      previously constipated could actually be the only

 

      sign of ischemic bowel disease or ischemic colitis,

 

      I would have significant concern with that and

 

      would have to say no.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  I am sorry, I don't really

 

      see where this is a yes/no answer.

 

                DR. FOGEL:  It is not a yes/no.

 

                DR. BUCHMAN:  Then just strike my last

 

      sentence.

 

                DR. MANGEL:  Where we are right now, I am

 

      not quite sure we could answer this question one

 

      way or another, forgetting about the yes/no.  I

 

                                                               324

 

      think we are still going to discuss today, and

 

      obviously it won't be resolved today, is there an

 

      increased incidence of ischemic colitis in

 

      irritable bowel syndrome.  The bulk of the events

 

      of ischemic colitis were in the IBS patients.  I am

 

      sure that we have a good handle from the

 

      postmarketing data on how many of the constipated

 

      patients--I think there were two constipated

 

      patients with ischemic colitis but we don't know

 

      how many patients received the drug for

 

      constipation.  I think it is just too early to

 

      comment on it.

 

                DR. FOGEL:  Thank you.  Dr. Cryer?

 

                DR. CRYER:  I think we all acknowledge

 

      that there is clearly under-reporting in the

 

      postmarketing experience, and what I learned from

 

      this is that there is clearly a great amount of

 

      off-label use, based on the demographics of the

 

      prescribing that we saw today and what we know from

 

      other therapeutic categories.  So, I do not think

 

      that 11,600 patients in the clinical trial

 

      experience to date are going to be representative

 

                                                               325

 

      of the older population and their risk for these

 

      adverse events.  I also was concerned with the very

 

      high, 12 percent, incidence of diarrhea in the

 

      population that was greater than 65, from these

 

      trials.  So, the implication for these events as it

 

      relates to chronic constipation is that I do have

 

      some concern, particularly in these who are greater

 

      than 65 years of age.

 

                DR. FOGEL:  Dr. Levin?

 

                DR. LEVIN:  I would say based on what we

 

      heard today there are still serious concerns about

 

      the safety profile of the drug.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  I think the sponsor has done

 

      a very good job in presenting to us the results of

 

      the clinical trial and emphasizing that is young

 

      person in the placebo group that developed ischemic

 

      colitis.  So, it is a very serious diagnosis but I

 

      do feel that if we don't address the over 65, we

 

      don't lump them into this, they have done a pretty

 

      decent job and I don't have as many concerns as

 

      with other drugs in terms of ischemic colitis.

 

                                                               326

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  I vote against ischemic

 

      colitis and severe diarrhea.

 

                [Laughter]

 

                DR. FOGEL:  Okay, thank you.  Dr. Furberg?

 

                DR. FURBERG:  Those problems represent a

 

      serious concern and there should be warning

 

      included in the labeling.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  I think there are still

 

      concerns.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  Yes, it is serious and I

 

      think we are going to come to the warning versus

 

      precautions but these are serious complications and

 

      the implications are that we have to deal with

 

      them.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  I agree.

 

                DR. FOGEL:  Dr. Metz?

 

                DR. METZ:  Yes, implications of these

 

      issues--I am very comfortable that this drug works

 

                                                               327

 

      in the selected population that has been targeted

 

      and I don't want to see it denied.  So, I would

 

      vote to approve but the implications of these

 

      issues are that I think we have to be very careful

 

      about having the drug get over-used in populations

 

      where efficacy hasn't been shown and there might be

 

      concerns, primarily the elderly, and I am not sure

 

      in my mind what to do about the males but I think

 

      the younger males should be getting the drug.  So,

 

      the implication is that I would limit the access or

 

      make people aware of the fact that this isn't

 

      something you can just dish out like M&Ms.

 

                DR. FOGEL:  I think that the adverse

 

      events are something that require additional

 

      attention, and I think a proactive postmarketing

 

      effort needs to be made to make sure that we

 

      actually quantify these adverse events.  So, I

 

      think it is an issue.

 

                Before we go on to the next questions, we

 

      are actually just going to quickly review what we

 

      already decided.  Tom?

 

                DR. PEREZ:  I feel like I am on a runaway

 

                                                               328

 

      train here.  As far as the questions where we have

 

      taken clear votes, the first one was 1(c), for

 

      which we had a unanimous 13 no's.  For 1(d), we had

 

      8 no and 5 yes.  Number 1(e), we had 9 yes with

 

      caveats in many of them, 3 no, 1 abstained.  For

 

      1(f), we had 7 yes, 3 no and 1 abstained.

 

                DR. FOGEL:  We are going to move on.

 

                DR. BEITZ:  Excuse me, I thought we had

 

      two abstentions.

 

                DR. PEREZ:  For what?

 

                DR. BEITZ:  For 1(f).

 

                DR. PEREZ:  One changed so we have one

 

      abstention, Furberg changed from an abstention to a

 

      no vote.

 

                DR. SACHAR:  What about 1(b), did we ever

 

      vote?

