STOPPING RULES IN FIRST ENTRY INTO HUMAN STUDIES Club Phase 1 Working Party: Alain Patat, Yves Donazzolo, Henri Caplain, Stephan Chalon, Michel Sibille Joint Conference of European Human Pharmacological Societies and 20th Anniversary of AGAH AGAH, CLUB PHASE I, AHPPI & BAPU BERLIN, 31 Mar - 01 APR 2011 1 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 WHY French Club Phase I Working group : Br J Clin Pharmacol 2010 70:5 736–748 French Club Phase I Working group: A safety grading scale to support dose escalation and define stopping rules for healthy subjects first-entry-into-man studies. Br J Clin Pharmacol 2010 70:5 736–748 New requests by regulatory authorities after TGN 1412 tragedy – London 2006 Improve and facilitate decision making in dose escalation studies as requested by EMA guideline on Strategy to Identify Mitigate Risks for First in Human Clinical trials with Investigational Medicinal Products Using risk assessment & minimization strategy 2 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 HOW & SCOPE Needs: Standardisation of methods for an accurate and relevant grading of adverse events & clinical findings Clinically relevant & accepted «Stopping rules» • Individual level • Group/cohort level Applicable to FIH studies conducted in young male subjects • First-in-Human dose escalation studies (single & multiple dose) • Healthy subjects 3 AP 3 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 CURRENT AVAILABLE GUIDELINES Nothing relevant and accepted fitting well to healthy subject participating in FIHs WHO Recommendations for grading Acute & subacute toxic 1. effects WHO Handbook for reporting results of cancer treatment (1981) NCI Common Terminology Criteria for Adverse Events (CTCAE 2. v4 Sept 2009) (cid:31) Only applicable to oncology NIH Division of AIDS (Dec 2004) : Table for grading the 3. severity of adult and paediatric adverse events FDA Guidance for Industry (Sept 2007) : Toxicity grading scale 4. for adult and adolescent volunteers enrolled in preventive vaccine clinical trials. (cid:31) controversy in-between organizations (2005) (cid:31) not relevant enough to healthy subjects 4 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 NEED OF RELEVANT PROPOSALS CPI proposals .../... 5 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 PREAMBULE : DEFINITION & WORDING ADVERSE EVENT OR FINDING Adverse Event (ICH definition): « any untoward medical occurrence in a patient or clinical investigation subject administered a pharmaceutical product and which does not necessarily have to have a causal relationship to this treatment ». Any spontaneously reported or observed AE (cid:31) to be collected 6 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 PREAMBULE : DEFINITION & WORDING ADVERSE EVENT OR FINDING Clinical event = ADVERSE EVENT Non-clinical (vital signs, ECG, routine laboratory tests…) event = FINDING 7 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 IS THE EVENT RELATED ? Investigator judgement: « unrelated, unlikely, possible, probable, (likely) or definite » Final judgement / coding : binary process (related or not related ) Low imputability power due to small number of subjects (cid:31) Clear proof of intercurrent disease: non-related If not => related 8 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 QUOTATION? USE OF THE NIH / FDA GRADING Grading: use NIH/FDA 4-level scales of intensity: 1. Grade 1 : mild : Does not interfere with daily activity 2. Grade 2 : moderate : Interferes with daily activity; no treatment excepted acetaminophen (limited amount) 3. Grade 3 : severe : Prevents daily activity or requires treatment (or medical intervention - FDA) 4. Grade 4 : life-threatening : Emergency room visit or disabling or hospitalization 9 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011 FIRSTLY Application to clinical AEs quotation directly derived à from observed severity/intensity or from daily life consequences 10 Joint conference AGAH - BAPU - Club Phase I - AHPPI - Berlin - 31 March to 1st April 2011
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