Clinical Review for NDA 21-686

 

NDA:                           21-686

 

Sponsor:                       AstraZeneca

 

Drug name:                   Exanta (ximelagatran) Tablets

 

Indications:                  

 

1)      Prevention of venous thromboembolism (VTE; defined as deep

vein thrombosis [DVT], pulmonary embolism [PE], or both), in patients undergoing knee replacement surgery;

 

2)      Long-term secondary prevention of VTE after standard treatment for an episode of acute VTE;

 

3)      Prevention of stroke and other thromboembolic complications

associated with atrial fibrillation (AF). (see Medical Officer’s  review from the Division of Cardio-Renal Drug Products for details)

 

 

            Date submitted: December 23, 2003

 

            Date received:              December 23, 2003

 

            Review completed:       August 5, 2004

 

            Reviewer:                     Ruyi He, M.D.

 

 

 

NOTE: This is a preliminary/draft review that is not intended to provide any recommendations on the approvability of NDA 21,686.  Any opinions expressed in the review do not necessarily reflect those of the Division/Office.


 

Table of Contents

 

Table of Contents............................................................................................ 2

Executive Summary......................................................................................... 5

 

I.          Summary of Clinical Findings................................................................................ 5

A........ Brief Overview of Clinical Program................................................................ 5

B......... Efficacy......................................................................................................... 6

C........ Safety............................................................................................................ 7

D........ Dosing......................................................................................................... 11

E......... Special Populations...................................................................................... 11

Clinical Review.............................................................................................. 14

I.          Introduction and Background.............................................................................. 14

A........ Drug Established and Proposed Trade Name, Drug Class, Sponsor’s Proposed Indication(s), Dose, Regimens, Age Groups................................................................................ 14

B......... State of Armamentarium for Indication(s)..................................................... 14

C........ Important Milestones in Product Development.............................................. 15

D........ Other Relevant Information.......................................................................... 15

E......... Important Issues with Pharmacologically Related Agents............................... 15

II.        Clinically Relevant Findings From Chemistry, Animal Pharmacology and Toxicology, Microbiology, Biopharmaceutics, Statistics and/or Other Consultant Reviews 15

III.       Human Pharmacokinetics and Pharmacodynamics............................................ 16

A........ Pharmacokinetics......................................................................................... 16

B......... Pharmacodynamics...................................................................................... 17

IV.       Description of Clinical Data and Sources........................................................... 18

A........ Overall Data................................................................................................ 18

B......... Tables Listing the Clinical Trials.................................................................... 19

C........ Postmarketing Experience............................................................................ 19

D........ Literature Review........................................................................................ 20

V.        Clinical Review Methods..................................................................................... 20

A........ How the Review was Conducted................................................................. 20

B......... Overview of Materials Consulted in Review................................................. 21

C........ Overview of Methods Used to Evaluate Data Quality and Integrity............... 21

D........ Were Trials Conducted in Accordance with Accepted Ethical Standards...... 22

E......... Evaluation of Financial Disclosure................................................................. 22

VI.       Integrated Review of Efficacy............................................................................. 22

A........ Brief Statement of Conclusions..................................................................... 22

B......... General Approach to Review of the Efficacy of the Drug.............................. 23

C........ Detailed Review of Trials by Indication......................................................... 24

D........ Efficacy Conclusions.................................................................................... 24

VII.     Integrated Review of Safety................................................................................ 27

A........ Brief Statement of Conclusions..................................................................... 27

B......... Description of Patient Exposure................................................................... 31

C........ Methods and Specific Findings of Safety Review.......................................... 33

D........ Adequacy of Safety Testing......................................................................... 84

E......... Summary of Critical Safety Findings and Limitations of Data......................... 84

VIII.    Dosing, Regimen, and Administration Issues..................................................... 85

IX.       Use in Special Populations................................................................................... 85

A........ Evaluation of Sponsor’s Gender and Age Effects Analyses and Adequacy of Investigation          85

B......... Evaluation of Evidence for Race, or Ethnicity Effects on Safety or Efficacy.... 86

C........ Evaluation of Pediatric Program................................................................... 86

D........ Comments on Data Available or Needed in Other Populations...................... 87

 

Appendix A: List of abbreviations…………………………………………………….89

            Appendix B: Individual More Detailed Study review………………………...……...91

 

A.          STUDY SH-TPO-0010 (EXULT A)……………………………………....91

 

B.           STUDY SH-TPO-0012 (EXULT B)………………………………….…..115

 

C.          Study SH-TPV-0003 (THRIVE III)……………………………………142

 


 

Clinical Review for NDA 21-686





 



 

EXANTA ® (ximelagatran) is an oral anticoagulant and a prodrug of melagatran, a potent, reversible, competitive and direct inhibitor of thrombin. Ximelagatran prevents a key step in the coagulation cascade, the conversion of fibrinogen to fibrin.

 

Ximelagatran is in development for several indications, of which the following 3 are being

submitted in this application: prevention of VTE (defined as deep vein thrombosis [DVT], pulmonary embolism [PE], or both), in patients undergoing knee replacement surgery; long-term secondary prevention of VTE after standard treatment for an episode of acute VTE; and prevention of stroke and other thromboembolic complications associated with atrial fibrillation (AF). All 3 indications are for the adult population only.


 

The studies were designed to demonstrate that fixed doses of ximelagatran, without coagulation

monitoring or dosage adjustment, offers superiority to placebo (VTE Secondary Prevention),

superiority to warfarin (Knee Replacement Surgery), and non-inferiority to warfarin (Atrial

Fibrillation).

 

The development program includes 82 clinical studies with ximelagatran and/or melagatran

(60 Phase I studies and 22 Phase II and III studies), in which 30,698 subjects were randomized. A total of 17,593 randomized subjects received the oral prodrug ximelagatran, or the active drug melagatran. In the long-term treatment populations, 6931 patients received ximelagatran, 5024 of whom received treatment for at least 6 months and 3509 for at least a year in patients with atrial fibrillation (up to 2.5 years in the pivotal SPORTIF studies and up to 4 years in the ongoing SPORTIF IV study).

 

Each Phase 3 study was conducted as a multi-center, randomized, parallel-group, comparator-controlled design. All studies were double-blind except for SH-TPA-0003 (SPORTIF III for the indication of prevention of stroke in patients with AF; which was an open-label in design). All studies used a central laboratory for all protocol-specified laboratory measurements.

 

For the indication of prevention of VTE in patients undergoing elective knee replacement surgery, the sponsor conducted three Phase 3 studies in comparison with warfarin in patients undergoing primary, elective total knee replacement (TKR) surgery (SH-TPO-0006, EXULT A and EXULT B). A total of 5284 patients were randomized in these three studies (1927 to ximelagatran 36 mg bid, 2247 to warfarin, and 1110 to ximelagatran 24 mg bid).

 

To support the indication of prolonged prophylaxis of VTE after a six-month anticoagulation treatment for VTE, the sponsor provided only one 18-month study, SH-TPV-0003 (THRIVE III). A total of 1233 patients were randomized, with 914 completing the 15-month duration (475 on ximelagatran 24 mg bid and 439 on placebo) and only 193 completing the entire 18-month study (107 on ximelagatran 24 mg bid and 86 on placebo).

 

For the indication of prevention of stroke and systemic embolic events in patients with nonvalvular atrial fibrillation, Division of Cardio-Renal drug products (HFD-110) is conducting the review for both efficacy and safety.

 

 

B.        Efficacy

 

Indication 1:  prevention of VTE in patients undergoing elective total knee replacement (TKR) surgery

 

Oral ximelagatran 36 mg bid were superior to warfarin in reducing total VTE and/or all- cause mortality at end of 7-12 days therapy among patients undergoing TKR surgery in two Phase 3 studies.

 

In the pooled EXULT A and EXULT B analyses, the incidence of total VTE and/or all-cause

mortality among patients undergoing TKR was 21.7% for patients in the ximelagatran 36 mg

group and 30.2% for patients in the warfarin group (p<0.001). However, the benefit was mainly due to a reduction in asymptomatic distal DVT diagnosed by venography which is not clinically meaningful. There were no clinically or statistically significant differences between ximelagatran and warfarin groups in reducing the frequency of proximal DVT, PE, and/or all-cause mortality in this population.

 

There are several major problems with using warfarin as an active comparator in these two studies. Warfarin is not approved for this short term indication. The comparison is unfair, because warfarin will take about 3-5 days to reach therapeutic level, while Exanta reaches therapeutic levels within hours. Mean days of exposure were 8.1 days for ximelagatran and 6.7 days for warfarin in these two studies. The results show that 33.1% - 35.2% of patients receiving warfarin had an INR less than 1.8 at postoperative day 3, and 24.0 – 26.9% % of patients receiving warfarin had an INR less than 1.8 at end of treatment (day 7 – 12). Because this study is designed to show superiority of ximelagatran, efficacy results for ximelagatran in these studies may still be acceptable, since warfarin may be considered to be placebo.


 


In EXULT A ximelagatran 24 mg bid was not superior to warfarin in reducing total VTE and/or all-cause mortality (27.6% warfarin vs 24.9% ximelagatran 24 mg) at end of 7-12 days therapy.

 

Indication 2: long-term secondary prevention of VTE after standard treatment for an

                      episode of acute VTE

 

Ximelagatran significantly reduced the recurrence rate of symptomatic, objectively confirmed VTE (the primary variable of the study) as compared to placebo over 18 months of treatment (cumulative risk of 2.8% versus 12.6%; hazard ratio 0.16; p<0.0001). The number of patients with a VTE event was 12 in the ximelagatran group and 71 in the placebo group. The number of patients with a PE event was lower in the ximelagatran group compared to the placebo group (2 and 23) respectively. The results for the secondary variable, all-cause mortality, showed no significant difference between the treatment groups (1.1% vs 1.4% for patients on ximelagatran and placebo, respectively) during the 18 months.

 

C.        Safety


 

C.1. Safety of ximelagatran in patients undergoing a surgical procedure (use < 35 days)

 

A total of 1913 patients were exposed to ximelagatran 36 mg bid, 1097 patients were exposed to ximelagatran 24 mg bid, and 2226 patients were exposed to warfarin with a mean duration of exposure of 8 days for the ximelagatran groups.

 

Overall, more than 55% of patients in each treatment group experienced at least 1 adverse event (AE). Post-operative complications were mostly related to bleeding and were reported at a higher frequency in the ximelagatran groups (17% at 36 mg, 23% at 24 mg) than in the warfarin groups (15% and 20%, respectively).

 

There were 18 deaths (12 patients exposed to ximelagatran and 6 patients exposed to warfarin). Of the 12 fatal SAEs reported among the 3010 patients who received ximelagatran (0.4%), 2 were fatal bleeding events (both on ximelagatran 36 mg).  Six were fatal events in which ‘PE could not be excluded’. The last 4 fatal SAEs in patients who received ximelagatran were adjudicated as ‘death not associated with VTE or bleeding’.  The investigators reported the causes of death in 1 patient on treatment as sudden death, and in the other 3 patients after treatment as intestinal perforation, acute MI, and pneumonia. Of the 6 deaths reported among the 2226 patients who received warfarin (0.3%), 2 were fatal events in which ‘PE could not be excluded’. The causes of death in 2 patients on treatment were arrhythmia and MI and in the other 2 after treatment were colon carcinoma and AMI.

 

There were more adverse events leading to discontinuation of study drug (DAEs) in the ximelagatran 36-mg group (2.6%) than in the warfarin group (2.0%) and in the ximelagatran 24-mg group compared to warfarin group (3.1% versus 2.1%, respectively) with postoperative complication, the most common adverse event leading to study drug discontinuation.



With respect to on-treatment adjudicated events, major bleeding occurred in 0.9% of patients treated with ximelagatran 36 mg, compared to 0.5% of patients treated with warfarin. There were 2 fatal bleeding events (both on ximelagatran 36 mg).  Major/minor bleeding occurred in 5.1% of patients treated with ximelagatran 36 mg and 4.1% of patients treated with warfarin.

 

Incidences of ALAT elevation reported as AEs were higher in the 36-mg ximelagatran group (2.1%) than other groups (1.3-1.5% warfarin; 1.4% ximelagatran 24-mg). There were no hepatobiliary fatal SAEs, non-fatal SAEs or DAEs in either ximelagatran group. During the follow-up period (4-6 weeks), 8 patients in the ximelagatran group, and 1 in the warfarin group had their first ALAT elevation >3x ULN. However, patients were only followed up for 4-6 weeks post operation. Drug effects on liver toxicity beyond 4-6 weeks are unknown. It should be noted that in studies with long-term exposure to ximelagatran elevation of hepatic enzymes was typically seen between 2nd and 6th month after starting ximelagatran.

 

In both studies Exult A and Exult B, the proportion of patients with coronary artery disease adverse events (MI or ischemia/angina) was significantly higher in the ximelagatran groups than in the warfarin groups. In patients undergoing TKR surgery (Exult A and Exult B), proportion of patients with coronary artery disease adverse events was statistically significantly higher in the ximelagatran group (20/2677, 0.75%) than in the warfarin group (5/1907, 0.26%) (p=0.02800). The proportion of patients with MI was also higher in the ximelagatran group (16/2677, 0.60%) than in the warfarin group (4/1907, 0.21%) in the TKR population (p=0.04951). There were no appreciable differences between the treatment groups for underlying diseases including hypertension, hypercholesterolemia, diabetes mellitus, coronary atherosclerosis, as well as age, gender and weight. Considering ximelagatran as an anticoagulant with potential to treat MI, these results are worrisome.

 

Overall, these studies raised some safe concerns for use of oral ximelagatran 36 mg bid for 7 to 12 days after surgery (beginning the morning after surgery) in the prevention of VTE in patients undergoing elective knee replacement surgery. There is a potential risk of higher coronary artery disease adverse events including acute myocardial infarction. Potential long-term use that will cause liver toxicity is high. Also, major bleeding events were higher in patients treated with ximelagatran than in patients treated with warfarin. The long-term follow up (6 months) data may also be considered to adequately assess liver toxicity for short-term use of ximelagatran.


 

C.2. Safety of ximelagatran in patients with long-term exposure (> 35 days)

 

A total of 6931 patients received doses from 20 to 60 mg of ximelagatran, for a median of 370 days. A total of 5024 patients were exposed to ximelagatran for at least 6 months and 3509 for at least 12 months. A total of 6216 patients were exposed for a median of 455 days to warfarin (n=4967) and placebo (n=1249).

 

 

C.2.1. Death

There were 224 deaths during active treatment, 112 in the ximelagatran treatment groups and 112 in the comparator groups. A further 331 patients died after stopping study drug (166 in the ximelagatran group and 165 in the comparator group). There was no differences between the treatment groups. The most common fatal SAE was myocardial infarction.

 

C.2.2. Non-fatal SAE

A total of 26.3% of patients in the ximelagatran group and 27.1% of patients in the comparator group experienced a non-fatal SAE during treatment.  A further 5.5% of patients in the ximelagatran group and 4.3% of patients in the comparator group experienced a non-fatal SAE after stopping study drug. The most common non-fatal SAEs were cardiovascular events. The most common non-fatal SAEs considered to be causally related to ximelagatran were increases in hepatic transaminases.

 

C.2.3. Discontinuation

The proportion of patients who discontinued study drug was higher in the ximelagatran group (1189/6931, 17.2%) than in the comparator group (801/6216, 12.9%).  This was mostly due to the discontinuation of study drug due to elevated hepatic transaminases. Data from discontinuation of ximelagatran secondary to AEs indicate that “coronary artery disorders (CAD)” were more common in the ximelagatran group than in the comparator group (0.6% vs. 0.3%, respectively) whereas thromboembolic events were less common DAEs in the ximelagatran  group (0.4% vs.1.3%, respectively), because of a placebo control. Other common causes of discontinuations included bleeding events, with no difference between ximelagatran and the comparators, except for haematuria and rectal haemorrhage/ melaena, which caused slightly more discontinuations in the ximelagatran group than in the comparator groups.

 

C.2.4. Bleeding Events

In patients with atrial fibrillation (AF), ximelagatran 36 mg was associated with fewer major bleeding events than warfarin (AF pool; 2.4% and 3.4% for the ximelagatran and warfarin group, respectively, p=0.0288).  However, there were no significant differences for major bleeding events between the groups in each of the 2 pivotal studies (SH-TPA-0003 and STP-0005). In patients with acute VTE, ximelagatran 36 mg was associated with numerically fewer major bleeding events than enoxaparin/warfarin. In patients undergoing extended secondary prophylaxis for VTE, ximelagatran 24 mg was associated with a similar incidence of major bleeding events to placebo. A total of 38 patients experienced bleeding-related SAEs with a fatal outcome, 19 cases in each treatment group (ximelagatran or comparator).

 

C.2.5. Hepatobiliary Toxicity

In patients receiving long-term administration of ximelagatran (>35 days) an increase in ALAT >3xULN occurred in 6-13% (average 7.6%, 531/6948) compared to 0-2% (average 1.1%, 68/6230) of patients receiving comparator treatments. Including local laboratory data, 620 patients showed an ALAT elevation >3xULN during the studies, 546 patients in the ximelagatran group (cumulative incidence 7.8%) and 74 patients in the comparator group (cumulative incidence 1.1%).  Among the 531 patients in the ximelagatran group who presented with an ALAT >3xULN, 206 (39%) completed the study on study drug.  The remaining 325 patients (61%) discontinued study drug prematurely.