 

                DR. PEREZ:  We didn't have a clear vote on

 

      that.  Let's see, we had a lot of comments but

 

      there was no clear indication of a yes or no.

 

                DR. SACHAR:  That is like the last

 

      election.

 

                DR. PEREZ:  If you would like to take a

 

                                                               329

 

      vote on that--

 

                DR. FOGEL:  Would the committee like to

 

      take a vote on question 1(b)?  The question that we

 

      are going to vote on is, is the population studied

 

      representative of patients with chronic

 

      constipation?  Yes or no?  Dr. Levin?

 

                DR. LEVIN:  Abstain.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  Yes.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  No because of the elderly

 

      issues.

 

                DR. FURBERG:  No.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  We went through this in

 

      terms of saying that in answering this we were

 

      anticipating also (c) and (d).  So, excluding the

 

      (c) and (d) part in the IBS I said yes.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  Yes.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  Yes.

 

                                                               330

 

                DR. FOGEL:  Dr. Metz?

 

                DR. METZ:  Abstain.

 

                DR. FOGEL:  Yes.  Dr. Sachar?

 

                DR. SACHAR:  No.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  Yes.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  No, I think it is functional

 

      constipation.

 

                DR. FOGEL:  Dr. Cryer?

 

                DR. CRYER:  No.

 

                DR. FOGEL:  Thank you.  We are going to

 

      move on now--

 

                DR. PEREZ:  Wait a minute.  We have 5 no,

 

      6 yes and 2 abstentions.

 

                DR. FOGEL:  Safety question 2(b), the

 

      incidence of diarrhea and discontinuations due to

 

      diarrhea was higher in patients greater than 65

 

      years of age.  Is there sufficient information that

 

      Zelnorm is safe for use in this age group?  Dr.

 

      Levin?

 

                DR. LEVIN:  Resoundingly no.

 

                                                               331

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  No.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  No, and I am also worried

 

      about incidence of diarrhea but that diarrhea will

 

      have worse implications in the elderly.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  No.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  No.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  No.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  No.

 

                DR. FOGEL:  Dr. Metz?

 

                DR. METZ:  No.

 

                DR. FOGEL:  No.  Dr. Sachar?

 

                DR. SACHAR:  No.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  No.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  No.

 

                                                               332

 

                DR. FOGEL:  Dr. Cryer?

 

                DR. CRYER:  No.

 

                DR. PEREZ:  Thirteen no.

 

                DR. FOGEL:  Question 2(c), do the adverse

 

      event data from the clinical trials and post

 

      surveillance provide adequate evidence of safety of

 

      Zelnorm for the treatment of chronic constipation?

 

      Dr. Cryer?

 

                DR. CRYER:  I was just reading the

 

      question.  My answer is no.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  Well, once again, excluding

 

      the subgroups which have been spoken about I would

 

      say yes.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  I am going to abstain

 

      because although in essence it is insufficient but

 

      what else can you do, besides get the data from

 

      clinical trials and postmarketing surveillance?  We

 

      don't live in a communistic society or in a society

 

      where there is a registry for everybody with

 

      constipation.

 

                                                               333

 

                DR. FOGEL:  Dr. Sachar?

 

                DR. SACHAR:  In the grand scheme of the

 

      world, yes.

 

                DR. FOGEL:  For the population under age

 

      65, I think that there is adequate evidence of

 

      safety of Zelnorm.  But we know from other drugs

 

      that with increased use of the drug we will see

 

      increased incidence of complications.  Dr. Metz?

 

                DR. METZ:  Yes, for people under 60, 65,

 

      70, wherever the cut-off ultimately ends up.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  yes, if we look at a cut-off

 

      of 55, 60, 65 etc. and find a good cut-off.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  yes.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  Yes, with the same

 

      comment about the age cut-off.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  No because of the long-term

 

      safety.

 

                DR. FOGEL:  Dr. Strom?

 

                                                               334

 

                DR. STROM:  Yes for short-term use in

 

      young women.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  Yes, with the same caveats

 

      for age.

 

                DR. FOGEL:  Dr. levin?

 

                DR. LEVIN:  No because of the lack of

 

      long-term data.

 

                DR. PEREZ:  Let's see, question 2(c) had 9

 

      yes responses, 3 no and 1 abstention.

 

                DR. FOGEL:  Question 2(d) should the

 

      information on the postmarketing cases of ischemic

 

      colitis and intestinal ischemia be moved from the

 

      precautions section to the warning section of the

 

      package insert?

 

                The labeling regulations state that the

 

      precautions section of the labeling "shall contain

 

      information regarding any special care to be

 

      exercised by the practitioner for safe and

 

      effective use of the drug."  The warnings section

 

      "shall describe serious adverse reactions and

 

      potential safety hazards, limitations in use

 

                                                               335

 

      imposed by them, and steps that should be taken if

 

      they occur.  The labeling shall be revised to

 

      include a warning as soon as there is reasonable

 

      evidence of an association of a serious hazard with

 

      a drug; a causal relationship need not have been

 

      proved."  In addition, the warnings section should

 

      include any potentially fatal adverse reactions.