 

The time pattern of ALAT elevations was consistent across patients.  The increase typically occurred between 1 and 6 months after the initiation of ximelagatran.  Before and after this time frame the incidence of ALAT increase was similar to that in the comparator groups. Of the 531 ximelagatran-treated patients who had an ALAT elevation >3xULN recorded by the central laboratory, 502 (95%) had their ALAT return to <2xULN (235 with study drug continued). Most cases show a peak of ALAT within the first 2 to 3 months post-randomization and a decline back towards baseline within about 6 months post-randomization in patients who discontinued or in patients continued on ximelagatran.  

 

Eighteen patients who discontinued study drug with elevations of ALAT subsequently resumed treatment after ALAT had returned to the normal range. Of these 18 patients, 2 again experienced elevations of ALAT after drug was resumed.

 

An evaluation of potential risk factors for increase in ALAT indicated an increased risk in the

post acute coronary syndrome (ACS) (p=0.0009), VTE-treatment (VTE-T) populations (p=0.0003), in female patients (p=0.0002), in patients with low BMI (<27 kg/m2) (p<0.0001), and in patients receiving concomitant treatment with statins (p=0.019). Asian patients were found to have a decreased risk (p=0.0038). Although a single factor identified above may not be strong enough to eliminate the subgroup population, consideration may be given to contraindicating ximelagatran in patients who have 2 or more risk factors, such as, female patients with low body weight or who are taking a statin.

 

ALAT >3xULN was associated with bilirubin >2xULN (within one month following the rise in

ALAT) in 0.53% (37/6948) of all patients who were exposed to ximelagatran >35 days as compared to 0.08% (5/6230) of patients exposed to comparators. Concomitant elevations of ALAT >3xULN and bilirubin >2xULN were observed during the first month of ximelagatran therapy in 6 of 37 patients. Nine ximelagatran-treated patients (24.3%, 9/37) died with concomitant ALAT >3xULN and bilirubin >2xULN. Among these, 3 died from heart failure; 3 died from carcinomas with hepatic metastases; 2 (ID# 7259, and 7859) died from GI bleeding with coagulopathy (1 with biopsy documented hepatic necrosis) and 1 (ID# 5442) died from hepatitis B. Liver failure/toxicity by ximelagatran might have caused or at least contributed to these deaths. Only one autopsy was done in these 9 deaths and it showed a small, friable and diffusely mottled liver suggestive of severe diffuse hepatic necrosis.

 

C.2.6. Adverse Events of Coronary Artery Disease

In all study populations except the post acute coronary syndrome, the proportion of patients with coronary artery disease adverse events was higher in the ximelagatran groups than in the comparator groups (7.0% and 6.7% for the AF pool, 1.3% and 0.1% for the VTE-treatment (VTE-T) pool and 2.6% and 2.0% for the VTE-prevention (VTE-P) pool, for the ximelagatran and comparator groups, respectively).  This trend was consistent across the pools for myocardial infarction.

 

The proportion of patients with coronary artery disease adverse events was statistically significantly higher in the ximelagatran group (32/1848, 1.7%) than in the warfarin/placebo group (12/1859, 0.7%) in the VTE (VTE-T + VTE-P) population (p=0.00411). The proportion of patients with MI was also significantly higher in the ximelagatran group (13/1848, 0.7%) than in the warfarin/placebo group (3/1859, 0.16%) in the VTE population (p=0.01183). There were no appreciable differences between the treatment groups for underline diseases including hypertension, diabetes mellitus, hypercholesterolemia, coronary atherosclerosis, as well as age, gender and weight. Considering ximelagatran as an anticoagulant with potential to treat MI, these results are worrisome.

 

D.        Dosing


 

For the indication of prevention of VTE in patients undergoing elective knee replacement surgery, the proposed dose is oral ximelagatran 36 mg bid for up to 12 days. For the indication of prolonged prophylaxis VTE after a six-month anticoagulation treatment for VTE, the proposed dose is oral ximelagatran 24 mg bid.

 

In term of hepatobiliary toxicity, there was not a marked dose response over the dose range 24 mg to 60 mg ximelagatran, but there was a noticeably lower incidence of elevation of liver transaminases at the 24 mg dose compared to the higher doses.


 

E.         Special Populations

 

For short-term use (< 35 days)

For the indication of prevention of VTE in patients undergoing elective knee replacement surgery, the majority of the patients were female (61.5%); most were Caucasian (95.1%); and most were greater than 64 years of age (65.6%). The mean age was approximately 67 years, but ranged from 26 years to 91 years.  Almost half the patients had a body mass index >30 kg/m2, which is typical for TKR surgery patients but higher than the general population.

 

The incidence of VTE and/or all-cause mortality was significantly higher in female and older patients. Results for these subgroups are summarized in the following Table:

 

Table 1: Incidence of total VTE and/or all-cause mortality for selected subgroups (efficacy ITT population) – Pooled 36 mg bid

 


The subgroup factors that had no significant impact on the incidence of total VTE and/or all-cause mortality were: race, body mass index, estimated CrCL, general anaesthesia (yes/no), time to first dose, and time to ambulation.

 

For long-term use (> 35 days)

For the indication of prolonged prophylaxis of VTE after a six-month anticoagulation treatment for an episode of acute VTE, the majority of the patients were male (54%), Caucasian (93%), and less than 60 years of age (52%). The mean age was approximately 57 years, but ranged from 18 years to 90 years.  Subgroup factors that had no significant impact on the VTE events were: sex, age, race, body mass index, estimated CrCL, initial proximal/or distal DVT (yes/no), previous VTE events (yes/no).

 

An evaluation of potential risk factors for increase in ALAT indicated an increased risk in the

Post ACS (p=0.0009), and VTE-T (p=0.0003) populations and also in female patients (p=0.0002), patients with low BMI (<27 kg/m2) (p<0.0001) and patients receiving concomitant treatment with statins (p=0.019); Asian patients were found to have a decreased risk (p=0.0038). Although single factor identified above may not be strong enough to eliminate the subgroup population, consideration may be given to contraindicating ximelagatran in patients who have 2 or more factors, such as, female patients with low body weight or who are taking a statin.

 


All three indications are for the adult population only. AstraZeneca requests a waiver for pediatric studies for the indications claimed in this application. It is unlikely that a substantial number of pediatric patients will be treated with EXANTA for the claimed indications. The estimated number of pediatric patients diagnosed with atrial fibrillation in the US in 2002 is less than 1,500 children. The estimated total number of pediatric patients treated for VTE (of which prevention of recurrent events, the indication claimed in this application, is a subset of patients) in the US in 2002 is less than 3,000 children. The estimated cumulative number of pediatric patients diagnosed with conditions for which EXANTA will be indicated is less than 5,000 children. Thus, the number of pediatric patients likely to be treated with EXANTA for the claimed indications is well below the number defined as a substantial number in the Pediatric Final Rule. Therefore, I recommend that the sponsor’s requests for waiver of the requirements to conduct pediatric studies be granted for the indications claimed in this application.

 

Subjects with renal impairment

Melagatran, the active metabolite of ximelagatran, is eliminated primarily via renal excretion.  Renal function decreases with age and the target patient population for ximelagatran is of older age (median age about 65 years). As expected, subjects with severe renal impairment had higher plasma concentrations of melagatran. The mean (SD) half-lives of melagatran were 6.8 (2.0) h and 9.3 (3.5) h after subcutaneous injection melagatran and oral ximelagatran dosing, respectively, in the subjects with renal impairment.  These half-lives were about 3-fold higher than for control subjects with normal renal function. Therefore, usage of ximelagatran in patients with severe (CrCL < 30mL/min) renal impairment is not recommended. A dosing reduction should be considered for the patients who have moderate renal impairment (CrCL < 80mL/min).

 

Subjects with hepatic impairment

The absorption of ximelagatran and the metabolic biotransformation to its active form, melagatran, are not influenced for subjects with mild and moderate hepatic impairment. However, patients who have abnormal liver function or history of liver diseases have been excluded from the studies. Due to high risk of liver toxicity, the use of ximelagatran in patients with hepatic disease and/or ALT > 2 times the upper limit of normal at the start of therapy is contraindicated.



 

EXANTA ® (ximelagatran) is an oral anticoagulant and a prodrug of melagatran, a potent, reversible, competitive and direct inhibitor of thrombin.

 

Ximelagatran is in development for several indications, of which the following 3 are being

submitted in this application: prevention of VTE (defined as deep vein thrombosis [DVT], pulmonary embolism [PE], or both) in patients undergoing knee replacement surgery; long-term secondary prevention of VTE after standard treatment for an episode of acute VTE; and prevention of stroke and other thromboembolic complications associated with atrial fibrillation (AF). All 3 indications are for the adult population only.

 

For the indication of prevention of VTE in patients undergoing knee replacement surgery, the proposed dosing is EXANTA 36 mg twice-daily for a treatment period of 7 to 12 days.

Provided hemostasis has been established, the first dose should be given the morning after surgery, but no sooner than 12 hours from the time of surgery. For the indication of long-term secondary prevention of VTE, it is proposed that patients who have received standard anticoagulant treatment for DVT or PE be treated with EXANTA 24 mg twice-daily. For the indication in patients with atrial fibrillation, please see Medical Officer’s review from the Division of Cardio-Renal Drug Products for details. No dosage adjustment is necessary with EXANTA in patients with a creatinine clearance (CrCL)  >30 mL/min. Usage of EXANTA in patients with severe renal impairment (CrCL <30 mL/min) is not recommended. The use of EXANTA in patients with hepatic disease and/or ALT >2 times the upper limit of normal at the start of therapy is contraindicated.

 

 

B.        State of Armamentarium for Indication(s)


 

Warfarin is approved for:

·        the prophylaxis and/or treatment of venous thrombosis and its extension, and PE;

·        the prophylaxis and/or treatment of the thromboembolic complications associated with atrial fibrillation and/or cardiac valve replacement;

·        reducing the risk of death, recurrent MI, and thromboembolic events such as stroke or systemic embolization after MI.

 

The “Dosage and Administration” section of warfarin labeling refers to “longer term therapy” for indications such as VTE, in patients with A-Fib or mechanical and bioprosthetic heart valves. It also states that the duration of therapy in each patient should be individualized and anticoagulant therapy should be continued until the danger of thrombosis and embolism has passed. Thus, the indications and dosing recommendations for warfarin are sufficiently broad to encompass extended prophylaxis of DVT.


 

Lovenox (enoxaparin sodium), a low molecular weight heparin, is approved for the indication of the prophylaxis of DVT in patients undergoing knee replacement surgery. Arixtra (fondaparinux sodium) injection, a synthetic inhibitor of activated Factor X (Xa), is approved for the indication of the prophylaxis of DVT in patients undergoing hip or knee replacement surgery.

 

 

C.        Important Milestones in Product Development

 




 

A Marketing Authorization Application (MAA) was submitted to the European Union (EU) in

June 2002 and approved by France in December 2003 for the prevention of VTE in patients undergoing hip or knee replacement surgery. National Marketing Authorizations for additional 14 countries in EU are issued in June 2004. UK and Ireland have been withdrawn from the Mutual Recognition Procedure. However, approved dose in EU is 24 mg twice a day, instead of 36 mg twice a day proposed in this submission.




 

EXANTA ® (ximelagatran) is the first oral direct inhibitor of thrombin. Iprivask (desirudin for injection) is an iv inhibitor of thrombin that was approved for the indication of the prevention of VTE in patients undergoing hip (not knee) replacement surgery.



 

The prodrug ximelagatran is a poor inhibitor of thrombin, while the active metabolite, melagatran, is a potent, rapid and reversible direct thrombin inhibitor. Melagatran prolongs coagulation times in all species studied and inhibits the thrombin-induced aggregation of human, dog and rat platelets. In plasma coagulation assays such as Activated Partial Thromboplastin Time (APTT) and Prothrombin Time (PT) there is a variation in the response to fixed melagatran plasma concentrations between available various test kits for each assay. Thrombin Time (TT) and Ecarin Clotting Time (ECT) are assays that have been used in order to characterize synthetic or recombinant direct thrombin inhibitors, such as melagatran and hirudin.

 

In the Safety Pharmacology study investigating intestinal motility in rats, the highest dose, 200 mmol/kg (95 mg/kg), of ximelagatran, inhibited intestinal motility. Oral, but not subcutaneous, administration of melagatran inhibited gastrointestinal motility at doses above 10 mmol/kg (4.3 mg/kg). Based on the equal exposure to melagatran after sc and oral administration it was concluded that the effect is elicited from the mucosal side of the gastrointestinal tract. High doses of melagatran given iv to dogs induced vasodilatation and increased vascular permeability, which was explained by histamine release. No liver toxicity or cardiac toxicity were reported from pre-clinical toxicology studies.

 

 

III.           Human Pharmacokinetics and Pharmacodynamics

 

According to the sponsor’s report, ximelagatran has following PK/PD profiles.

 

A.        Pharmacokinetics


 

After oral administration to healthy subjects, the absorption of ximelagatran and the bioconversion to melagatran is rapid. The bioavailability of melagatran after oral dosing with ximelagatran to healthy subjects is about 20%, with low inter- and intra-individual variability. Melagatran is mainly excreted unchanged in urine with a renal clearance that corresponds to the glomerular filtration rate. The half-life of melagatran is about 3 hours after oral dosing with ximelagatran to young healthy subjects.

 

The pharmacokinetics of melagatran, following oral administration of ximelagatran and parenteral administration of melagatran to healthy subjects, are dose proportional, i.e., the exposure of melagatran increases linearly in proportion to the given dose (15 to 60 mg). No time-dependent changes in the pharmacokinetics of melagatran are observed during repeated oral dosing with ximelagatran to healthy subjects. The interindividual variability in melagatran exposure is low (coefficient of variation (CV) ~20%) and the intraindividual variability is even lower (CV ~10%).

 

The pharmacokinetics of melagatran, following oral administration of ximelagatran and parenteral administration of melagatran, are consistent across the different patient populations studied, and in agreement with pharmacokinetic properties observed in healthy subjects. After oral administration of ximelagatran, the half-life of melagatran is about 4 to 5 hours in the patient populations studied, which is longer than in young healthy subjects. This appears to a large extent to be due to the age-related lower renal function in patients.

 

The interindividual variability of melagatran exposure is higher for patients (CV ~50%) than for healthy volunteers, which to a large extent appears to be due to the interindividual variability in renal function. No time-dependent changes in the pharmacokinetics of melagatran are observed for patients receiving long-term oral treatment with ximelagatran. The intraindividual variability of melagatran exposure is low (CV ~25%), suggesting that the pharmacokinetics of melagatran are predictable and reproducible.

 

Race has no influence on the absorption and metabolism of ximelagatran. Compared to patients with normal renal function (CrCL >80 mL/min), the melagatran exposure was about 1.5 and 2.5 times higher for patients with mild renal impairment (CrCL 50 to 80 mL/min) and moderate renal impairment (CrCL 30 to <50 mL/min), respectively.

 

After oral administration of ximelagatran to patients with severe renal impairment (CrCL 10 to 30 mL/min), the melagatran exposure was 5 times higher than for control subjects with normal renal function. Compared with the average for the studied patient populations, melagatran exposure is increased about 3-fold and the half-life is increased about 2-fold in patients with severe renal impairment. For patients with end-stage renal disease requiring dialysis, the clearance of melagatran is low and comparable to the non-renal clearance in healthy subjects. Melagatran clearance is increased during dialysis, suggesting that dialysis is effective in accelerating the elimination of melagatran. Mild to moderate liver impairment has no influence on the absorption or metabolism of ximelagatran. Gender, age, body weight and obesity have no influence on the absorption and metabolism of ximelagatran. The influence of these intrinsic factors on the elimination of melagatran appears to a large extent to be related to differences in renal function.

 

The extent of absorption and conversion of ximelagatran is not affected by food. Oral

administration of ximelagatran with food causes a 1-hour delay of the tmax of melagatran but the AUC and Cmax of melagatran are unaffected. The pharmacokinetics of ximelagatran is not influenced by concomitant intake of alcohol. In vivo drug interaction studies with drugs that are substrates of CYP3A4 (nifedipine, atorvastatin, amiodarone, diazepam), CYP2C9 (diclofenac) and CYP2C19 (diazepam) showed no interaction and confirmed that ximelagatran has a low potential for drug interactions mediated by cytochrome P450 metabolism. Upon co-administration of ximelagatran and erythromycin to healthy subjects, the bioavailability of melagatran increased by approximately 80%. Erythromycin is known to interact with many drugs, as it is metabolized by and inhibits CYP3A4. However, this isoenzyme is not judged to be the site of the interaction as in vitro studies with ximelagatran and melagatran have shown that they are not substrates of CYP3A4. Concomitant chronic treatments had no significant influence on the pharmacokinetics of melagatran for any of drugs or drug classes evaluated in the studied patient populations.

 

B.        Pharmacodynamics

 


Statistically significant concentration-response relationships were detected between melagatran plasma concentrations and inhibition of thrombin generation, platelet activation and thrombus formation. Oral administration of ximelagatran results in a predictable and rapid onset of action as indicated by statistically significant inhibition of thrombin generation, platelet activation and thrombus formation measured at 2 hours post-dosing.

 

Melagatran induces a relatively small prolongation of the Capillary bleeding time (CBT) (up to 35%) following doses of 24 to 72 mg oral ximelagatran. These prolongations were additive with

therapeutic doses of ASA and diclofenac (up to 43% prolongation in combination) but synergistic with a therapeutic dose of clopidogrel (98% prolongation in combination).