 

                So, to re-read the question, should the

 

      information on the postmarketing cases of ischemic

 

      colitis and intestinal ischemia be moved from the

 

      precautions section to the warnings section of the

 

      package insert?

 

                DR. LEVINE:  Clarification.

 

                DR. FOGEL:  Yes?

 

                DR. LEVINE:  Is age considered here?  In

 

      other words, are you going to say a warning for

 

      over 65 and no warning for under 65?

 

                DR. FOGEL:  FDA?

 

                DR. JUSTICE:  No, we are not proposing to

 

      separate by age.

 

                DR. BUCHMAN:  Actually, I want to ask the

 

      FDA one other question for another choice in this. 

 

                                                               336

 

      Because there is no way to prevent ischemic colitis

 

      in a patient who you are not suspecting has

 

      underlying SMA disease for example, or IMA disease,

 

      the only way to prevent it is not to give the drug.

 

      That would actually not make it a warning; that

 

      would make it a contraindication.  So, is the

 

      choice actually between a precaution and a

 

      contraindication with warning actually not even an

 

      issue?  Are we actually being asked to choose make

 

      the correct choice here?

 

                DR. FOGEL:  Hang on one second.

 

                DR. SCHOENFELD:  I just wanted to note

 

      that the revised labeling, the revised labeling

 

      that went into effect in April, specifically says

 

      that if a patient develops ischemic colitis they

 

      shouldn't get the drug.  So, if I understand Alan

 

      correctly, if a patient has ischemic colitis it

 

      specifically says that you should not prescribe it

 

      and that is now in the labeling.

 

                DR. FOGEL:  Can we get a clarification

 

      from the FDA?

 

                DR. JUSTICE:  We are only asking whether

 

                                                               337

 

      it should be moved from precautions to warnings.

 

      We are not proposing a contraindication.

 

                DR. BUCHMAN:  But I am asking you whether

 

      you should because the thing is that if you have a

 

      patient who doesn't have a history of ischemic

 

      colitis, because it clearly would be

 

      contraindicated in that individual and I think that

 

      is probably adequate as it is stated, the question

 

      is if there is a risk of ischemic colitis in a

 

      patient who is not known to have ischemic colitis,

 

      is the drug contraindicated in that individual?  If

 

      they are on birth control pills for example, should

 

      they not receive Zelnorm?  That would be a

 

      contraindication for example.

 

                DR. FOGEL:  We don't have any data to

 

      support that.

 

                DR. BUCHMAN:  We don't, but then maybe it

 

      should stay as a precaution.  Because the warning

 

      is in between.  It means you don't know what

 

      decision you should make.  If it truly is linked to

 

      ischemic colitis, for example, then clearly, in my

 

      mind, a young woman who is receiving birth control

 

                                                               338

 

      pills should not get Zelnorm.  If we don't think

 

      that it is, then we could leave it safely as a

 

      precaution because there is nothing you can do

 

      about it, other than not give it.

 

                MS. DINGEMANSE:  May I comment?  We have

 

      done a study in 45 women of childbearing age

 

      receiving oral contraceptives, and we also looked

 

      at the progesterone levels to assess the lack of

 

      ovulation.  This was proven.  This study has been

 

      submitted with the IBS application.  So, there is

 

      no increased risk of ovulation and also the

 

      pharmacokinetics have not changed the ethinyl

 

      estradiol and level of norgestrel to a significant

 

      level.  They are a little lower for the level of

 

      norgestrel but there is no change in ethinyl

 

      estradiol.

 

                DR. MANGEL:  I am reading the question

 

      different from Dr. Buchman.  Your different

 

      severities of regulatory statements, regulatory

 

      advice where a warning is more severe than a

 

      precaution and where actually a contraindication is

 

      a different family of material in the label than

 

                                                               339

 

      either a precaution or a warning.  In reading the

 

      question, is the threshold met that this is more

 

      severe than a precaution and warrants a warning,

 

      rather than starting to evoke whether or not there

 

      is additivity or synergism with other populations.

 

                DR. FOGEL:  Let me ask the FDA a question.

 

      What is the specific issue that you want us to

 

      address here?

 

                DR. BEITZ:  Well, before we get to that, I

 

      want to read you the regulation on

 

      contraindications.  Under that heading, the

 

      labeling would describe situations in which a drug

 

      should not be used because the risk of use clearly

 

      outweighs any possible benefit.  So, it is pretty

 

      strong language.  Then, further on the regulations

 

      say known hazards and not theoretical possibilities

 

      shall be listed.

 

                DR. JUSTICE:  What we are asking is

 

      whether the language that is currently in the

 

      precautions section regarding ischemic colitis and

 

      intestinal ischemia should be upgraded from a

 

      precaution to a warning.  We don't think we have

 

                                                               340

 

      sufficient information to propose a

 

      contraindication.

 

                DR. FOGEL:  Thank you.  Is that clear to

 

      the committee?  Dr. Levin?