 

Oral ximelagatran prolongs to varying degrees and with varying sensitivity conventional coagulation-time assays such as the activated partial thromboplastin time (APTT), activated clotting time (ACT), thrombin time (TT) and prothrombin time/international normalized ratio (PT/INR). The coagulation time assay prolongations occur in a concentration-dependent and non-linear (APTT, ACT, PT/INR) or linear (TT) manner. The APTT, ACT, and PT/INR

assays are rather insensitive and show variable responses to melagatran concentrations

whereas the TT is very sensitive to melagatran plasma concentrations. The ecarin clotting time (ECT), an experimental assay that is not widely available, was prolonged by melagatran in a concentration-dependent and linear manner. Oral dosing with ximelagatran results in a predictable and rapid onset of anticoagulation. The APTT is prolonged within 20 minutes of dosing with oral ximelagatran and peak prolongations are observed 2 hours postdosing. Melagatran-induced prolongation of the APTT is largely independent of the intrinsic (age, renal impairment, mild to moderate hepatic impairment, obesity, ethnicity, and disease) and extrinsic (food, alcohol, ASA, diclofenac, clopidogrel, amiodarone, atorvastatin, erythromycin, digoxin) factors studied.

 

The offset of action of 24 or 36 mg ximelagatran is rapid, with low but pharmacologically active concentrations of melagatran remaining for approximately 12 to 24 hours following the last dose.

There are no currently available haemostatic agents that have been demonstrated to have clinical value in reversing the anticoagulant effects of ximelagatran.

 



The development program for ximelagatran has been designed to offer an oral alternative

anticoagulant to warfarin for major indications. Ximelagatran has been evaluated in various

patient populations in large controlled, worldwide, clinical studies.

 

The development program includes 82 clinical studies with ximelagatran and/or melagatran

(60 Phase 1 studies and 22 Phase 2 and 3 studies), in which 30698 subjects were randomized. A total of 17593 randomized subjects received the oral prodrug ximelagatran, or the active drug melagatran. In the long-term treatment populations, 6931 patients received ximelagatran, 5024 of whom received treatment for at least 6 months and 3509 for at least a year (up to 2.5 years in the pivotal SPORTIF studies and up to 4 years in the ongoing SPORTIF IV study).

 

The design of the clinical studies has varied between indications but some important features

are common to most of them, as described below:

 

Overall design: Each Phase 3 study was conducted as a multi-center, randomized, parallel-group, comparator-controlled design. All studies were double-blind except for SH-TPA-0003

(SPORTIF III; which was open-label in design). All studies used a central laboratory for all

protocol-specified laboratory measurements.

 

Control groups and randomization: Each Phase 3 study included a control group and treatment allocation randomized by a central randomization service (interactive voice response system [IVRS]) to reduce bias.

 

Independent adjudication of clinical endpoint events: In each pivotal study, the endpoint events (efficacy, all-cause mortality, and bleeding events) were identified and assessed by the investigator but the primary efficacy evaluation was based on endpoint events confirmed by an independent expert adjudication committee who were blinded to the treatment taken by the patient.

 

Independent committees: In addition to the independent committee adjudicating the endpoint

events, each study incorporated an Independent Drug Safety Monitoring Board (DSMB;

responsible for reviewing safety during the conduct of the study), and an Independent Executive Committee (EC; responsible for oversight of the conduct and reporting of the study).





 

C.        Postmarketing Experience

 

There are no postmarketing data available as of July 2004.




The reviewer has searched the literatures related to ximelagatran up to July 2004 and incorporated them into the review.


 

 

V.      Clinical Review Methods

 

A.        How the Review was Conducted

 


The efficacy evaluation of the indication for prevention of VTE in patients undergoing knee replacement surgery is based on 2 clinical trials conducted by the sponsor (EXULT A and EXULT B). The sponsor conducted 3 multi-center, double-blind, parallel-group, Phase 3 studies in patients undergoing primary, elective TKR surgery (SH-TPO-0006, EXULT A and EXULT B). A total of 5284 patients were randomized in these 3 studies (1927 to ximelagatran 36 mg bid, 2247 to warfarin, and 1110 to ximelagatran 24 mg bid). All 3 studies evaluated ximelagatran administered postoperatively (beginning the morning after surgery) for 7 to 12 days compared to warfarin titrated to an INR of 2.5 (INR range 1.8 to 3.0) that was initiated the evening of the day of surgery.

 

Ximelagatran 36 mg bid was used in both studies EXULT A and EXULT B and ximelagatran 24 mg bid only was used in study SH-TPO-0006. The sponsor proposed 36 mg bid for this indication. Therefore, in this review, I mainly examine studies EXULT A and EXULT B for the efficacy evaluation of indication for prevention of VTE in patients undergoing knee replacement surgery.

 

For the indication of prolonged prophylaxis of VTE after a six-month anticoagulation treatment, the sponsor provided only one study, SH-TPV-0003 (THRIVE III). This was a multi-center, double-blind, parallel-group, placebo control study. Ximelagatran 24 mg bid or placebo were given as prolonged prophylaxis after a 6-month anticoagulation treatment for VTE. A total of 1233 patients were randomized, with 903 completing the study on the study drug (468 on ximelagatran 24 mg bid and 435 on placebo).


 

The medical officers from the Division of Cardio-Renal Drug Products will conduct the review for the indication of prophylaxis of stroke in patients with atrial fibrillation.

 

The safety evaluation included assessment of the data from all clinical studies which were divided into short term use (<35 days) and long-term use (> 35 days). There is no post-marketing safety data available.

 

Data from 10 Phase 2 and Phase 3 studies are presented in 4 pools based on the indication that was investigated. These indications were AF, VTE treatment (VTE-T), VTE secondary prevention (VTE-P) and post ACS. A fifth pool, the long-term exposure (LTE) pool, combines data from all of these indications.

 

The long-term (>35 days) safety of ximelagatran has been studied in a large population of 6931 patients comprising 3838 patients with atrial fibrillation (AF), 1236 patients for treatment (VTE-T), 612 patients for secondary prevention (VTE-P) of VTE and 1245 patients with recent acute coronary syndrome (post ACS). These 6931 patients received doses from 20 to 60 mg, for a median of 370 days, representing an overall exposure of 6768 patient-years. A total of 5024 patients were exposed to ximelagatran for at least 6 months (>180 days) and 3509 for at least 12 months (>360 days). All the studies were controlled, thus enabling comparison with a cohort of 6216 patients exposed for a median of 455 days mainly to the reference anticoagulant warfarin (n=4967), but also to placebo in a smaller number of patients (n=1249).

 

 

B.        Overview of Materials Consulted in Review


 

In this review, I have examined material in following sections: Cover letter, Labeling, Summaries, and clinical study reports, including data listings and case report forms (CRF).



 

The Division of Scientific Investigations has been consulted to conduct inspection for the following sites:

 



 

The sponsor has submitted informed consent with each clinical trial protocol. According to the sponsor, the protocol and all amendments for this study were reviewed by an Independent Ethics Committee (IEC), and monitoring and audit procedures performed prior to, during, and upon completion of this study have verified that this study was conducted in accordance with the ethical principles.



 

The sponsor submitted a FDA Form 3454 certifying that no investigator of any of the covered clinical studies had any financial interests to disclose.



 

Indication 1:  prevention of VTE in patients undergoing elective knee replacement surgery

 

Oral ximelagatran 36 mg bid was superior to warfarin in reducing total VTE and/or all- cause mortality among patients undergoing TKR surgery in 2 large Phase III studies.

 

In the pooled EXULT A and EXULT B analyses, the incidence of total VTE and/or all-cause

mortality among patients undergoing TKR was 21.7% for patients in the ximelagatran 36 mg

group and 30.2% for patients in the warfarin group, for an absolute risk reduction (ARR) of 8.6% (p<0.001). The ARR of 8.6% provided an number needed to treat (NNT, 1/ARR) of 12 (95% CI: 9 to 18).

 

The benefit was mainly due to a reduction in asymptomatic distal DVT diagnosed by venography which is not clinically meaningful. There were no clinically or statistically significant differences between ximelagatran and warfarin in reducing the frequency of proximal DVT, PE, and/or all-cause mortality in this population.

 

There are several major problems for comparison with warfarin as an active comparator in these two studies. Warfarin is not approved for the indication of prevention of DVT in patients undergoing elective knee replacement surgery. The comparison is unfair, because warfarin will take about 3-5 days to reach therapeutic level, while Exanta reaches therapeutic levels within hours. The results show that 33.1% - 35.2% of patients receiving warfarin had an INR less than 1.8 at postoperative day 3, and 24 – 26.9% % of patients receiving warfarin had an INR less than 1.8 at end of treatment (day 7 – 12). Because the study is designed to show superiority of ximelagatran, efficacy results for ximelagatran in these studies are still acceptable, considering warfarin group as placebo.


 

Indication 2: Prolonged prophylaxis VTE after a six-month anticoagulation treatment for a acute episode of VTE

 

Ximelagatran significantly reduced the recurrence rate of symptomatic, objectively confirmed VTE (the primary variable of the study) as compared to placebo over 18 months of treatment (cumulative risk of 2.8% versus 12.6%; hazard ratio 0.16; p<0.0001). The number of patients with a VTE event was 12 in the ximelagatran group and 71 in the placebo group. The number of patients with a PE event was lower in the ximelagatran group compared to the placebo group (2 and 23 in ximelagatran and placebo group respectively).

 

The results for the secondary variable, all-cause mortality, showed no significant difference between the treatment groups (1.1% vs 1.4% for patients on ximelagatran and placebo, respectively) during the 18 months.

 

B.        General Approach to Review of the Efficacy of the Drug


 

The efficacy evaluation of indication for prevention of VTE in patients undergoing knee

replacement surgery is based on 2 clinical trials conducted by the sponsor (EXULT A and EXULT B).

 

For the indication of prolonged prophylaxis VTE after a six-month anticoagulation treatment, the sponsor provided only one study, SH-TPV-0003 (THRIVE III). This was a multi-center, double-blind, parallel-group, placebo control study and this study was reviewed in detail.


 

The medical officers from the Division of Cardio-renal Drug Products will conduct the review for the indication of prophylaxis of stroke in patients with atrial fibrillation. Therefore, for the efficacy evaluation regarding the indication of prophylaxis of stroke in patients with atrial fibrillation, please see Dr. Desai’s Meidcal Officer Review on this submission.



 

Indication 1:  prevention of VTE in patients undergoing elective knee replacement surgery

 

The sponsor conducted 3 multi-center, double-blind, parallel-group, Phase 3 studies in patients undergoing primary, elective TKR surgery (EXULT A, EXULT B and SH-TPO-0006). A total of 5284 patients were randomized in these 3 studies (1927 to ximelagatran 36 mg bid, 2247 to well-controlled warfarin, and 1110 to ximelagatran 24 mg bid). All 3 studies evaluated ximelagatran administered postoperatively (beginning the morning after surgery) for 7 to 12 days compared to warfarin titrated to an INR of 2.5 (INR range 1.8 to 3.0) that was initiated the evening of the day of surgery.

 

Ximelagatran 36 mg bid was used in both studies EXULT A and EXULT B and ximelagatran 24 mg bid was used in study SH-TPO-0006. The sponsor proposed 36 mg bid for this indication. Therefore, in this review, I mainly examine studies EXULT A and EXULT B. Please see Appendix B for detailed review of the trials.

 

Indication 2: Prolonged prophylaxis VTE after a six-month anticoagulation treatment for

                       an acute episode of VTE

 

The sponsor provided only one study, SH-TPV-0003 (THRIVE III) to support this indication. This was a multicentre, double-blind, parallel-group, placebo control study. Ximelagatran 24 mg bid or placebo were given as prolonged prophylaxis after a 6-month anticoagulation treatment for VTE. A total of 1233 patients were randomized, with 903 completing the study on the study drug (468 on ximelagatran 24 mg bid and 435 on placebo). Please see Appendix B for detailed review of the trial.

 

Indication 3: prevention of strokes and systemic embolic event in patients with nonvalvular atrial fibrillation

 

Division of Cardio-Renal Drug Products (HFD-110) was consulted to review this indication. Please see medical officer’s review from HFD-110 for details.

 

 

D.        Efficacy Conclusions

 


Indication 1:  prevention of VTE in patients undergoing elective knee replacement surgery


 

Oral ximelagatran 36 mg bid was superior to warfarin in reducing total VTE and/or all- cause mortality among patients undergoing TKR surgery in 2 large Phase 3 studies. Table 3 summarizes primary endpoints- incidence of total VTE and/or all-cause mortality (efficacy ITT population) from both studies EXULT A and EXULT B, and Pooled 36 mg bid.

 

Table 3: Incidence of total VTE and/or all-cause mortality (efficacy ITT population) – EXULT A, EXULT B, and Pooled 36 mg bid

 


In EXULT A, the incidence of total VTE and/or all-cause mortality among patients undergoing TKR was 20.3% for patients in the ximelagatran 36 mg group and 27.6% for patients in the warfarin group, for an absolute risk reduction (ARR) of 7.3% (p=0.003). The ARR of 7.3% provided a relative risk reduction (RRR) of 26.5% and a number needed to treat (NNT=1/ARR) of 14 (95% CI: 8 to 40).

 

EXULT B replicated the superior efficacy of ximelagatran 36 mg bid versus warfarin group demonstrated in EXULT A. In EXULT B, the incidence of total VTE and/or all-cause mortality among patients undergoing TKR was 22.5% for patients in the ximelagatran 36-mg group and 31.9% for patients in the warfarin group, for an ARR of 9.3%. (p<0.001). The ARR of 9.3% provided an RRR of 29.5% and an NNT (1/ARR) of 11 (95% CI: 8 to 19).

 

In the pooled EXULT A and EXULT B analyses, the incidence of total VTE and/or all-cause

mortality among patients undergoing TKR was 21.7% for patients in the ximelagatran 36 mg

group and 30.2% for patients in the warfarin group, for an ARR of 8.6% (p<0.001). The ARR

of 8.6% provided an RRR of 28.1% and an NNT (1/ARR) of 12 (95% CI: 9 to 18).

 

However, the benefit was mainly due to a reduction in asymptomatic distal DVT diagnosed by venography which is not clinically meaningful (Table 4). There were no clinically or statistically significant differences between ximelagatran and warfarin in reducing the frequency of proximal DVT, PE, and/or all-cause mortality in this population.

 

Table 4: Objectively confirmed symptomatic and asymptomatic VTE over the entire study (efficacy ITT population) – EXULT A and B 36 mg bid

 


In EXULT A, the incidence of proximal DVT, PE, and/or all-cause mortality among patients undergoing TKR was 2.7% for patients randomized to ximelagatran 36 mg and 4.1% for patients randomized to warfarin (1.4% reduction; p=0.171). In EXULT B, the incidence of proximal DVT, PE, and/or all-cause mortality among patients undergoing TKR was 3.9% for patients randomized to ximelagatran 36 mg and 4.1% for patients randomized to warfarin (0.3% reduction; p=0.802).

 

Approximately 95% of patients in each treatment group had unilateral surgery performed and, therefore, the reductions in total VTE and/or all-cause mortality for the combined surgeries approximated the reduction for patients with unilateral surgery.

 

In both studies, a higher frequency of total VTE and/or all-cause mortality was observed across both treatment groups for female patients (relative to males), older patients (relative to younger patients), patients enrolled at sites in Canada (relative to those in the United States and the rest of the world).

 

In EXULT A ximelagatran 24 mg bid was not superior to warfarin  in reducing the rate of total VTE and/or all-cause mortality (27.6% warfarin vs 24.9% ximelagatran 24 mg).

 

There are several major problems for comparison of ximelagatran with warfarin in these two studies. Warfarin is not approved for this short-term indication. The comparison is unfair, because warfarin will take about 3-5 days to reach therapeutic level, while Exanta reaches therapeutic levels within hours. The results show that 33.1% - 35.2% of patients receiving warfarin had an INR less than 1.8 by postoperative day 3, and 24 – 26.9% % of patients receiving warfarin had an INR less than 1.8 by end of treatment (day 7 – 12).

 

 

Indication 2: Prolonged VTE prophylaxis after a six-month anticoagulation treatment for an acute episode of VTE

 

Ximelagatran significantly reduced the recurrence rate of symptomatic, objectively confirmed VTE as compared to placebo over 18 months of treatment (cumulative risk of 2.8% versus 12.6%; hazard ratio 0.16; p<0.0001). The number of patients with a VTE event was 12 in the ximelagatran group and 71 in the placebo group. The number of patients with a PE event was lower in the ximelagatran group compared to the placebo group (2 and 23 in ximelagatran and placebo group respectively (Table 5).

 

Table 5: The number of patients with VTE events in ximelagatran and placebo groups


 

The results for the secondary variable, all-cause mortality, showed no significant difference between the treatment groups (1.1% vs 1.4% for patients on ximelagatran and placebo, respectively) during the 18 months.

 

 

VII.   Integrated Review of Safety

 

A.        Brief Statement of Conclusions

 

A1. Safety of Ximelagatran in Patients Undergoing a Surgical Procedure (use <35 days)

 

A total of 1913 patients undergoing keen surgery were exposed to ximelagatran 36 mg bid, 1097 patients were exposed to ximelagatran 24 mg bid, and 2226 patients were exposed to warfarin with a mean duration of exposure of 8 days for the ximelagatran groups.