 

                DR. LEVIN:  We also had some discussion

 

      about the wording of the precaution.  Is that

 

      appropriate to address?  There was some feeling

 

      that it was a little too positive a precaution, if

 

      such a thing is possible.  Forgive my ignorance, is

 

      there a medication guide required with Zelnorm?  Is

 

      that an issue to be discussed today?

 

                DR. JUSTICE:  No.

 

                DR. MANGEL:  Before the vote, could I just

 

      also get a clarification.  For me, when I look on

 

      the surface it looks like perhaps two and a half

 

      months after a label change when, at least my

 

      understanding from what I heard today, is that

 

      there is not a new signal; there is not a concern

 

      to upgrade the safety information within the label,

 

      I am concerned about alarming the prescribing

 

      community for another "dear doctor" letter to go

 

      out saying it goes from a precaution to a warning

 

                                                               341

 

      when perhaps at one level it is a clarification

 

      from your previous conversations with the sponsor.

 

      I am curious if it is upgraded to a warning if you

 

      have a plan or even a preliminary plan of what the

 

      roll-out would be.  Would there be a medication

 

      guide?  Would there be a "dear doctor" letter?  You

 

      know, what would be the nature of the explanation

 

      for the prescribing community?

 

                DR. JUSTICE:  The answer to the first

 

      question is that one of the reasons we are asking

 

      now, after having made these changes, is that if

 

      Zelnorm is approved for chronic constipation it

 

      would be expanded to a larger population with a

 

      potentially different risk/benefit ratio.  So, I

 

      think it is a new question now.

 

                I think as far as would we request a "dear

 

      doctor" letter or med guide, we have not discussed

 

      that internally so we are not prepared to give you

 

      the answer right now.

 

                DR. FOGEL:  Dr. Cryer?

 

                DR. CRYER:  I just want to echo comments

 

      which Dr. Justice just made which caught my

 

                                                               342

 

      attention, that is that the approval of Zelnorm for

 

      a different indication will clearly lead to an

 

      expansion to different populations and a change in

 

      the risk/benefit ratio which we have seen to date,

 

      and principally younger women.

 

                So, as I read this, what the warnings

 

      allow that differ from what the precautions would

 

      provide is a mechanism to alert the prescribing

 

      physician of what those concerns might be in brief

 

      and what we have summarized in our discussions

 

      today.  The specific mechanisms that I see here in

 

      the warnings section suggest a potential safety

 

      concern, potential safety hazards and,

 

      specifically, limitations imposed by them.  So, if

 

      there is not going to be any specific

 

      differentiation of a warning or a precaution based

 

      upon an age of 65, I think that that specific

 

      limitation should be implemented using the warning

 

      mechanism, specifically age.

 

                DR. FOGEL:  Dr. Mangel?

 

                DR. MANGEL:  I think the answer is still

 

      unknown with respect to IBS versus Zelnorm.  I

 

                                                               343

 

      don't see a signal for chronic constipation but, by

 

      the same token, based on the IBS data we wouldn't

 

      have seen it yet, not enough patients.  I am

 

      concerned about upgrading the label with no new

 

      information.  If this was the original label and

 

      you asked should it be a warning for IBS, I would

 

      have been comfortable with yes at that point.  To

 

      change it now, I would say no.

 

                DR. DELLA'ZANNA:  I am just going to make

 

      a statement.  Without knowing the results of

 

      whether or not this gets approved or not approved

 

      for the chronic constipation, we may be looking at

 

      a recent labeling change either way.

 

                DR. MANGEL:  And my answer would still be

 

      the same.  It would be no based upon no new signal.

 

      For me, it would have been on the fence but it

 

      would have been certainly credible for IBS for

 

      there to be a warning versus a precaution.  It

 

      could have gone either way since there were no

 

      cases in 11,000 individuals in clinical trials,

 

      which gives us a degree of comfort in terms of the

 

      relative rate.  To make the change now with no new

 

                                                               344

 

      data, I would say no.

 

                DR. SACHAR:  Even though it says, "in

 

      addition, the warnings section should include any

 

      potentially fatal adverse reaction?"

 

                DR. MANGEL:  Yes.  I understand that and,

 

      once again, if a drug is given to three million

 

      people some people will die.  You know, that is

 

      where I don't think we have robust enough data to

 

      say you have four deaths out of three million and

 

      for each of the deaths they were difficult,

 

      confounded cases--is that reasonable; unreasonable?

 

      Where we sit now, I would say it is not a clear

 

      association.

 

                DR. FOGEL:  Dr. Buchman?

 

                DR. BUCHMAN:  I would leave it as a

 

      precaution but with a significant caveat.  We don't

 

      actually even know what the incidence of ischemic

 

      bowel disease is in the general population.  I

 

      don't believe the data that it is increased in

 

      irritable bowel syndrome because that is an

 

      oxymoron statement because they wouldn't have

 

      irritable bowel syndrome if they had ischemic bowel

 

                                                               345

 

      disease.  But I think that the precaution should be

 

      substantially more robust, including not only what

 

      we discussed this morning, to make them equal

 

      length, but to actually make it longer.  I think it

 

      specifically should list in precautions that it

 

      should be used with precaution in individuals that

 

      are taking concomitant oral contraceptives, and who

 

      smoke, and who have coexistent or known thrombotic

 

      disorders, and I think there needs to be

 

      postmarketing surveillance in those particular

 

      individuals because those would be at the highest

 

      risk for developing ischemic disease and could

 

      easily change to a warning or a contraindication,

 

      depending on what the results of that postmarketing

 

      surveillance would be.

 

                DR. FOGEL:  I just want to make sure your

 

      answer is yes, it stays as a precaution?

 

                DR. BUCHMAN:  No, my answer is no, it

 

      stays as a precaution.

 

                DR. FOGEL:  Dr. Sachar?

 

                DR. SACHAR:  I think the best way to

 

      achieve Dr. Buchman's aims is to move it to the

 

                                                               346

 

      warnings section.  I would say yes.

 

                DR. FOGEL:  If we exclude those people

 

      over the age of 65, I would recommend that it stay

 

      as a precaution, and I agree with the comments of

 

      Dr. Buchman.  Dr. Metz?

 

                DR. METZ:  I would say no, I would leave

 

      it as a precaution.  I think that we have no real

 

      data to suggest that the drug has this negative

 

      impact.  We are all worried about it but there is

 

      nothing that is a strong warning to me.  I do,

 

      however, think it is very important that an

 

      additional precaution go into this label, and that

 

      is that idiopathic constipation is what it is

 

      indicated for.  It is not indicated for secondary

 

      causes of constipation, and there is potentially

 

      concern about efficacy and risk/benefit in people

 

      over 65.  So, that would be an expansion, I

 

      suppose, of the precautions section but that

 

      doesn't mean that people won't be able to use it

 

      for those specific indications.

 

                On the other hand, I would feel

 

      uncomfortable if you took a long laundry list of

 

                                                               347

 

      all the potential risk factors of thrombotic events

 

      because then you are going to be frightening the

 

      very people who are going to be using these drugs,

 

      and there is no data in my opinion to suggest that

 

      smoking has an effect on this particular

 

      population, that hypocholesteremia, hypotension,

 

      diabetes and other things you might put in.  So, I

 

      don't think it should be so restrictive.

 

                I am concerned about secondary causes and

 

      I am concerned about the risk/benefit ratio in the

 

      elderly, but they may well ultimately be people to

 

      benefit from this drug.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  I would say yes, I would put

 

      it in the warnings because in the real world what

 

      is going to happen is that this is going to be used

 

      much more frequently in non-indicated patients.

 

      Number two, I predict, as with Rezulin and a few

 

      other drugs, as more patients use it you will begin

 

      to see, very likely, signs of ischemic colitis or

 

      vasculitis or other types of things that we don't

 

      know yet.  I would say if you can make a very

 

                                                               348

 

      strong precautionary note at this point and then

 

      change it to a warning when you see the rise in the

 

      postmarketing--I think one and a half years is

 

      nothing for these figures in postmarketing.  You

 

      are going to see a huge change, I predict.  So, I

 

      would vote yes, move it to a warning.

 

                DR. FOGEL:  Dr. LaMont?

 

                DR. LAMONT:  Yes, I think that there is

 

      reasonable evidence of an association although it

 

      is not causal, and it is potentially fatal.  So, I

 

      vote yes, to move it to the warnings section.

 

                DR. FOGEL:  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  No, I don't see the data

 

      justifying it.

 

                DR. FURBERG:  I do, yes.

 

                DR. FOGEL:  Dr. Furberg is yes.  Dr.

 

      D'Agostino is no.  Dr. Strom?

 

                DR. STROM:  I vote yes.  I think there are

 

      no data; since the "dear doctor" letter came out

 

      there is a wave of new adverse reactions.  I think

 

      there isn't a strong association when you have

 

      rates of reported adverse reactions, spontaneous

 

                                                               349

 

      reports, which are on the same order as the

 

      background rate of disease, given the available

 

      data.  The only argument against that are the data

 

      suggesting that maybe people with IBS have a higher

 

      rate of ischemic colitis and I don't find that

 

      credible but I haven't seen those studies in enough

 

      detail to be able to comment on them.  I am

 

      skeptical.

 

                I feel even more strongly that wording

 

      changes that need to be made that were suggested

 

      before so that we don't give a quantitative summary

 

      of only the absence of an effect and don't provide

 

      the quantitative summary where there is an effect.

 

                I think the other reason to put it into

 

      warnings is the issue of the elderly, and that this

 

      will be overused and shouldn't be used in the

 

      elderly, and that needs to be made loud and clear.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  Well, I feel at odds with

 

      some of my colleagues but the sponsor presented

 

      very good data in primates and in humans in

 

      coronary-arteries and mesenteric arteries that

 

                                                               350

 

      there is no effect of the drug.  So, I am puzzles

 

      by so much fear that I sense from some of my

 

      colleagues.  And, we are forgetting the thousands

 

      of patients in the clinical trials where there is

 

      no evidence of ischemia.