 

Overall, more than 55% of patients in each treatment group experienced at least 1 adverse event (AE). The frequency of AEs was similar between the treatment groups. Post-operative complications were mostly related to bleeding and were reported at a higher frequency in the ximelagatran groups (17% at 36 mg, 23% at 24 mg) than in the warfarin groups (15% and 20%, respectively).

 

There were 18 deaths (12 patients exposed to ximelagatran and 6 patients exposed to warfarin). Of the 12 fatal SAEs reported among the 3010 patients who received ximelagatran (0.4%), 2 were fatal bleeding events (both on ximelagatran 36 mg).  Six were fatal events in which ‘PE could not be excluded’. The last 4 fatal SAEs in patients who received ximelagatran were adjudicated as ‘death not associated with VTE or bleeding’.  The investigators reported the causes of death in 1 patient on treatment as sudden death, and in the other 3 patients after treatment as intestinal perforation, acute MI, and pneumonia. Of the 6 deaths reported among the 2226 patients who received warfarin (0.3%), 2 were fatal events in which ‘PE could not be excluded’. The causes of death in 2 patients on treatment were arrhythmia and MI and in the other 2 after treatment were colon carcinoma and AMI. None of the on-treatment major bleeding events in the ximelagatran 24 mg group or warfarin group was fatal.

 

Adverse events leading to discontinuation of study drug (DAEs) were higher in the ximelagatran 36 mg group (2.6%) than in the warfarin group (2.0%) as well as in the ximelagatran 24 mg group compared to warfarin (3.1% versus 2.1%, respectively) with postoperative complication the most common reason for a DAE.


 

With respect to on-treatment adjudicated events, major bleeding occurred in 0.9% of patients treated with ximelagatran 36 mg, compared with 0.5% of patients treated with warfarin. Major/minor bleeding occurred in 5.1% of patients treated with ximelagatran 36 mg and 4.1% of patients treated with warfarin. Similar results were observed for ximelagatran 24 mg bid compared with warfarin.

 

Incidences of ALAT elevation reported as AEs were higher in the 36 mg ximelagatran group (2.1%) than other groups (1.3-1.5% warfarin; 1.4% ximelagatran 24 mg). There were no hepatobiliary fatal SAEs, non-fatal SAEs or DAEs in either ximelagatran group. During the follow-up period (4-6 weeks), 8 patients in the ximelagatran group, and 1 in the warfarin group had their first ALAT elevation >3x ULN. However, patients were followed up only for 4-6 weeks post operation. Drug effects on liver toxicity beyond 4-6 weeks are unknown. It should be noted that elevation of hepatic enzymes was typically seen between 2nd and 6th month after starting ximelagatran.

 

In both Exult A and Exult B, the proportion of patients with coronary artery disease adverse events (MI or ischemia/angina) was higher in the ximelagatran groups than in the warfarin groups. The proportion of patients with coronary artery disease adverse events was statistically significantly higher in the ximelagatran group (20/2677, 0.75%) than in the warfarin group (5/1907, 0.26%) in the TKR population (Exult A and Exult B) (p=0.02800). The proportion of patients with MI was also higher in the ximelagatran group (16/2677, 0.60%) than in the warfarin group (4/1907, 0.21%) in the TKR population (p=0.04951). There were no appreciable differences between the treatment groups for underlying diseases which include hypertension, hypercholesterolemia, diabetes mellitus, coronary atherosclerosis, as well as age, gender and weight. Considering ximelagatran as an anticoagulant with potential to treat MI, these results are worrisome.

 

 

A2. Clinical Safety of Ximelagatran in Patients with long-term exposure (> 35 days)

 

A total of 6931 patients received doses from 20 to 60 mg of ximelagatran for > 35 days, with a median of 370 days. A total of 5024 patients were exposed to ximelagatran for at least 6 months and 3509 for at least 12 months. A total of 6216 patients were exposed for a median of 455 days to warfarin (n=4967) and placebo (n=1249).

 

A2.1 Death

There were 224 fatal cases during active treatment, 112 in the ximelagatran treatment groups and 112 in the comparator groups. A further 331 patients died after stopping study drug (166 in the ximelagatran group and 165 in the comparator group). There was no difference between the treatment groups. The most common fatal SAE was myocardial infarction.

 

A2.2 Non-fatal SAE

A total of 26.3% of patients in the ximelagatran group and 27.1% of patients in the comparator group experienced a non-fatal SAE during treatment.  A further 5.5% of patients in the ximelagatran group and 4.3% of patients in the comparator group experienced a non-fatal SAE after stopping study drug. The most common non-fatal SAEs were cardiovascular events. The most common non-fatal SAEs considered to be causally related to ximelagatran were increases in hepatic enzymes.

 

A2.3 Discontinuation

The proportion of patients who discontinued study drug was higher in the ximelagatran group (1189/6931, 17.2%) than in the comparator group (801/6216, 12.9%).  This was mostly due to the discontinuation of study drug due to elevated liver function tests. Data from discontinuation of ximelagatran secondary to AEs indicates that coronary artery disorders were more common in the ximelagatran group (0.6% vs. 0.3%) whereas thromboembolic events were more common DAEs in the comparators group (1.3% vs. 0.4%), because of placebo control. Other common causes of discontinuations included bleeding events, with no difference between ximelagatran and the comparators, except for haematuria and rectal haemorrhage/ melaena, which caused slightly more discontinuations in the ximelagatran group than in the comparators group.

 

A2.4 Bleeding Events

In patients with AF, ximelagatran 36 mg was associated with fewer major bleeding events than warfarin (AF pool; 2.4% and 3.4% for the ximelagatran and warfarin group, respectively, p=0.0288).  However, there were no significant differences for major bleeding events between the groups in each of 2 pivotal studies (SH-TPA-0003 and STP-0005). In patients with acute VTE, ximelagatran 36 mg was associated with numerically fewer major bleeding events than enoxaparin/warfarin. In patients undergoing extended secondary prophylaxis for VTE, ximelagatran 24 mg was associated with a similar incidence of major bleeding events to placebo. A total of 38 patients experienced bleeding-related SAEs with a fatal outcome, 19 cases in each treatment group (ximelagatran or comparator).

 

 

 

A2.5 Hepatobiliary toxicity

In patients receiving long-term administration of ximelagatran (>35 days) an increase in ALAT >3xULN occurred in 6-13% (average 7.6%, 531/6948) compared to 0-2% (average 1.1%, 68/6230) of patients receiving comparator treatments. Including local laboratory data, 620 patients showed an ALAT elevation >3xULN during the studies, 546 patients in the ximelagatran group (cumulative incidence 7.8%) and 74 patients in the comparator group (cumulative incidence 1.1%).  Among the 531 patients in the ximelagatran group who presented with an ALAT >3xULN, 206 (39%) completed the study on study drug.  The remaining 325 patients (61%) discontinued study drug prematurely.

 

The time pattern of ALAT elevations was consistent across patients.  The increase typically occurred between 1 and 6 months after the initiation of ximelagatran.  Before and after this time frame the incidence of ALAT increase was similar to comparators. Of the 531 ximelagatran-treated patients who had an ALAT elevation >3xULN recorded by the central laboratory, 502 (95%) had their ALAT return to <2xULN with treatment continued in 235 patients (46.8%). Most cases show a peak of ALAT within the first 2 to 3 months post-randomization and a decline back towards baseline within about 6 months post-randomization.  

 

Eighteen patients who discontinued study drug with elevations of ALAT subsequently resumed treatment after ALAT had returned to the normal range. Of these 18 patients, 2 again experienced elevations of ALAT after drug was resumed.

 

An evaluation of potential risk factors for increase in ALAT indicated an increased risk in the

Post ACS (p=0.0009), and VTE-T (p=0.0003) populations and also in female patients (p=0.0002) patients with low BMI (<27 kg/m2) (p<0.0001) and patients receiving concomitant treatment with statins (p=0.019); Asian patients were found to have a decreased risk (p=0.0038). Although single factor identified above may not be strong enough to eliminate the subgroup population, presence of 2 or more risk factors, such as, female patients with low body weight or who are taking a statin, should be considered a contraindication for ximelagatran.

 

ALAT >3xULN was associated with bilirubin >2xULN (within one month following the rise in

ALAT) in 0.53% (37/6948) of all patients who were exposed to ximelagatran >35 days as compared to 0.08% (5/6230) of patients exposed to comparators. Nine ximelagatran-treated patients (24.3%, 9/37) died with concomitant ALAT >3xULN and bilirubin >2xULN. Among these, 3 died from heart failure; 3 died from carcinomas with hepatic metastases; 2 (ID# 7259, and 7859) died from GI bleeding with coagulopathy (1 with biopsy documented hepatic necrosis) and 1 (ID# 5442) died from hepatitis B. Liver failure/toxicity by ximelagatran might have caused or at least contributed to these deaths. Only one autopsy was done in these 9 deaths and it showed a small, friable and diffusely mottled liver suggestive of severe diffuse hepatic necrosis.

 

A2.6 Adverse Events of Coronary Artery Disease

In all study populations except the post acute coronary syndromes, the proportion of patients with coronary artery disease adverse events was higher in the ximelagatran groups than in the comparator groups (7.0% and 6.7% for the AF pool, 1.3% and 0.1% for the VTE-T pool and 2.6% and 2.0% for the VTE-P pool, for the ximelagatran and comparator groups, respectively).  This trend was consistent across the pools for myocardial infarction.

 

The proportion of patients with coronary artery disease adverse events was statistically significantly higher in the ximelagatran group (32/1848, 1.7%) than in the warfarin/placebo group (12/1859, 0.7%) in VTE (VTE-T + VTE-P) population (p=0.00411). Proportion of patients with MI was also significantly higher in the ximelagatran group (13/1848, 0.7%) than in the warfarin/placebo group (3/1859, 0.16%) in VTE population (p=0.01183). There were no appreciable differences between the treatment groups for underlying diseases. Considering ximelagatran as an anticoagulant with potential to treat MI, these results are worrisome.

 

B.        Description of Patient Exposure


 

An overview of days of exposure to treatment for the surgical population who received study drug for < 35 days is provided in Table 6.



Table 6: Overview of exposure: Warfarin-comparison Pool

 

In the 36-mg (EXULT) Pool, 1913 and 1897 patients were exposed to active ximelagatran 36 mg and warfarin, respectively. In the 24 mg Pool, 1097 patients received active ximelagatran 24 mg and 1081 patients received warfarin. In total, the Warfarin-comparison Pool comprised 1913 patients exposed to ximelagatran 36 mg, 1097 patients exposed to ximelagatran 24 mg, and 2226 patients exposed to warfarin. Mean days of exposure were 8.1 days for ximelagatran 24 mg or 36 mg, 6.7 days for warfarin, which does not include the first dose of warfarin given the evening of surgery. More patients (73%) in each of the ximelagatran 24-mg or 36-mg groups remained on treatment from 7 to 9 days, compared to the warfarin group (43%). This finding probably reflects warfarin treatment being withheld due to INRs within normal range.

 

For non-Surgical Populations who received study drug for > 35 days, data from 10 Phase II and Phase III studies, in which patients received ximelagatran for up to 4 years, are presented in 4 pools based on the indication that was investigated. These indications were AF, VTE treatment (VTE-T), VTE secondary prevention (VTE-P) and post ACS. A fifth pool, the long-term exposure (LTE) pool, combines data from all of these indications.

 

The long-term (>35 days) safety of ximelagatran has been studied in a large population of 6931 patients comprising 3838 patients with atrial fibrillation (AF),1236 patients for treatment (VTE-T) and 612 patients for secondary prevention (VTE-P) of venous thromboembolism (VTE) and 1245 patients with recent acute coronary syndrome (post ACS). These 6931 patients received doses from 20 to 60 mg, for a median of 370 days, representing an overall exposure of

6768 patient-years. A total of 5024 patients were exposed to ximelagatran for at least 6 months (>180 days) and 3509 for at least 12 months (>360 days). All the studies were controlled, thus enabling comparison of a cohort of 6216 patients exposed to ximelagatran for a median of 455 days mainly to the reference anticoagulant warfarin (n=4967), but also to placebo in a smaller number of patients (n=1249).

 

Demographic and other characteristics: the long-term exposure (LTE) pool

The treatment groups were well-balanced regarding demographic characteristics. Nearly all (>93%) of the patients were Caucasian and the majority (64%) were males. The majority of the females (89%) were over 45 years of age (an arbitrary cut-off to distinguish females of childbearing potential). Most patients (64.1%) were 65 years or over although there was a wide range of ages in the program (18 to 97 years). Demographic characteristics of all treated patients in the LTE pool are shown in Table 7.

 


Table 7: Demographic description: LTE pool

 

 

C.        Methods and Specific Findings of Safety Review

 


1: The surgical population who received study drug for < 35 days


 

The treatment groups were well-balanced regarding demographic characteristics. Nearly all (>94%) of the patients were Caucasian and there were more females (62%) than males (38%).

Approximately two-thirds of patients were 65 years or older (66%) although there was a

wide range of ages in the program (24 to 91 years of age). There were 18% to 20% of patients above 100 kgs and about 50% with a BMI >30 kg/m2 . A total of 16 patients had severe renal impairment (CrCL <30 mL/min) (in violation of entry criteria). Approximately 35% of the patients had some renal impairment (CrCL <80 mL/min).

 

1.1 Most common AEs –Warfarin-comparison Pool

 

Overall, more than 55% of patients in each treatment group experienced at least 1 AE. The frequency of AEs was similar in the ximelagatran 24-mg and the warfarin groups (66% and 61%, respectively). The frequency of AEs was similar in the ximelagatran 36-mg and the warfarin groups (58% and 56%, respectively).

 

The incidence of SAEs was higher in the ximelagatran treatment groups than in the concurrent warfarin group (3.8 vs. 3.2% for 36 mg of ximelagatran vs. warfarin and 3.2% vs. 2.7% for 24 mg of ximelagatran vs. warfarin).

 

The incidence of discontinuations was higher in the ximelagatran treatment groups than in the concurrent warfarin group (2.6% vs. 2.0% for 36 mg of ximelagatran vs. warfarin and 3.1% vs. 2.1% for 24 mg of ximelagatran vs. warfarin respectively).

 

1.2 Deaths

 

There were 18 fatal cases in the Warfarin-comparison Pool (12 patients exposed to ximelagatran and 6 patients exposed to warfarin) with 4 and 3 fatalities occurring during the

treatment period, respectively.

 

Of the 12 fatal SAEs reported among the 3010 patients who received ximelagatran (0.4%), 2 were fatal bleeding events (both on ximelagatran 36 mg).  Six were fatal events in which ‘PE could not be excluded’. The last 4 fatal SAEs in patients who received ximelagatran were adjudicated as ‘death not associated with VTE or bleeding’.  The investigators reported the causes of death in 1 patient on treatment as sudden death, and in the other 3 patients after treatment as intestinal perforation, acute myocardial infarction, and pneumonia.

 

Of the 6 fatal SAEs reported among the 2226 patients who received warfarin (0.3%), 2 were fatal events in which ‘PE could not be excluded’. The last 4 fatal SAEs in warfarin-treated patients were adjudicated as ‘death not associated with VTE or bleeding’.  The investigators reported the causes of death in 2 patients on treatment as arrhythmia and MI and in the other 2 after treatment as colon carcinoma and acute myocardial infarction.

 

Two fatal cases of GI hemorrhage occurred during treatment in the ximelagatran 36-mg group. The number and percentage of patients who died during or after treatment in the Warfarin-comparison Pool is presented in Table 8.

 

 

 

 

 

 

Table 8: Number (%) of patients with fatal SAEs during or after treatment, presented by preferred term: The Warfarin- comparison Pool (exposed safety population)

 


 

1.3 Serious Adverse Events other than deaths – Warfarin-comparison Pool

 

Within both 36-mg (EXULT) and 24-mg pools, the frequency of non-fatal SAEs was higher in either ximelagatran treatment group (3.7% and 3.5%) than in their respective warfarin groups (3.1 and 2.6%) during treatment.

 

Including both during study treatment and after study treatment periods, the most frequently occurring non-fatal SAEs were postoperative complications and myocardial infarction, which occurred more frequently in the ximelagatran groups, and atrial fibrillation, which occurred more frequently in the warfarin group.

 

The number of patients with the most commonly reported non-fatal SAEs during and after

treatment is presented in Table 9.

 

 

 

 

 

 

 

Table 9 Number (%) of patients with the most commonly reported non- fatal SAEs during and after treatment: The Warfarin- comparison Pool (exposed safety population)

 


Please see the section of 1.7: coronary artery disease adverse events for more details about the adverse events related to myocardial infarction and coronary artery diseases.

 

1.4 Discontinuations due to AEs - Warfarin-comparison Pool

 

Discontinuations due to AEs (DAE) were slightly higher in the ximelagatran 36-mg group (2.6%) than warfarin (2.0%) as well as in the ximelagatran 24-mg group comparison to warfarin (3.1% versus 2.1%, respectively); this was driven by an excess of bleeding-related AEs. Regardless of treatment group, the most common reason for a DAE was postoperative complication, with a similar incidence between treatment groups.