 

                I think the agency and we, ourselves, need

 

      to remain credible because if we are going to put

 

      in warnings for things that we are just fearful of,

 

      I think we are going in a very treacherous way.

 

      So, I would say to remain as a precaution rather

 

      than a warning.

 

                DR. FOGEL:  Thank you.  Dr. Levin?

 

                DR. LEVIN:  I would move it to warnings

 

      and, obviously since I talked about it, I would

 

      strengthen the wording to at least be equitable in

 

      describing non-events and events.

 

                I would also urge the agency to think

 

      seriously about a medication guide requirement

 

      because we are relying on patients, and this will

 

      be in the package labeling, to report immediately

 

      to their physicians certain symptoms that are

 

      indicative of serious adverse reactions and I think

 

                                                               351

 

      patients need to have that information given to

 

      them at the time of dispensing.  So, I really

 

      think, if you haven't thought about it, FDA, you

 

      ought to think about requiring a medication guide

 

      for this product.

 

                DR. PEREZ:  Dr. Levin, you said, yes, move

 

      it?

 

                DR. LEVIN:  Move it.

 

                DR. FOGEL:  Do you want to give us a

 

      summary of question two?

 

                DR. PEREZ:  Yes, 7 yes, 6 no.

 

                DR. FOGEL:  The last question, I will read

 

      it and I have a quick clarification question for

 

      FDA.  The question as written is as follows: Should

 

      Zelnorm be approved for the proposed indication of

 

      the treatment of patients with chronic constipation

 

      and relief of the associated symptoms of straining,

 

      hard or lumpy stools, and infrequent defecation?

 

                My question for clarification is as

 

      follows, we have had discussion about gender and

 

      age exclusions.  Is this just a question of what

 

      the indication would be, and the modifiers of

 

                                                               352

 

      gender and age will be added at a later date?

 

                DR. JUSTICE:  We can do that of, if the

 

      committee wants to revise the question to reflect

 

      the discussion about age and gender, they can do

 

      so.

 

                DR. FURBERG:  Can we also get in duration

 

      of treatment?

 

                DR. FOGEL:  Can we do that?

 

                DR. BUCHMAN:  To be short-term

 

      constipation?

 

                DR. FOGEL:  No, no, short-term treatment;

 

      long-term constipation is the indication.

 

                DR. STROM:  Ron, can I suggest two votes?

 

      One would be on the unqualified indication, the way

 

      it is worded.  The second would be an indication

 

      for short-term use in young women.

 

                DR. FOGEL:  Actually, we have a number of

 

      different clauses to consider.  Why don't we vote

 

      on the main question and we will vote on each one

 

      of these special cases.

 

                So, excluding gender, age, duration of

 

      therapy, should Zelnorm be approved for the

 

                                                               353

 

      proposed indication of the treatment of patients

 

      with chronic constipation and relief of the

 

      associated symptoms of straining, hard or lumpy

 

      stools, and infrequent defecation?  Yes or no, Dr.

 

      Levin?

 

                DR. STROM:  Can I just clarify the

 

      question again?  When you say excluding those--

 

                DR. FOGEL:  We will come to all those.

 

      Those will be separate votes.

 

                DR. STROM:  So, we are voting as written.

 

      You are asking for vote on an unrestricted

 

      indication.

 

                DR. FOGEL:  We are going to vote on the

 

      recommendation as written and we are going to add a

 

      number of different questions.

 

                DR. STROM:  I am still confused.

 

                DR. FOGEL:  We are going to vote on the

 

      question as written, and then we are going to vote

 

      on whether it should be used in people over the age

 

      of 65; whether it should be used for males.

 

                DR. LEVIN:  That is what the sponsor asked

 

      for so we are voting on what the sponsor asked for.

 

                                                               354

 

      No.

 

                DR. SJOGREN:  I am confused.  If I vote

 

      yes, that means that the sponsor will have no

 

      restrictions?

 

                DR. FOGEL:  Is that correct, FDA?

 

                DR. JUSTICE:  That is correct.

 

                DR. SJOGREN:  Then the vote is no.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  No.

 

                DR. FURBERG:  No.

 

                DR. D'AGOSTINO:  No.

 

                DR. LAMONT:  No.

 

                DR. LEVINE:  No.

 

                DR. FOGEL:  Dr. Metz?

 

                DR. METZ:  I am also still confused.  If I

 

      vote yes, the precautions and warnings and issues

 

      are all jacked up--

 

                DR. FOGEL:  No, we are voting on what it

 

      says.

 

                DR. METZ:  Then I have to vote no.

 

                DR. FOGEL:  No.

 

                DR. SACHAR:  No.

 

                                                               355

 

                DR. BUCHMAN:  No.

 

                DR. MANGEL:  No.

 

                DR. CRYER:  No.