 

1.5 Bleeding events in the Warfarin-comparison Pool

 

Major bleeding events were uncommon overall and higher in ximelagatran groups than warfarin groups during the treatment period (0.9% ximelagatran 36 mg, 0.5% warfarin; 0.9% ximelagatran 24 mg, 0.6% warfarin). In the 36-mg Pool, the difference in the frequencies of major bleeding events between ximelagatran and warfarin was 0.4% (95% CI, –0.1% to1.0%). Similar results were noted for the 24-mg Pool (ximelagatran-warfarin, 0.3%; 95% CI, -0.5% to 1.0%). The proportions of patients with on-treatment major bleeding events in the Warfarin-comparison Pool, for both the 36-mg and 24-mg Pools, are summarized in Table 10.

 

 

 

 

 

 

 

Table 10 Number (%) of patients with on- treatment adjudicated major bleeding events: Warfarin- comparison Pool (exposed safety population)

 


 

Adjudication criteria for major bleeding were medical or surgical intervention for the reported

bleeding event and/or bleeding index >2. The distribution of all major bleeding events by adjudication criteria was similar to the distribution of on-treatment events.

 

In the 36-mg Pool, the most common locations of on-treatment major bleeding events in the ximelagatran group were wound hematoma, gastrointestinal bleeding, and wound bleeding. Events in these locations occurred with comparable frequency in the warfarin group. In the 24-mg Pool, wound hematoma and gastrointestinal bleeding were more frequent in the ximelagatran group than in the warfarin group, while wound bleeding occurred only in the warfarin group. There were no major nasal or urinary bleeding events in any treatment group.

 

The frequencies of patients with on-treatment major/minor bleeding events were higher in ximelagatran groups than warfarin groups (5.1% ximelagatran 36 mg, 4.1% warfarin; 5.7%

ximelagatran 24 mg, 4.7% warfarin).

 

Two fatal on-treatment major bleeding events occurred in the ximelagatran 36-mg group; both

events were coded as GI hemorrhage. None of the on-treatment major bleeding events in the ximelagatran 24-mg group was fatal. There were no fatal on-treatment bleeding events in the warfarin-groups.

 

Two critical-site on-treatment bleeding events occurred during ximelagatran treatment (0.9%).

One patient (SH-TPO-0012-029-10779) treated with ximelagatran 36 mg developed postoperative confusion just after surgery. A CT scan revealed a subdural hematoma. The other patient (SH-TPO-0010-016-2131), who was treated with ximelagatran 24 mg, was found by CT scan to have a left frontal brain hemorrhage after 6 days of postoperative confusion; a biopsy

revealed a malignant glioma; the reported AE was coded as cerebral hemorrhage. No

bleeding at other critical sites (intraspinal, intraocular, retroperitoneal, or pericardial) was

reported in the ximelagatran groups. None of the major bleeding events reported in warfarin-treated patients occurred at a critical site (intracranial, intraspinal, intraocular, retroperitoneal,

or pericardial).

 

In the ximelagatran groups, on-treatment major bleeding events included GI bleeding in

9 patients (5 in the 36-mg group, 4 in the 24-mg group), with 2 events in the 36-mg group

reported as fatal bleeding SAEs as noted above. Additional on-treatment major bleeding events included 12 wound hematomas (7 in the 36-mg group, 5 in the 24-mg group) and 5 wound-bleeding events (all in the 36-mg group). Medical or surgical intervention for the bleeding event was required in 14 ximelagatran-treated patients (11 in the 36-mg group, 3 in the 24-mg group). These interventions included evacuation/aspiration of clot or hematoma, incision and drainage, wound irrigation and debridement, closure of wound, re-operation, endoscopy, laparotomy and gastrostomy for ulcers and evacuation of subdural hematoma.

 

In the warfarin-treated groups, on-treatment major bleeding events included GI bleeding in

3 patients and haemarthroses in 2 patients. Additional on-treatment major bleeding events

included 5 wound hematomas and 2 wound-bleeding events. Medical or surgical intervention for the bleeding event was required in 6 warfarin-treated patients. The interventions included evacuation/aspiration of blood or hematoma, surgical drainage, debridement of wound haematoma, re-operation and removal of blood from knee, and transfusion.

 

1.5.1 Incidence of reported bleeding events

 

Fewer than 8% of patients in each treatment group had a reported bleeding event during study treatment. Two patients in the ximelagatran 36-mg group had fatal nonsurgical bleeding events of GI hemorrhage.

 

In the 36-mg Pool, the frequency of patients with a reported bleeding event was higher in the ximelagatran group than in the warfarin group (7% and 5%, respectively). Overall, the proportions of patients who had at least 1 reported bleeding event were higher in the ximelagatran treatment groups (6.7% and 7.2% respectively) than in the warfarin groups (5.0 and 5.6% respectively), as were the proportions of patients who had an event that led to discontinuation of study treatment (1.1% in ximelagatran group vs. 0.5% in warfarin groups). There was no appreciable difference among groups with respect to SAEs of bleeding.

 

The overall frequencies of on-treatment reported bleeding events for the 36-mg and 24-mg Pools are shown in Table 11.

 

 

 

 

 

 

 

Table 11: Number (%) of patients who had an on-treatment reported bleeding event in any category: Warfarin-comparison Pool (exposed safety population)

 


 

The overall incidence of adjudicated bleeding with ximelagatran was low and considered to be clinically acceptable.

 

1.5.2 Conclusions on bleeding

 

A numerically higher frequency of bleeding events was observed for ximelagatran in the oral

only, post-operative program for TKR when compared with warfarin. The overall incidence of bleeding with ximelagatran was low and considered to be clinically acceptable.

 

With respect to on-treatment adjudicated events, major bleeding occurred in 0.9% of patients treated with ximelagatran 36 mg, compared with 0.5% of patients treated with warfarin. Major/minor bleeding occurred in 5.1% of patients treated with ximelagatran 36 mg and 4.1% of patients treated with warfarin. Similar results were observed for ximelagatran 24 mg bid compared with warfarin.

 

Fewer than 8% of patients in any of the ximelagatran or warfarin groups had a reported bleeding event during study treatment, and most events were non-serious. There was no apparent relationship between ximelagatran dose and bleeding risk, as indicated by similar proportions of patients with bleeding events (major and major/minor) in the ximelagatran 36-mg and 24-mg groups in Study SH-TPO-0010.

 

Subgroup analyses of major/minor bleeding events in the 36-mg and 24-mg comparison groups did not reveal a subgroup with a clinically important difference in bleeding risk from the entire population (ie, one which might require dose adjustment). In general, treatment differences were consistent across subgroups.

 

1.6 Analysis of ALAT elevations in the Surgical population

 

Since ALAT is a more specific marker of liver cell damage than ASAT, and because there was no pattern for an increase in alkaline phosphatase (ALP) or bilirubin in isolation, ALAT forms the basis of the analysis. A threshold of >3x ULN ALAT was used to indicate a signal of potential clinical relevance.

 

1.6.1 Studies EXULT A (SH-TPO-0010) and EXULT B (SH-TPO-0012)

 

Changes from baseline in clinical chemistry parameters, including elevations in ALAT,

reflected surgical intervention and postoperative recovery and were generally comparable in

the ximelagatran and warfarin treatment groups. These changes generally occurred during the immediate postoperative course of treatment and at the time of the end of treatment with a return to near baseline levels at follow-up.

 

In EXULT A, there were no differences between the ximelagatran groups and the warfarin

group for patients who had ALAT elevation >3x ULN at the end of treatment (6/723, 36-mg;

4/706, 24-mg; 12/704 warfarin). During the follow-up period, 4 patients in the ximelagatran

36-mg group, 1 patient in the ximelagatran 24-mg group, and 0 in the warfarin group had their

first ALAT elevation >3x ULN. Three of the 4 patients in the ximelagatran 36-mg group had their first ALAT elevation >30 days after receiving their last ximelagatran dose while the fourth patient had their first ALAT elevation 28 days after receiving their last ximelagatran dose.

 

In EXULT B, there were no differences between the ximelagatran and warfarin groups for

patients who had ALAT elevations >3x ULN at end of treatment (7/1095, ximelagatran 36-mg

group; 6/1087 warfarin group). During the follow-up period, 4 additional patients had their

first ALAT elevation >3x ULN: 3 in the ximelagatran 36-mg group and 1 in the warfarin

group. For all 3 ximelagatran 36 mg patients, the elevations were resolved within 30 days of elevation, including one patient (SH-TPO-0012-510-14309) who began a LMWH on postoperative day 11 as treatment for DVT.

 

Drug effects on liver toxicity beyond 4-6 weeks are unknown. It should be noted that elevation of hepatic enzymes was typically seen between 2nd and 6th month after starting ximelagatran (long-term exposure data).

 

1.6.2 Hepatobiliary AEs in the Surgical population Warfarin-comparison Pool

 

Overall frequency of AEs in the liver and biliary system disorder was slightly higher in

the ximelagatran 36-mg (EXULT) group compared to warfarin (6.7% vs 5.4%) and in the

ximelagatran 24-mg group, 5.5% ximelagatran 24-mg versus 5.1% warfarin. This was due to a higher rate of reported GGT increased (ximelagatran: 5.6% in the 36-mg group, 4.4% in the 24-mg group, versus 4.2% in both warfarin groups).

 

Incidences of ALAT (SGOT) increased reported as AEs were similar across the groups (36-mg ximelagatran comparison: 2.1% ximelagatran 36-mg, 1.3% warfarin; 24-mg comparison group: 1.4% ximelagatran 24-mg, 1.5% warfarin). There were no hepatobiliary fatal SAEs, non-fatal SAEs or DAEs in either ximelagatran group.

 

1.6.3 Conclusions of hepatobiliary effects in the Surgical population

 

There were no differences in the on-treatment incidences of ALAT elevation between ximelagatran and warfarin. However, during the follow-up period (4-6 weeks), 7 patients in the ximelagatran group, and 1 in the warfarin group had their first ALAT elevation >3x ULN. Drug effects on liver toxicity beyond 4-6 weeks are unknown. It should be noted that elevation of hepatic enzymes was typically seen between 2nd and 6th month after starting ximelagatran (long-term exposure data).

 

1.7 Coronary artery disease adverse events

 

Serious adverse events on coronary artery disease including MI are summarized in table 12.

 

Table 12: Summary of CAD adverse events following short-term use of ximelagatram#

 

Exult A

 

Exult B##

 

Exult A and B

 

Event: N (%)

Exanta

N=1526

Warfarin

N=759

Exanta

N=1151

Warfarin

N=1148

Exanta

N=2677

Warfarin

N=1907

MI

11 (0.72)

1

(0.13)

5

(0.43)

3

(0.26)

16*

(0.60)

4*

(0.21)

Other CAD (Angina/ischemia)

3

(0.2)

0

1

(0.17)

1

(0.09)

4

(0.15)

1

(0.05)

Total

14

(0.92)

1

(0.13)

6

(0.7)

4

(0.35)

20**

(0.75)

5**

(0.26)

*p=0.04951; ** p=0.02800

#Excluded 4 patients who did not take study medications, 3 in ximelagatran group (ID: #3206, #7086 and #10944) and 1 in warfarin group (ID: #9089) whose death was also adjudicated by the central adjudication committee as PE.

##one case of sudden death (#15016) in the warfarin group was included as MI and two cases of sudden deaths in the Exanta group (ID: #14366 and 12122) were excluded from the analysis.

Summarized from Module 5, vol. 1 Table 54 and vol. 2 Table 11.3.5.1; vol. 3 Table 55 and vol. 4 Table 11.3.5.1

 

 

In both Exult A and Exult B, the proportion of patients with coronary artery disease adverse events (MI and angina) was higher in the ximelagatran groups than in the warfarin groups. After combining Exult A and Exult B, proportion of patients with coronary artery disease adverse events was statistically significantly higher in the ximelagatran group (20/2677, 0.75%) than in the warfarin group (5/1907, 0.26%) in the TKR population (p=0.02800). Proportion of patients with MI was also higher in the ximelagatran group (16/2677, 0.60%) than in the warfarin group (4/1907, 0.21%) in the TKR population (p=0.04951). There were no appreciable differences between the treatment groups for underlying diseases including hypertension, diabetes mellitus, hypercholesterolemia, coronary atherosclerosis, as well as age, gender and weight (Table 13).

Table 13: Concomitant medical conditions in studies EXULT A and B
___________________________________________________________
                                                  Ximelagatran           Warfarin
                                                     N=2225                 N=1575
                                                      n (%)                     n (%)
___________________________________________________________
Hypertension                          1325 (59.6)             963 (61.1)
hypercholesterolemia               339 (15.2)             243 (15.4)
Diabetes mellitus                     290 (13.0)             199 (12.6)
Coronary atherosclerosis         155 (6.9)                 99 (6.3)
____________________________________________________________
                                                 N=2677                 N=1907

Gender     Male                       1015 (37.9)           715 (37.5)
Age, years  Mean (SD)            67.7 (9.5)             67.5 (9.5)
Weight (kg) Mean (SD)           84.3 (18.1)           84.5 (17.7)

____________________________________________________________

 

All of events occurred during the first 2 weeks, except 2 cases of MI in the ximelagatran group that occurred at day 28 and day 39, and 1 case in the warfarin group reported at day 21. In the ximelagatran group, 14 cases occurred during the treatment period; 3 cases occurred 1-4 days after last dose of ximelagatran; 2 cases, beyond 1 week after last dose. The relationship between last dose and events in 1 other case is unclear. The diagnoses of MI in 1 patient in the warfarin group is unclear (PE can not be ruled out). One case was reported at day 21. Four other cases were reported during the treatment period.  Considering ximelagatran as an anticoagulant with potential to treat MI, these results are worrisome.

 

 

2: The non-surgical population who received study drug for > 35 days

 

2.1 Common adverse events: long-term exposure (LTE) pool

 

The overall frequencies of AEs, fatal SAEs, non-fatal SAEs and DAEs during active treatment

are presented for the LTE pool in Table 14.

 

Table 14: Number (%) of patients who had an adverse event: LTE pool

 


The overall proportion of patients reporting adverse events was high (85%) due to the severity of the underlying diseases in these populations but there was no difference between the treatment groups. The frequency of SAEs (fatal and non-fatal) was similar between the treatment groups. The proportion of patients who discontinued study drug was higher in the ximelagatran group (17.2%) than in the comparator group (12.9%). This was mostly due to discontinuation of study drug due to elevation of hepatic function tests. The most commonly reported AEs in the LTE pool are presented in Table 15. Adverse events reported with a frequency of at least 4.0% in any column are presented. The events are sorted by the ximelagatran column.

 

Table 15: Number (%) of patients with the most commonly reported AEs: LTE pool


 

2.2 Deaths

 

The overall mortality in the ITT population was 3.9% in the ximelagatran group and 4.4% in

the comparator group. AEs that most frequently led to death were myocardial infarction,

sudden death, cardiac arrest and cardiac failure, events expected for the 2 populations at risk

of cardiovascular events, AF and post ACS.

 

2.2.1 Deaths: LTE pool

 

Death was included in the definition of the endpoints in the studies in the LTE pool and all

cause mortality is analyzed using the ITT population. Overall mortality was similar between ximelagatran and comparators.

 

 

Table 16: Risk of death in the LTE pool, estimated relative risk with 95% CI (ITT population)

 


Because the comparator was placebo in the VTE-P and Post ACS pools, a higher mortality

might have been expected for the comparator group. Therefore, the overall mortality has also

been compared between ximelagatran and the active comparator (warfarin). Overall mortality was similar between ximelagatran (6.5%) and warfarin (7.1%).

 

2.2.2 Fatal SAEs in the safety population

 

There were 224 fatal cases during active treatment, 112 in the ximelagatran treatment groups and 112 in the comparator groups. A further 331 patients died after stopping study drug (166 in the ximelagatran group and 165 in the comparator group).

 

The most common fatal SAE was myocardial infarction (MI). During active treatment, the proportion of patients who died due to acute MI was the same for the 2 treatment groups (0.2%). However, after stopping treatment fatal acute MIs occurred more frequently in the ximelagatran group (0.4%) than the comparator group (0.2%).

 

In the post ACS pool, there was an increased proportion of fatal myocardial infarctions in the post-treatment period (1.1% vs 0.5%). There were 29 fatal cases during active treatment, 15 (1.2%) in the ximelagatran treatment groups and 14 (2.2%) in the placebo group. A further 35 patients died after stopping study drug, 27 (2.2%) in the ximelagatran groups and 8 (1.3%) in the placebo group. All deaths during treatment were reported in terms associated with cardiovascular

disease, with the exception of one suicide in the placebo group.

 

2.2.3 Fatal SAEs considered causally related by the investigator: LTE pool

 

There were no differences between treatments concerning the number of fatal SAEs considered by the investigators to be causally related to study drug (Table 17).

 

 

 

Table 17: Number (%) of patients with fatal serious adverse event considered causally related by the investigator: LTE pool

 

 

                                                                   During the treatment                                                After treatment                

                                                                        ximelagatran       Comparators                              ximelagatran      Comparators

                                                                                  n=6931                 n=6216                                         n=6819                   n=6104

                                                           n    (%)         n   (%)                          n     (%)        n    (%)

Total                                                 14   (0.2)        10 (0.2)                          5   (0.1)          8   (0.1)

 

GI haemorrhage                                  1                                                                               1

Haematemesis                                    1                                                                               1  

Hepatitis infectious                                                                                         1            

Myocardial infarction                          1                       

Cardiac arrest                                     1                    2             

Cardio-respiratory arrest                    1                       

Fibrillation ventricular              1                       

Cerebral haemorrhage                        2                    2                                   1                    2  

Cerebrovascular disorder                    1                    1                                                         2  

Haemorrhage intracranial                                          1                                                         1

Subarachnoid haemorrhage                 1                       

Aspiration pneumonia                                                                                    1

Bronchitis aggravated                                                                                                            1 

Hypoxia                                                                                                        1            

Resp distress syndrome adult                                                                                                1 

Respiratory disorder                                                 1 

Retroperitoneal haemorrhage                                    1 

Myeloid metaplasia                                                                                        2            

Pulmonary carcinoma                          1                       

Sudden death                                     3                    1             

Sepsis                                                1           

 

 

 

2.2.4 Comparison of deaths between pools

 

There was a similar mortality rate in patients taking ximelagatran and those taking comparators in all pools.  The most frequent AEs leading to death were driven by the 2 populations at risk of cardiovascular events, AF and post ACS: myocardial infarction, sudden death, cardiac arrest, cardiac failure.  There were no obvious differences in the rates of such fatal cardiac events between groups, except for an excess of myocardial infarctions in patients who had discontinued ximelagatran and this was seen in the post ACS pool.  Most of these AMIs started during treatment.

 

 

 

2.3      Serious adverse events other than death

 

There was a higher frequency of SAEs in the hepatobiliary in the ximelagatran groups relative to comparator treatment in all pools.

 

A higher frequency of SAEs related to coronary artery disease was seen in the ximelagatran groups in all pools with the exception of the Post ACS pool.

 

Subjects in the safety population who experienced non-fatal SAEs during or after active study treatment are included in the following tables.

 

Table 18      Number (%) of patients with the most commonly reported non-fatal serious adverse events:  LTE pool 

 


A total of 26.3% of patients in the ximelagatran group and 27.1% of patients in the comparator group experienced a non-fatal SAE during treatment.  A further 5.5% of patients in the ximelagatran group and 4.3% of patients in the comparator group experienced a non-fatal SAE after stopping study drug.

 

The most common non-fatal SAEs were cardiovascular events which reflect the diseases under study. The most common non-fatal SAEs considered to be causally related to ximelagatran were increases in hepatic enzymes.

 

The profile of the non-fatal SAEs was consistent with the pattern of all AEs in the pool. There was a higher reporting frequency of SAEs in the hepatobiliary organ system in the ximelagatran groups compared to warfarin or placebo in all pools.

 

A higher frequency of SAEs related to coronary artery disease was seen in the ximelagatran groups in all pools with the exception of the Post ACS pool.

 

2.4 Discontinuation of Study Drug due to an Adverse Event (DAE)

 

The most common AEs causing discontinuation of study drug for the LTE pool are presented in Table 19. 

 

Table 19:  Number (%) of patients with the most commonly reported DAEs:  LTE pool 

 


The proportion of patients who discontinued study drug was higher in the ximelagatran group (17.2%) than in the comparator group (12.9%).  This was mostly due to the discontinuation of study drug due to increased liver function tests (LFTs).

 

Apart from increases in hepatic enzymes, the most frequent reasons for discontinuations were related to coronary artery disorder in the ximelagatran group (0.6% vs. 0.3%). Thromboembolic events were more common DAEs in the comparators group (1.3% vs. 0.4%), because of placebo control in secondary prevention study.

 

Other common causes of discontinuations included bleeding events, with no difference between ximelagatran and the comparators, except for hematuria and rectal haemorrhage/melaena, which caused slightly more discontinuations in the ximelagatran group than in the comparators group.

 

2.5 Bleeding Events

 

2.5.1      Major bleeding events

 

The risk of a major bleeding event is summarized by treatment group in Table 20. 

 

Table 20: Risk of a major bleeding event per patient year

 


 

In patients with AF, ximelagatran 36 mg was associated with statistically significantly fewer major bleeding events than warfarin (AF pool; 2.4% and 3.4% for the ximelagatran and warfarin group, respectively, p=0.0288).  However, there were no significant differences for major bleeding events between the groups in each of 2 pivotal studies (SH-TPA-0003 and STP-0005). In patients with acute VTE, ximelagatran 36 mg (1.1%, 14/1240) was associated with numerically fewer major bleeding events than enoxaparin/warfarin (2.1%, 26/1249).

 

In patients undergoing extended secondary prophylaxis for VTE, ximelagatran 24 mg was associated with a similar incidence of major bleeding events to placebo (1% and 0.8%, respectively).

 

2.5.2      Major/minor bleeding events

 

The risk of a major/minor bleeding event is summarized by treatment group in Table 21. 

 

Table 21: Risk of a major/minor bleeding event per patient year

 


In patients with AF, ximelagatran 36 mg was associated with statistically significantly fewer major/minor bleeding events than warfarin  (AF pool; 32.0% and 39.1% for the ximelagatran and warfarin groups, respectively, p<0.0001).  In patients with acute VTE, ximelagatran 36 mg was associated with numerically fewer major/minor bleeding events than enoxaparin/warfarin (5.5% vs. 7.0%).

 

In patients undergoing extended secondary prophylaxis for VTE, ximelagatran 24 mg was associated with a numerically more major/minor bleeding events than placebo (21.9% and 18.2% for the ximelagatran and the placebo group, respectively).

 

In the dose-finding study in post ACS patients, the risk of a major/minor bleeding event with ximelagatran plus ASA increased with increasing dose.  Patients who received ximelagatran plus ASA had statistically significantly more major/minor bleeding events than patients who received placebo plus ASA (pooled doses;  19.8% and 11.3% for the ximelagatran plus ASA, and the placebo plus ASA, respectively, p<0.0001).  

 

2.5.3 Fatal bleeding events

 

The incidence of fatal bleeding events (adjudicated fatal events, and bleeding-related serious

adverse events leading to death) is summarized by treatment group in Table 22.

 

Table 22: Summary of fatal bleeding events, by study

 


    OT: on treatment

 

In addition to the 13 patients with bleeding-related serious adverse events leading to death whilst on treatment in Table 20 (safety population), a further 16 patients had bleeding-related serious adverse events leading to death after stopping treatment.  Of these 16 patients, 7 had received ximelagatran and 9 had received warfarin.  Thus in total, 29 patients experienced bleeding-related SAEs with a fatal outcome.  

 

Almost all fatal bleeding events were intracranial (17 cases) or gastrointestinal (10 cases), except 1 case of pericardial and 1 case of retroperitoneal bleeding.

 

Of the 29 patients who experienced bleeding-related SAEs with a fatal outcome, 13 were not included in the “on treatment” analysis of bleeding outcomes.  Ten events were intracerebral haemorrhages that were adjudicated as strokes by the adjudication committee.

 

Patient SH-TPV-0002-701-4723 was not included in the OT-analysis as a fatal bleed.  This patient had a “Bleeding per rectum” that started 30 days after last study drug intake and therefore the adjudication committee classified this as "Death not associated with VTE or bleeding".

 

Conversely, 7 patients in the ximelagatran group and 2 patients in the warfarin group who had a fatal major bleed according to the adjudication committee are not included in the 29 patients who experienced bleeding-related SAEs with a fatal outcome.  Eight patients were not captured by the search on bleeding terms because the term used by the investigator to describe the AE leading to death did not match the preferred terms used to identify patients with bleeding events. The remaining patient (SH-TPA-0003-316-2826) in the ximelagatran group died after discontinuing study drug and is therefore not shown in the AE tables.

 

In summary, a total of 38 patients experienced bleeding-related SAEs with a fatal outcome, 19 cases in each treatment group (ximelagatran or comparator).

 

2.5.4 Overview of reported bleeding-related adverse events across indication pools

 

An overview of the incidence of bleeding adverse events is summarized by treatment for the individual pools in Table 23.

 

Table 23: Number (%) of patients who had bleeding-related adverse events

 


In patients with AF, the incidence of reported bleeding adverse events with ximelagatran 36 mg (32.6%) was less than that observed with warfarin (40.1%).  The incidence of serious adverse events and discontinuations due to a bleeding adverse event was low and similar in both treatment groups.

 

In patients with acute VTE, the incidence of reported bleeding adverse events with ximelagatran 36 mg (18.3%) was less than that observed with enoxaparin/warfarin (25.4%).  The incidence of serious adverse events and discontinuations due to a bleeding adverse event was low and similar in both treatment groups.

In patients undergoing extended secondary prophylaxis for VTE, the incidence of reported bleeding adverse events with ximelagatran 24 mg was numerically greater than that observed with placebo.  The incidence of serious adverse events and discontinuations due to a bleeding adverse event was low and similar in both treatment groups.

The incidence of reported bleeding adverse events in patients receiving ximelagatran and ASA (20.1%) was higher than that observed with placebo and ASA (11.4%).  The incidence of serious adverse events and discontinuations due to a bleeding adverse event with ximelagatran plus ASA was low (2.7% and 4.5% for serious adverse events and discontinuations due to adverse events, respectively), but higher than that observed with placebo and ASA (1.1% and 0.9% for serious adverse events and discontinuations due to adverse events, respectively).

 

In AF patients, the most commonly reported bleeding related AEs for ximelagatran-treated patients were purpura (which was the preferred term used to code unspecified hematomas, bruises and petechiae) (11.1%), epistaxis (7.2%), haematuria (5.4%) and rectal haemorrhage (2.9%).  

 

In patients with an acute VTE, the most commonly reported bleeding related AEs for ximelagatran-treated patients were purpura (4.6%), epistaxis (3.2%), haematuria (2.8%) and gingival bleeding (2.0%).  

 

In patients undergoing extended secondary prophylaxis for VTE the most commonly reported bleeding related AEs for ximelagatran-treated patients were haematuria (6.0%), purpura (4.7%), melaena (3.6%), and rectal haemorrhage (1.6%).  

 

The most commonly reported bleeding AEs in patients receiving ximelagatran and ASA were epistaxis (4.9%), haematuria (4.9%), melaena (3.7%) and purpura (3.6%).  

 

2.5.5 Relationship between exposure to melagatran and bleeding events

 

The association between AUC and the cumulative risk of a major/minor bleeding event is summarized for ximelagatran-treated patients in the AF pool in Table 24.

 

Table 24:      Association between AUC and cumulative risk of having a bleeding event (major or minor) after one year in the study

 


The risk of having a major/minor bleeding event with ximelagatran 36 mg increases with increasing AUC values (hazard ratio 1.17, 95% CI: 1.12, 1.21)

 

There was no statistically significant relationship between the risk of having a major/minor bleeding event with ximelagatran 24 mg and increasing AUC values (hazard ratio 1.08, 95% 0.90, 1.29).  

 

2.5.6 Subgroup analyses of bleeding events: 

 

Within-treatment group comparisons suggested that, for both ximelagatran and warfarin, patients >75 years old, and those with prior stroke/TIA, were at an increased risk of major/minor bleeding.  In the ximelagatran group only, CrCL <80 mL/min, previous CAD and diabetes mellitus were also suggested to be associated with an increased risk of major/minor bleeding events.  In the warfarin group, the same conclusion was suggested for patients with paroxysmal AF and those who had previously taken aspirin.

 

For the majority of subgroups investigated, patients were statistically significantly less likely to have a major/minor bleed with ximelagatran 36 mg than warfarin.  Two significant treatment by risk factor interactions were detected, for CrCL <80 mL/min (p<0.001) and diabetes mellitus (p=0.002).  In terms of the key demographic characteristics, the following subgroups were statistically significantly less likely to have a major bleed with ximelagatran 36 mg than warfarin patients with a CrCL >80 mL/min, patients less than 75 years old, patients with a BMI >25, males and females, patients with a weight >50 kg and Caucasians.

 

There were no subgroups that were statistically significantly less likely to have a major/minor bleed with warfarin compared to ximelagatran.  

   

2.6 Hepatobiliary effects

 

It should be noted that the following patients have been excluded from the studies:

·        Patients with known clinically significant liver disease (as judged by the investigator) or persistent ASAT and/or ALAT > 3 x ULN (defined by central laboratory)

·        Patients with continuous treatment with NSAID or Known drug addiction and/or alcohol abuse

 

In studies with ximelagatran (bid, fixed dose), from June 2000, liver enzymes were monitored

at least monthly for the first 6 months and if ALAT increased to >3xULN, were monitored

weekly; if ALAT reached >7xULN study drug was stopped. From 2 November 2001, this

algorithm was changed. The threshold for beginning weekly monitoring was reduced from

3xULN to 2xULN and the threshold for discontinuation of study drug was revised from

7xULN to 5xULN (or persistent increase >3xULN for up to 4-8 weeks). In the program,

40% of the ximelagatran-treated patients who had an ALAT >3xULN were monitored using

the more stringent algorithm.

 

2.6.1 Patients contributing to ALAT measurement

 

The number of randomized patients contributing to ALAT testing is shown in Table 25.

 

Table 25: Number of patients randomized, and contributing ALAT measurements over time in the long-term studies (ITT population) - Central laboratory data only

 


 

Of the 6948 patients randomized to ximelagatran, 6840 contributed at least one ALAT measurement and 5528 had an ALAT measurement at the 6-month visit.

 

2.6.2 Elevations in liver function tests (LFTs)

 

The distribution of patients with elevated ALAT, ASAT, ALP and total bilirubin, according to

various multiples of ULN is shown for the LTE pool in Table 26 (Central laboratory data

only).

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 26: Cumulative incidence of patients with elevated ALAT, bilirubin, ASAT, G-GT and ALP (ITT population): LTE pool - Central laboratory data only

 


The pooled data shows a similar pattern to that seen in the individual studies. ALAT showed a significant increase in ximelagatran-treated patients compared to those treated with comparators at all thresholds. ASAT increased in conjunction with ALAT. There was no similar increase for ximelagatran relative to comparators in total bilirubin and ALP.

 

ALAT is the main marker of a hepatic effect in the ximelagatran group compared to the comparator. There is a strong correlation with ASAT, but ALAT is generally higher and is known to be more specific to the liver. The elevation in the other tests is not as different between groups, and there is no correlation between ALAT and ALP or bilirubin. These features point to a predominantly hepatocellular type of hepatic injury, as opposed to a cholestatic type.

 

As ALAT is a more specific marker of liver cell damage than ASAT, and there was no pattern

for an increase in ALP or bilirubin in isolation, ALAT was used for monitoring and management decisions and forms the basis of the analysis. A threshold of >3xULN ALAT is generally considered to represent a clinically significant elevation. Lower cut-off levels are considered to be less informative due to the commonness of slight elevations in untreated populations. Therefore, ALAT values of >3xULN have been used to indicate a signal of potential clinical relevance.

 

 

 

 

2.6.3 ALAT elevation according to various thresholds

 

The distribution of patients with elevated ALAT according to various multiples of the upper limit of the normal range is shown by study for patients treated with ximelagatran in Table 27 and for patients treated with comparator in Table 26.  These tables present central laboratory data only.

 

Table 27      Cumulative incidence of ximelagatran-treated patients with elevated ALAT by study (ITT population) - Central laboratory data only

 


Table 28      Cumulative incidence of comparator-treated patients with elevated ALAT by study (ITT population) - Central laboratory data only

 


 

There was a higher incidence of ALAT elevation in ximelagatran –treated patients regardless of the threshold (xULN) and the effect was consistent across all studies.

 

Overall, approximately twice as many ximelagatran-treated patients experienced an ALAT elevation >ULN (30.0% vs 15.2%).  There were approximately 4 times as many ximelagatran-treated patients who experienced an increase in ALAT >2xULN (12.1% vs 2.9%) and this difference increased to 7-fold at >3xULN.  The additional data obtained from local laboratories did not affect the patterns seen in the Central laboratory data.  

 

2.6.4 Patients with ALAT>3xULN measured at the Central laboratory

 

The number of patients with an increase in ALAT >3xULN is presented for both ximelagatran and the comparators in Table 29.  

 

Table 29      Elevations of ALAT >3xULN (ITT population) - Central laboratory data only

 


 

In patients receiving long-term administration of ximelagatran (>35 days) an increase in ALAT >3xULN occurred in 6-13% (average 7.6%, 531/6948) compared to 0-2% (average 1.1%, 68/6230) of patients receiving comparator treatments.

 

The overall incidence of ALAT > 3xULN in SH-TPA-0002/4 after 2 years of treatment was 6.4% (12/187) in the ximelagatran group and 0% (0/67) in the warfarin group.  The incidence was comparable in the other 2 studies in AF patients, SH-TPA-0003 (6.3%) and SH-TPA-0005 (6.0%); the incidence in the warfarin group was 0.8% in both of these studies.  The incidence in both the ximelagatran group and the warfarin group was higher in VTE-T patients  (9.6% and 2.0%, respectively).  The higher incidence in the warfarin group may have been due to the enoxaparin given as part of the treatment regimen in the comparator group.  In the post ACS study, SH-TPC-0001, the incidence was notably higher in the ximelagatran  36, 48 and 60 mg dose groups (12 to 13%) but the incidence in the 24 mg group was similar to that seen in AF patients (6.5%).

 

There were a further 11 patients who had an ALAT elevation >3xULN recorded after study closure and are therefore excluded from the ITT analyses of these data.  These 11 patients comprised 9 patients in study SH-TPV-0002/5 (6 in the ximelagatran group and 3 in the enoxaparin/warfarin group) and 2 patients in study SH-TPC-0001 (1 in the ximelagatran 36 mg group and 1 in the placebo group).  Finally, Patient 012-205 in study SH-TPA-0004 had an ALAT elevation >3xULN after 2.5 years of treatment with ximelagatran.  This patient is not included in the analysis because only data up to 30 June 2001 (the date of the interim CSR ) from this ongoing study have been integrated in the safety database.