 

                DR. PEREZ:  Unanimous, 13 no.

 

                DR. FOGEL:  What I would like to do is

 

      start by adding on a number of clauses.  Should

 

      Zelnorm be approved for the proposed indication of

 

      the treatment of patients with chronic constipation

 

      and relief of the associated symptoms for females

 

      only, for treatment of female patients only?

 

                DR. BUCHMAN:  That is excluding age?

 

                DR. FOGEL:  We will get to age next.  For

 

      female patients only?

 

                DR. STROM:  You are saying of any age and

 

      any duration?

 

                DR. FOGEL:  Correct.  Dr. Cryer?

 

                DR. CRYER:  You asked should Zelnorm be

 

      approved for females only?

 

                DR. FOGEL:  Right.  The question is should

 

      we exclude males?  Let's phrase it that way, the

 

      indication would exclude males from treatment.

 

                [Multi-member discussion]

 

                                                               356

 

                DR. JUSTICE:  Could I just offer a

 

      suggestion?  Maybe you could just go one by one and

 

      say what the exclusion should be.

 

                DR. FOGEL:  Okay, I think that is a better

 

      suggestion.  Dr. Cryer, what exclusions would you

 

      like to place on this?

 

                DR. CRYER:  Sixty-five or older; no gender

 

      exclusion.

 

                DR. MANGEL:  Sixty-five or older.  I would

 

      exclude males and I would change the nomenclature

 

      for chronic constipation to either functional or

 

      idiopathic constipation,

 

                DR. BUCHMAN:  I say no, actually, to

 

      anything because we are looking at a completely

 

      benign disorder, despite the fact that it affects

 

      lifestyle.  So, I think that really almost any

 

      adverse events are unacceptable, unless the data

 

      was really quite robust, and a 10 percent benefit

 

      over placebo is not sufficient for me to waive the

 

      adverse events.  I don't agree, actually, with the

 

      primary outcome variable of one bowel movement, and

 

      I looked at the three bowel movements which was

 

                                                               357

 

      statistically significant but not clinically

 

      significant.  So the bottom line is it is no for me

 

      under any circumstance.

 

                DR. FOGEL:  Dr. Sachar?

 

                DR. SACHAR:  I am with Dr. Buchman on

 

      this.  We have been here for eight hours and I am

 

      convinced that we can squeeze some statistical

 

      significance out of these data but, when all is

 

      said and done, knowing how this drug is going to be

 

      marketed, advertised, prescribed, renewed,

 

      continued, passed around and consumed, for me it

 

      just doesn't cut it.  I vote no approval under any

 

      circumstance.

 

                DR. FOGEL:  I vote for approval of the

 

      drug.  I would exclude all individuals over the age

 

      65.  I would exclude males and I would vote for a

 

      12-week course of therapy.  Dr. Metz?

 

                DR. METZ:  I would vote for approval.  I

 

      would exclude patients over 65.  I would have a

 

      precaution for males, that the risk/benefit ratio

 

      has not been shown.  I would suggest that there

 

      also is comment on the fact that the studies were

 

                                                               358

 

      only done for 12 weeks but I don't think it should

 

      be restricted to only 12 weeks.

 

                DR. FOGEL:  Dr. Levine?

 

                DR. LEVINE:  I was going to support what

 

      Dr. Buchman said about specific diseases, etc. to

 

      exclude.  I think the risk is so great that it will

 

      be over-utilized, I vote no.

 

                DR. METZ:  Forgive me for going back.  I

 

      feel very strongly that secondary causes of

 

      constipation should be considered before people

 

      start this drug and I would put that in.

 

                DR. FOGEL:  Thank you.  Dr. LaMont?

 

                DR. LAMONT:  Yes, I vote yes for 12 weeks

 

      of therapy in chronic idiopathic constipation,

 

      females only, less than 65.

 

                DR. FOGEL:  Thank you.  Dr. D'Agostino?

 

                DR. D'AGOSTINO:  The same.

 

                DR. FOGEL:  Dr. Furberg?

 

                DR. FURBERG:  The same.

 

                DR. FOGEL:  Dr. Strom?

 

                DR. STROM:  The same, but only if there

 

      was a risk management plan to ensure that, in fact,

 

                                                               359

 

      it was used that way.

 

                DR. FOGEL:  Dr. Sjogren?

 

                DR. SJOGREN:  Actually, I would like to

 

      say that it is not a benign condition.  I have

 

      several patients that have undergone surgeries.

 

      Some others have contemplated suicide.  It is a

 

      very serious condition for patients with

 

      constipation.  We are blessed, I guess, at this

 

      table, especially my male colleagues that are not

 

      being recruited into these studies--

 

                DR. BUCHMAN:  The drug didn't prevent

 

      surgery though.

 

                DR. SJOGREN:  No, no, but it is a very

 

      serious condition.  If you can treat it and there

 

      is hope with some kind of medical therapy I don't

 

      think we should deny it.  I vote yes for people

 

      that are 65 or younger.  I would not like to see

 

      men because the data, although very provocative,

 

      still needs to be expanded.  I think I would not

 

      restrict the length of the therapy.

 

                DR. FOGEL:  Dr. Levin?

 

                DR. LEVIN:  I would vote yes under 65;

 

                                                               360

 

      women only; 12 weeks of therapy.  I would add that

 

      there be a medication guide, and I agree with Brian

 

      that there be some sort of proactive risk

 

      management program, that we do not rely on what the

 

      studies tell us isn't very effective, that is,

 

      product labeling to do the job of preventing the

 

      use of this drug inappropriately in the general

 

      population.

 

                DR. FOGEL:  Thank you.  Any additional

 

      information that the FDA would like?  Any

 

      clarifications that they would like?

 

                DR. BEITZ:  Yes, since you brought it up,

 

      could you elaborate on the risk management plan

 

      that you are thinking about?

 

                DR. STROM:  The answer is easy--no.  It

 

      would not be an easy risk management plan because,

 

      obviously, use for IBS is very different and I am

 

      not suggesting it get stricter for IBS.  How you

 

      differentiate that, it is not clear.  We need a lot

 

      more thought than I have given it, and a lot more

 

      creativity I think.

 

                I think my point is I would only be

 

                                                               361

 

      comfortable with it being available in this way if

 

      there was a way of being sure it wasn't going to be

 

      overused.  I don't know that I can come up with

 

      such a way without impairing its use for IBS, which

 

      I am not suggesting that we do.  I guess one way

 

      would be just to look at things like, you know, a

 

      medication guide plus a close marketing survey

 

      about how the drug is being used, with the idea

 

      that if it is being used substantially in people

 

      over age 65 or long-term use, which are easy things

 

      to measure, that the company has to take major

 

      proactive action in order to limit use or risk

 

      losing the indication.

 

                Certainly the things we are concerned

 

      about--gender, age, duration--are easy things to

 

      measure in a postmarketing surveillance study, and

 

      I would want to make sure it is not happening, as

 

      well as to have the company very, very actively

 

      market, plus a med guide in order to prevent that.

 

                DR. FURBERG:  Discourage off-label use.

 

                DR. LEVIN:  I would agree, med guide,

 

      tracking to see how the drug is being used, and

 

                                                               362

 

      perhaps educational detailing is another method

 

      that the company could use to deal with off-label

 

      use and to deal with inappropriate use of the drug.

 

                DR. FOGEL:  Is there any other--

 

                DR. METZ:  I don't want to rush to a

 

      defense of the sponsor but a very important point

 

      is that the more you make these things restrictive,

 

      the more you chase the prescribing doc away and you

 

      deny drugs to patients when they certainly work for

 

      indications.  I think another drug that works

 

      exactly opposite to this one has essentially died

 

      because of that kind of intervention.  So, I would

 

      be wary about going overboard here and making it

 

      such a big spiel that it is just not going to

 

      happen.

 

                DR. FOGEL:  Well, I think the other drug

 

      died because it was over-prescribed and I think we

 

      are trying to save this drug from a potentially

 

      similar fate.

 

                DR. LEVIN:  The patients also died with

 

      the other drug, not just the drug.

 

                DR. SACHAR:  I need one comment on the

 

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      record because I am taking to heart the comments of

 

      Dr. Sjogren and of the patient representative who

 

      spoke to us, and I just want to make it clear that

 

      when I said I am with Dr. Buchman on this I exclude

 

      any implication that this is not a serious

 

      condition.

 

                DR. FOGEL:  Does the FDA have any other

 

      questions, clarifications that they want?

 

                DR. BUCHMAN:  I will modify my statement.

 

      The word benign is a relative term, and it is

 

      benign when compared to ischemic bowel; it is

 

      benign when compared to cancer.  I, myself, have

 

      never had a suicidal patient but it obviously is a

 

      problem or we wouldn't be here today.  But benign

 

      is a relative term only; so is efficacy.

 

                DR. STROM:  But I think it is also

 

      important to point out that the degree of efficacy

 

      we are dealing with here is very marginal.  I guess

 

      the other thing I would like to add is if we can

 

      see analyses of predictors of responders that look

 

      in much more detail at some of the kind of things I

 

      was asking about before, I would feel much more

 

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      comfortable with it being more freely available to

 

      people who fit that requirement.  My concern is

 

      broad use of the drug for a condition where there

 

      will be a very high placebo response rate and

 

      people are going to think the drug is

 

      working--patients and docs are going to think it is

 

      working when it is just placebo effect.

 

                DR. SACHAR:  you have stated well the

 

      basis of my no vote.

 

                DR. FOGEL:  Thank you all for your

 

      clarifications.  At this juncture, I would like to

 

      thank the members of the committee.  I would like

 

      to thank the representatives of the sponsor,

 

      Novartis.  I would like to thank the FDA.  And, we

 

      will close the meeting at this time.  Thank you,

 

      all.

 

                [Whereupon, at 4:45 p.m., the proceedings

 

      were adjourned.]

 

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