 

2.6.5 Time course of ALAT elevations

 

As shown in the previous section, 599 patients showed an ALAT elevation >3xULN during the studies, 531 patients in the ximelagatran group (cumulative incidence 7.6%) and 68 patients in the comparator group (cumulative incidence 1.1%).  Note that this is the central laboratory data only.  Including local laboratory data, 620 patients showed an ALAT elevation >3xULN during the studies, 546 patients in the ximelagatran group (cumulative incidence 7.8%) and 74 patients in the comparator group (cumulative incidence 1.1%).   

 

The time pattern of ALAT elevations was consistent.  The increase typically occurred between 1 and 6 months after the initiation of ximelagatran.  Before and after this time frame the incidence of ALAT increase was similar to comparators.  The divergence occurred largely up to 6 months and thereafter the additional increment was 1.0% for ximelagatran and 0.4% for comparators. Figure 1 shows the number of patients presenting for the first time with an increase in ALAT >3xULN during each month of treatment.

 

Figure 1: Number of new patients with ALAT >3xULN by month since randomization (ITT population): LTE pool – Central laboratory data only 

 


 

 

 

 

The figure shows the number of patients presenting with ALAT >3xULN for the first time and it should be noted that there were 6948 patients in the ximelagatran group and 6230 in the comparator group.  In the first month of treatment there was no difference in the incidence of ALAT >3xULN between ximelagatran (23 cases) and comparator-treated patients (25 cases).  The difference became significant at 2 months.  Of the 531 ximelagatran-treated patients who had ALAT >3xULN, 495 (93.0%) were detected during the first 6 months and 519 (97.7%) were detected within the first 12 months.  Beyond 12 months, few new patients presented with ALAT >3xULN.

 

Regardless of the magnitude of the ALAT increase examined, the time pattern was consistent. In the ximelagatran group, the majority of patients who experienced an elevation in ALAT presented between 2 and 4 months. Beyond 12 months the incidence of increased ALAT was similar to the comparators.

 

2.6.6 Recovery of elevated ALAT values towards normal

 

Among the 531 patients in the ximelagatran group who presented with an ALAT >3xULN, 206 (39%) completed the study on study drug.  The remaining 325 patients (61%) discontinued study drug prematurely. The analysis of the reduction of elevated ALAT toward normal is presented in Table 30. 

 

Table 30      Number of ximelagatran-treated patients with ALAT>3xULN, measured at the Central laboratory by magnitude of last recorded ALAT measurement (ITT population):  LTE pool

 


This table includes ximelagatran-treated patients who had an ALAT >3xULN recorded at the Central laboratory during the studies categorized by their maximal ALAT elevation (>3, >5 or >10xULN).  For each category, the number of patients who had a last recorded ALAT value of <1, <2, <3 or >3xULN, is shown.  The table is further subdivided into those patients who continued on study drug and those who stopped study drug.  For example, from the second column of the table it can be seen that 84 patients who had a maximal ALAT elevation of >3xULN but <5xULN, had returned to an ALAT <1xULN at their last recorded measurement, while continuing to take study drug.  From the penultimate column in the table it can be seen that 8 patients who had a maximal ALAT elevation of >10xULN, still had ALAT >3xULN at their last recorded measurement, having stopped taking study drug.  

 

Of the 531 ximelagatran-treated patients who had an ALAT elevation >3xULN recorded by the central laboratory, 502 (95%) had their ALAT return to <2xULN by the last measurement taken before the cut-off for this file.  So far, it is not possible to identify who the patients are that will not return to baseline. The mean number of days taken for ALAT to return to <2xULN was similar whether the patients continued to take ximelagatran or not (Table 31).

 

Table 31      Mean number of days between first ALAT elevation >3xULN (measured at the Central laboratory) to normalization for ximelagatran-treated patients (ITT population):  LTE pool

 


 

Most cases show a peak of ALAT within the first 2 to 3 months post-randomization and a decline back towards baseline within about 6 months post-randomization.  

 

The pattern of return to baseline or ULN was similar whether the patient discontinued study drug or not, and only sustained above ULN in a few cases.  

 

A total of 35 patients, 30 in the ximelagatran group and 5 in the comparator group, still had ALAT >2xULN at the last measurement (including local laboratory measurements). Of the 30 ximelagatran-treated patients, 11 died while their ALAT was still elevated; 3 patients had an alternative explanation for the raised LFTs (alcohol); 2 patients were lost to follow-up and one patient had a final ALAT measurement that according to the investigator had “decreased to a medically insignificant level”.  The remaining 13 patients continued under surveillance at the time of the cut-off for this file.  

 

2.6.7 Re-challenge to ximelagatran after temporary discontinuation of study drug with ALAT elevations

 

Eighteen patients who discontinued study drug with elevations of ALAT subsequently resumed treatment after ALAT had returned to the normal range. Of these 18 patients, 2 (Patient SH-TPA-0003-017-2619 and Patient SH-TPA-0005-370-5718) again experienced elevations of ALAT after drug was resumed.

 

2.6.8 Elevated ALAT by dose

 

Table 32 shows the cumulative incidence of ximelagatran-treated patients with elevated ALAT by dose in study SH-TPC-0001.  

 

Table 32     Cumulative incidence of ximelagatran-treated patients with elevated ALAT by dose in study SH-TPC-0001 (ITT population) 

 


There was not a marked dose response over the dose range 24 mg to 60 mg but there was a noticeably lower incidence of all multiples of ULN at the 24 mg dose compared to the higher doses.

 

2.6.9 Combination of ALAT and bilirubin elevation

 

The combination of transaminase and bilirubin elevation has been considered to predict the occurrence of severe injury in some patients.  The number of patients in each of the studies that contribute to the LTE pool who had an increase in total bilirubin >2xULN within one month following an increase in ALAT >3xULN are shown in Table 33.  

 

Table 33      Concomitant elevations of ALAT >3xULN and bilirubin >2xULN (ITT population) - Central laboratory data only

 


ALAT >3xULN was associated with bilirubin >2xULN (within one month following the rise in ALAT) in 0.4% (26/6948) of all patients who were exposed to ximelagatran >35 days as compared to 0.1% (4/6230) of patients exposed to comparators.

 

Additional ALAT and bilirubin data were obtained from tests performed at local laboratories. These included 11 new cases (10 ximelagatran, 1 comparator) who had an increase in bilirubin >2xULN within one month following an increased ALAT >3xULN.  One additional patient (#7859) described in the section of Deaths in ximelagatran-treated patients with ALAT >3xULN (see below) had bilirubin elevation > 5.6x ULN. This patient was not included in the sponsor’s analysis for combination elevation. Therefore, at the cut-off date for this file there were 37 such cases in the ximelagatran group and 5 in the comparator group (0.53% vs 0.08%).  The ximelagatran-treated patients who had an increase in total bilirubin >2xULN within one month following an increase in ALAT >3xULN are summarized in Tables below.

 

Table 34      List of ximelagatran-treated patients with concomitant elevations of ALAT >3xULN and bilirubin >2xULN – Central laboratory data only


 


Table 35      List of ximelagatran-treated patients with concomitant ALAT >3xULN and bilirubin >2xULN – local laboratory data only


 

Table 36      List of ximelagatran-treated patients with concomitant ALAT >3xULN and bilirubin >2xULN – local laboratory data only


 

Concomitant elevations of ALAT >3xULN and  bilirubin >2xULN were observed during the first month of ximelagatran therapy in 6 of 37 patients.

 

Two comparator-treated patients with concomitant ALAT >3xULN and bilirubin >2xULN died and both died from pancreatic cancer.

 

Nine ximelagatran-treated patients who died are presented here more in detail (including patient # 7859 who was missed by the sponsor for concomitant ALAT and bilirubin elevation analysis).

 

·        Patient 7259, an 80 year old male, began ximelagatran 36 mg bid treatment on 11 June 2001. He experienced elevated liver transaminases with biopsy-demonstrated hepatic necrosis and a fatal bleed due to a duodenal ulcer. The patient had a medical history of hyperlipidemia treated in the past with simvastatin until March 1999, AF since 1996, hydronephrosis probably related to an ectopic ureter insertion, urinary retention, fibromyalgia treated with prednisone in the past, coronary artery disease treated with bypass grafting in 1999, and right colon cancer diagnosed in 1999. Concomitant medications included Lopressor (metoprolol), digoxin, and Flomax (tamsulosin). On 30 May 2001, the patient's baseline liver function tests were normal with ALAT 16 U/L, ASAT 22 U/L, ALP 67 U/L and total bilirubin 0.9 mg/dL . On 6 August 2001, at the Month 2 Visit, his LFTs were mildly elevated, but less than the 3x ULN threshold that required discontinuation of study medication . At the next scheduled visit (4 September 2001) the transaminases were found to be further elevated (ALAT 970 U/L, ASAT 698 U/L, ALP 142 U/L), leading to weekly LFT monitoring and study drug discontinuation on 7 September 2001. Transaminases continued to increase. On 19 September 2001, ALAT and ASAT were 1502 U/L and 1355 U/L, respectively; ALP was 154 U/L; total bilirubin was 2.4 mg/dL (nearly twice the ULN) and direct bilirubin was 0.6 mg/dL. Serologies for hepatitis A, B, and C, cytomegalovirus, Epstein-Barr, and herpes simplex viruses did not show a recent viral infection. Carcino-embryonic antigen and antinuclear antibodies were negative. Abdominal ultrasound showed normal liver, normal gallbladder, normal biliary tree and 2 simple cysts in the right kidney. An abdominal and pelvic CT scan performed on 21 September 2001 showed no significant new findings compared to a prior examination (3 August 2000). Liver transaminases peaked on 27 September 2001 and then decreased on 4 October 2001. ALP peaked at 198 U/L on 3 October 2001 and decreased to 170 U/L on 4 October 2001. Total bilirubin was 10.7 mg/dL on 3 October 2001 and then decreased to 7.9 mg/dL on 4 October 2001. Prothrombin time (13.6 sec) and INR (1.2), which were close to normal on hospital admission (20 September 2001) started to increase on 1 October 2001, reaching16.3 sec and 1.7 respectively. Conversely, albumin decreased to 2.9 g/dL on 2 October 2001. This laboratory profile suggested impairment of his synthetic liver function. A liver biopsy performed on (27 September 2001) demonstrated "severe active hepatitis with hepatocyte necrosis, areas of collapse and marked bile ductular proliferation consistent with acute submassive necrosis." The hepatologist considered the most likely explanation was medication-induced hepatitis. INR remained elevated (1.8 on 8 October 2001) and serum albumin low (2.5 g/dL on 8 October 2001). platelet count was 65,000/mm3 (29 October 2001). Profound fatigue continued with no evidence of encephalopathy. However, he had developed ascites, significant lower extremity edema and oliguria. On the morning of 3 November 2001, the patient's wife found him unresponsive at home. Resuscitation failed and the patient was pronounced dead. The cause of death was upper GI bleed due to duodenal ulcer. An autopsy confirmed the presence of atherosclerotic disease, ischemic heart disease with triple CABG and atrial septal defect repair; adenocarcinoma of the colon resected with no evidence of recurrence or metastatic disease, and left hydronephrosis with no evidence of mechanical obstruction. The significant findings were: A large duodenal ulcer (2.5 cm) with erosion into pancreas and peripancreatic soft tissue and hemorrhagic contents through most of the small intestine with intact bowel. A small, friable and diffusely mottled liver suggestive of severe diffuse hepatic necrosis. Microscopically, there was extensive liver necrosis with hepatocyte dropout and bile duct proliferation, similar to that seen in the previous biopsy. A significant amount of hepatic parenchyma remained. Tissue architecture showed early resolution of the inflammation compared to the previous biopsy. There was serous ascites in the abdomen. The spleen was not enlarged. Moderate reduction of megakaryocytes in bone marrow. The cause of death was an acute gastrointestinal bleed from a duodenal ulcer, with a coagulopathic state from hepatic injury contributing to death. Both decreased clotting factors and platelet reduction cause the coagulopathy, the latter related to a decreased number of megakaryocytes in the bone marrow. The autopsy report speculated that prednisone therapy may have caused the duodenal ulcer and decreased synthesis of thrombopoietin by the liver could have played a role in the thrombocytopenia. The investigator assessed the event of liver failure as being related and the event of fatal bleed due to duodenal ulcer as not related to the study medication.

 

 

·        Patient 5442 was a 73 year old male Caucasian. Relevant medical history included diabetes mellitus, systemic lupus erythematosus, hypertension, heart disease, gastric ulcer, COPD and cardiac arrhythmia. The reason for entering the study was DVT. The patient received 36 mg Ximelagatran b.i.d. Transaminases were slightly increased (ASAT 60 U/l; ALAT 60 U/l; AP 210 U/l), nine days after start of study medication, but this was thought to be due to the known lupus erythematosus which was otherwise not active (titer of antinuclear antibodies > 1:80, i.e. normal). Eighteen days after commencing study medication, the patient experienced hepatitis type B and was hospitalized. Hepatitis serology had been done six days before admission because of rising transaminases and showed HBs antigen, HBc antibody and HBe antigen 2 positive, while HBs antibodies, hepatitis C virus antibodies, HBe antibodies, HAV-Ak-IgM and HBc-Ak-IgM were all negative. From this constellation with absence of antibodies an acute hepatitis B was diagnosed. With regard to the normal incubation time, infection had probably occurred before inclusion into the study, but a plausible source of infection could not be detected. Transaminases continued to rise. Four days after hospitalization, ASAT was 354 U/l, ALAT 367 U/l, AP 292 U/l and G-GT 54 U/l. LDH had increased to 360 U/l and bilirubin was 1.8 mg/dl. Two days later study medication was withdrawn. The patient's general condition was good, without signs of hepatic encephalopathy or failure. Two days after withdrawal of study medication, ASAT was 593 U/l, ALAT 518 U/l and bilirubin 4 mg/dl. The next day the patient was transferred to an infection treatment unit. The patient began to develop icterus and bilirubin tests taken ten days, 15 days and 19 days after onset, showed a rapid increase to 8 mg/dl, 17.2 mg/dl and 26.8 mg/dl, respectively. Transaminases meanwhile decreased slightly. Eleven days after onset of the event, the patient complained of nausea and pain in his right flank. Five days later, a gastroscopy performed showed multiple gastric ulcers covered with fibrin, but no signs of acute bleeding. Quick value, which had been around 40% before, dropped to 29 % with an international normalized ratio of 2.3. ASAT value was 287 U/l and ALAT was 189 U/l approximately three weeks after onset. Therapy consisted of low molecular heparin, oral iron substitution, pantoprazole, metoclopramide, lactulose, prednisolone, amino acid infusions and amoxicilline + clavulanic acid. The patient's general condition deteriorated. Abdominal computerized tomography performed 18 days after onset, showed beginning formation of ascites. On that day the patient complained of vertigo and nausea and felt very tired. The next day repeated enuresis was reported. Agitation, signs of hepatic encephalopathy and tarry stools appeared three weeks after onset. During the next two days the patient deteriorated dramatically. All therapy was stopped because of poor prognosis. The patient became comatose and died from hepatic failure two days later. Autopsy was not performed. All attending doctors agreed that the cause of death was fulminant hepatitis B, but it seemed debatable whether this was an acute condition or an exacerbation of a chronic disease that had already been present in 2001, but had been masked by the immunosuppressive therapy for lupus erythematosus. Azathioprine induced hepatotoxicity is another aggravating factor under discussion. The investigator considered there was a reasonable possibility that the event may have been caused by study medication.

 

 

·        Patient 3963 was a 45 year old Caucasian. Relevant medical history included constant atrial fibrillation, left heart failure, congestive cardiomyopathy, chronic bronchitis, paroxysmal ventricular tachycardia and an automatic implantable cardioverter/defibrillator. Pre-study stroke prophylaxis consisted of warfarin. As study treatment the patient was allocated to receive ximelagatran 36 mg b.i.d. Approximately 28 weeks after commencing study medication the patient was hospitalized with dyspepsia, nausea, vomiting, increased weight and girth. In addition the pacemaker had been activated three times for the last few days because of ventricular tachycardia. The condition was consistent with deterioration of congestive heart failure with increased right heart failure, peripheral edema and possible liver enlargement. Blood samples including liver enzymes were taken. An ultrasound of the liver showed severe intra-abdominal obesity and fatty liver. The slightly increased liver enzymes were assessed due to hypoperfusion and liver stasis. The patient's treatment with diuretics and antiarrhythmics was adjusted after which the condition stabilized. The day before the planned discharge, the condition aggravated acutely with cardiogenic shock. The patient was transferred to another hospital where in spite of maximum inotropic support, the patient died. The patient died approximately nine days after the onset of the event. Cause of death was cardiac failure and shock. An autopsy has not been performed. The investigator considered there was no reasonable possibility that the events may have been caused by study medication. Additional safety surveillance resulted in the following information: Approximately 6 months from start of study drug (day 190), elevated LFTs were noted by the central laboratory: ALT 4.81 x ULN, AST 4.33 x ULN, ALP 1.98 x ULN and Bil 2.77 x ULN. Repeat sampling on day 203 showed ALT 1.31 x ULN, AST 1.17 x ULN, ALP 1.36 x ULN, and Bil 1.77 x ULN. At this time point the patient was re-hospitalized with deterioration of congestive heart failure, as described above.

 

 

·        Patient 0430 was a 90 year old Caucasian. Relevant medical history included hypertension, myocardial infarction, diabetes, lumbar pain, insomnia and bronchopneumopathy. The reason for entering the study was an acute coronary syndrome with a peak Troponin I value of 0.44 (ULN=0.04). The patient received ximelagatran 24 mg b.i.d. and ASA 160 mg o.d. After four weeks on study drug the patient developed right cardiac failure which was considered non-serious. After 17 days the event was considered medically important and the patient was hospitalized. He presented with bilateral lower leg edema and jugular turgescence. The patient was hospitalized for worsening of right cardiac failure after 16 weeks on study drug. He presented with edema. Study drug was withdrawn (total study drug treatment was 18 weeks) and the patient died from right cardiac failure 3 days after stop of study drug. No autopsy was performed. The investigator considered that there was no reasonable possibility that the events may have been caused by study medication or by other medication. Additional safety surveillance resulted in the following information: Four and a half months from start of study drug (day 132) elevated LFTs were noted by the central laboratory: ALT 4.42 x ULN, AST 6.35 x ULN, ALP 4.30 x ULN, and Bil 2.23 x ULN. ALT had been slightly increased at start of study drug (1.33 x ULN), but was normal from day 8 until day 132. ALP was elevated throughout the study with a peak at the last sampling on day 132. Bil was slightly elevated from day 84. The patient experienced a minor conjunctival bleeding 11 days prior to the ALT elevation and muscular pain 4 days prior to the ALT elevation. As described above, the patient also had hematuria followed by worsening of right cardiac failure with fatal outcome at the time of the ALT elevation.

 

 

·        Patient 2893 was a 66 year old Caucasian. Medical history included paroxysmal atrial fibrillation, angina pectoris, myocardial infarction, chronic obstructive airways disease, cholelithiasis and hypercholesterolaemia. Pre-study stroke prophylaxis consisted of warfarin. As study treatment the patient was allocated to receive ximelagatran 36 mg b.i.d. Approximately 40 weeks after commencing study medication, the patient experienced abdominal pain and nausea. The patient was hospitalized and hepatic colic was diagnosed. After one week in hospital he also experienced severe heart failure. This event lasted only one day. The patient remained in hospital. One week after the episode with severe heart failure the patient had symptoms of ventricular tachycardia. He was treated with DC shock and xylocaine. He was discharged from hospital after five weeks, and was recovered from all events at that time. Study drug continued unchanged. Approximately one year and seven weeks after start of study drug the patient suffered from eruption of erysipeloid. He was hospitalized one week later and treated with ciprofloxacin. During the hospitalization stay, approximately one month after he was admitted the patient suffered from abdominal pain due to cholelithiasis. The clinical condition deteriorated and he died the next day. Cause of death was cardiac arrest. The investigator suggested that the abdominal pain surcharged the heart and thereby caused the cardiac insufficiency. There was no action taken regarding study drug prior to the death. The investigator considered there was no reasonable possibility that the events may have been caused by study medication. Additional safety surveillance resulted in the following information: Local ALT peak was 18.4 x ULN at day 287, but ALT never exceeded 3 x ULN in central labs.

 

 

·        Patient 1793 was a 69 year old Caucasian. Relevant medical history included constant atrial fibrillation and unspecified essential hypertension. Pre-study stroke prophylaxis consisted of warfarin. As study treatment the patient was allocated to receive ximelagatran 36 mg b.i.d. Approximately 34 weeks after commencing study medication, the patient experienced dyspepsia, icterus and weight loss. The patient was hospitalized. Study medication was withdrawn due to the event icterus. Metastases in liver were discovered. During the hospital stay approximately 12 days later malignant neoplasm was discovered in the stomach. Computed tomography, sonogram and laparotomy were performed. The patient was given symptomatic treatment. Nine days after the operation the patient suddenly died. An autopsy was performed which confirmed the cause of death as pulmonary embolism. The investigator considered there was no reasonable possibility that the events may have been caused by study medication. Additional safety surveillance revealed the following information: Approximately eight months from start of study drug (day 237) elevated LFTs were noted by the central laboratory: ALT 3.56 x ULN, AST 2.51 x ULN, ALP 3.54 x ULN, and Bil 5.00 x ULN. No further central labs were obtained for reasons described above.

 

 

·        Patient 2065 was a 51 year old Caucasian. Relevant medical history included sleep apnoea. The reason for entering the study was an acute coronary syndrome with a peak CKMB value of 331 (ULN=3). The patient received ximelagatran 60 mg b.i.d. and ASA 160 mg o.d. After three weeks and five days on study drug treatment the patient had icterus. A liver ultrasound was performed showing a 4 times 4 cm large tumor in the pancreatic gland. Bilirubin was 141 (normal range 4-21), ALP was 10.2 (normal range 0.8-4.6) and ALAT was 11.2 (normal range < 0.80). Study drug was withdrawn. The patient was discharged after two weeks and six days. Six weeks after stop of study drug the patient had visual field loss. A CT-scan of the brain was done. Treatment with heparin fraction was given. According to available information the event was still present when the patient died. Two weeks and six days later the patient was again hospitalized due to worsening symptoms of his pancreatic tumor with liver metastasis. Ultrasound showed ascites, which was evacuated. No chemotherapy was given during this hospitalization. He was discharged after one week and four days. The patient died at home three days later because of his cancer. The investigator considered that there was no reasonable possibility that the events had been caused by the study medication. Additional safety surveillance resulted in the following information: Expressed as multiples of ULN, ALT peak value was 11.81 x ULN at day 34, which was 8 days after study drug had been stopped. At day 40 ALT was 4.79 x ULN, AST 2.02 x ULN, ALP 2.35 x ULN, and Bil 12.45 x ULN. No further central labs were obtained before death.

 

 

·        Patient 4035 was a 76 year old Caucasian. Relevant medical history included previous VTE event, hypertension, parkinsonism, pyeloglomerulonephritis and coronary disease. The reason for entering the study was DVT. The patient received ximelagatran 36 mg b.i.d. Fifteen weeks after start of study drug the patient was hospitalized due to melaena, decreased haemoglobin and anaemia. HB was 8.6. Bleeding from the digestive tract was suspected. Study drug was permanently stopped. Blood transfusion (two units of blood) was given. Gastroscopy was normal. The patient recovered from the bleeding and was discharged from hospital one week after start of event. Hb was now 12.0 (normal for this patient). Two weeks after discharge from hospital colonoscopy and ultrasonography were done that revealed adenocarcinoma of colon. Four weeks after stop of study drug the patient was hospitalized for operation of colon adenocarcinoma and liver metastases in the right liver lobe. Resection of sigmoideum and right liver lobe were done. After six days X-ray of abdomen showed fluid levels. An abscess of the anastomosis was diagnosed and he was re-operated. Four days later a multiorgan failure developed diagnosed with abdominal ultrasound and x-ray. The patient was treated with antibiotics, fluid, enoxaparin, blood, plasma and digoxin. He died the same day and the probable cause of death was the multiorgan failure. The investigator considered there was a reasonable possibility that the event bleeding from digestive tract may have been caused by study medication, but that there was no reasonable possibility that the events adenocarcinoma, liver metastases, abscess of anastomosis and multiorganic failure may have been caused by study medication.

 

·        Patient 7859 (not included in the sponsor’s concomitant ALAT and bilirubin elevation analysis) was a 77 year old Caucasian and initiated on ximelagatran 36 mg bid treatment on 13 August 2001. Past medical history included a cholecystectomy, duodenal ulcer, sick sinus syndrome, pacemaker insertion, hypertension, carotid stenosis, abdominal aortic aneurysm repair (13 April 2001), and coronary artery disease. On 15 October 2001 (day 63), safety laboratory results demonstrated elevated liver transaminases: ALAT 216 U/L, ASAT 154 U/L; ALP was 156 U/L and total bilirubin 1.3 (baseline 1.1) mg/dL. He took his last dose of study medication in the evening on day 80. The next day (on 2 November 2001), the patient awoke with stomach pain and light-headedness. Bowel movements produced bloody stools. He was admitted to hospital that same morning. At admission, he had pallor, blood pressure 76/45 mm Hg, and heart rate 103/min. Laboratory tests showed hemoglobin of 7 g/dL, hematocrit 20%, prothrombin time 37 sec, INR 3.4, aPTT 69 sec, albumin 2 g/dL, ASAT 629 U/L, ALAT 569 U/L, ALP 173 U/L and plasma melagatran was 0.25 mM (therapeutic range). During hospitalization, he received vitamin K, packed red blood cells (19 units), fresh frozen plasma (15 units), cryoprecipitate (30 units) and fluids. On 03 Nov laboratory tests showed hemoglobin of 9.6 g/L, hematocrit of 27.3%, prothrombin time 14.5 secs, aPTT 53 secs and INR 1.1. Liver enzymes also decreased: ALAT 134 U/L, ASAT 236 U/L and ALP 49U/L, but bilirubin was 6.2 (5.6x ULN). The patient underwent a gastroscopy that revealed a Bilroth II anastomosis. There was bleeding in the pre-anastomotic area and epinephrine was injected to attempt to decrease the bleeding. The same day (3 November 2001) he presented with signs of respiratory failure. Echocardiogram showed 55% left ventricular function and no major cardiac abnormalities. However, heart rate was 130 to 140/min. Vasopressors were necessary to sustain blood pressure and diltiazem was given to decrease the heart rate. Synchronized cardioversion failed 4 times to establish sinus rhythm. Shock persisted despite resuscitation with fluids, 2 units of packed RBC, 10 units of fresh frozen plasma and 1 unit of platelets. Profound coagulopathy occurred. A consulting surgeon deemed operation futile. Support was subsequently withdrawn and the patient died on 3 November 2001. No autopsy was conducted but the cause of death was considered to be hemorrhage. The investigator assessed the event as possibly related to the study medications and concluded that the liver problems contributed to the bleeding.

 

2.6.10 Deaths in ximelagatran-treated patients with ALAT >3xULN 

 

The number of deaths in ximelagatran-treated patients having maximum ALAT >3xULN is 19 (3.6%, 19/531) and in patients having maximum ALAT <3xULN is 251 (251/6417, 3.9%) for central laboratory ITT population.   There was no apparent difference in the incidence of death between ximelagatran-treated patients who experienced an increase in ALAT >3xULN (3.6%) and those who did not (3.9%).

 

In addition to the 19 patients (19/531, 3.6%) who had ALAT >3xULN measured at the Central laboratory subsequently died, an additional patient died after study closure and is therefore not counted in the ITT analysis and a further 3 patients who had ALAT >3xULN measured at a local laboratory subsequently died.  Therefore, a total of 23 patients who had ALAT >3xULN subsequently died. The one individual who had an hepatic SAE leading to death was Patient SH-TPV-0002-265-5442 (see details above).  ALAT was elevated 12 days after starting study medication and he died 6 days thereafter from an acute hepatitis B rapidly evolving to fulminant hepatitis.  This pattern of ALAT elevation was not consistent with the previously observed pattern of elevations in patients exposed to ximelagatran.  Although ximelagatran was not the cause of the infectious hepatitis, the investigator could not rule out the possibility that it aggravated the outcome.  Two other patients who died due to GI hemorrhage with severe coagulopathy had elevated hepatic enzymes prior to death; both cases (patient 7259 and 7859) were described above. Clearly, coagulopathy was due to ximelagatran and it aggravated and contributed to these 2 patients’ deaths.

 

Patients who had ALAT >3xULN measured at the Central laboratory and subsequently died are presented in Table 37.

 

 

 

 

 

 

Table 37: List of ximelagatran-treated patients who had ALAT >3xULN measured at the Central laboratory and subsequently died


 

 

An additional patient died after study closure and is therefore not counted in the ITT analysis. Patient SH-TPC-0001-062-0286, an 82 year old female, died from AMI 2 weeks after stopping study drug (ximelagatran 36 mg bid) due to a previous AMI.

 

A further 3 patients who had ALAT >3xULN measured at a local laboratory subsequently died.  These were as follows:

 

Patient SH-TPA-0005-0050-8357, a 74-year-old female, died from sepsis while taking ximelagatran 36 mg bid, and the temporary ALAT elevation was found during a previous hospitalization for pneumonia.

 

Patient SH-TPA-0003-217-2893, a 67-year-old male, died while taking ximelagatran 36 mg bid due to acute cholecystitis and cardiac arrest.  The reported SAE term was abdominal colic.

 

Patient SH-TPV-0002-504-4035, a 76-year-old male, died due to multiorgan failure.  The patient had been hospitalized for operation of colon adenocarcinoma and liver metastases in the right liver lobe, 4 weeks after stop of study drug (ximelagatran 36 mg bid).

 

Seven of 19 cases (#1793, 3963, 7259, 7859, 5442, 0430 and 2065) have been discussed above in detail. Patient 2826 died from rupture of aorta and patient 6603 died 16 months after discontinuing study drug.

 

2.6.11 Potential prognostic factors related to ALAT >3xULN.

 

The multivariate analysis of potential prognostic factors for the risk of ALAT>3xULN was

performed using a logistic regression model with a stepwise selection algorithm. The following factors were tested for inclusion; sex (female vs male), age, (>=75 vs <75 years), weight (>=75 vs <75 kg), BMI (>=27 vs <27 kg/m2), CrCL (>=80 vs <80 mL/min), ethnic origin (Asian vs rest, i.e. all others), concomitant aspirin use (yes vs no), concomitant statin use (yes vs no), and patient population (VTE-T vs rest, VTE-P vs rest and Post ACS vs rest, AF was used as "baseline"). Stepwise analyses are presented in Table 38 (for patients in the ximelagatran group only).

 

Table 38: ALAT >3xULN, analysis of potential prognostic factor, stepwise model

selection algorithm, (ximelagatran group only) (ITT population): LTE pool

 


From these analyses 6 risk factors were statistically significant for the ximelagatran group:

Post ACS population (p=0.0009), VTE-T population (p=0.0003), use of statins (p=0.019),

BMI <27 kg/m2 (p<0.0001), non-Asian race (p=0.0038) and female sex (p=0.0002, 9.4% vs. 6.7%).

 

2.6.12 Relationship between exposure to melagatran and ALAT elevation.

 

Exposure to melagatran has been evaluated in patients in the non-surgical long-term studies.  Individual melagatran AUCs were estimated by population PK modeling.  The distribution of melagatran AUC in patients with an event is largely within the melagatran AUC range in patients without an event.  These data suggest that for the patient population and doses studied exposure is not predictive of ALAT >3xULN in individual patients.

 

The calculated cumulative risk (hazard ratio) of an increase in ALAT for each unit increment of AUC, in each pool, is shown in Table 39.  Except for the VTE-P and post ACS pools, there is a statistically significant relationship between exposure and the risk of an ALAT elevation above 3xULN in each pool.

 

Table 39 Relationship of melagatran AUC to occurrence of ALAT elevation >3xULN


 

2.6.13 Summary of hepatobiliary toxicity

 

In patients receiving long-term administration of ximelagatran (>35 days) an increase in

ALAT >3xULN occurred in 6-13% (total: 531/6948, 7.6%) compared to 0-2% (total: 68/6230, 1.1%) of patients receiving comparator treatments. ASAT increased in conjunction with ALAT. The time pattern of ALAT elevations was consistent and typically occurred between 1 and 6 months after the initiation of ximelagatran. Prior to and after this time frame the incidence of ALAT increase was similar to comparators. These data are based on ALAT sampling in 6840 patients.

 

Among the 531 patients in the ximelagatran group who presented with an ALAT >3xULN, 206 (39%) completed the study on study drug.  The remaining 325 patients (61%) discontinued study drug prematurely. The hepatic transaminases returned to <2xULN in the majority of patients (95%), whether the patient continued treatment with ximelagatran or not.

 

An evaluation of potential risk factors for increase in ALAT indicated an increased risk in the

Post ACS (p=0.0009), and VTE-T (p=0.0003) populations and also in female patients (p=0.0002) patients with low BMI (<27 kg/m2) (p<0.0001) and patients receiving concomitant treatment with statins (p=0.019); Asian patients were found to have a decreased risk (p=0.0038). Although any single factor identified above may not be strong enough to justify to excluding the subgroup population, the patients who have 2 or more risk factors should not be given ximelagatran, such as, female patients with low body weight or who are taking statin.

 

ALAT >3xULN was associated with bilirubin >2xULN (within one month following the rise in

ALAT) in 0.53% (37/6948) of all patients who were exposed to ximelagatran >35 days as compared to 0.08% (5/6230) of patients exposed to comparators (including 10 ximelagatran and 1 comparator by local laboratory measurement). A total of 14 ximelagatran-treated patients (14/37, 35.1%) have no alternative explanation for concomitant ALAT and bilirubin elevation. Concomitant elevations of ALAT >3xULN and bilirubin >2xULN were observed during the first month of ximelagatran therapy in 6 of 37 patients. Nine of the ximelagatran-treated patients who had ALAT >3xULN and bilirubin >2xULN (24.3%, 9/37) died with these elevations. Among them, 3 died from heart failure; 3 died from carcinomas with hepatic matastases; 2 (ID# 7259, and 7859) died from GI bleeding with coagulopathy and 1 (ID# 5442) died from hepatitis B. One patient developed biopsy documented hepatic necrosis with coagulopathy with a fatal outcome from a duodenal ulcer (#7259). Liver failure/toxicity by ximelagatran might have caused or at least contributed to these deaths.

 

In conclusion, safety data on hepatobiliary toxicity does not support the safe use of ximelagatran for long-term (>35 days) treatment of patients with AF or DVT for either 36 mg bid or 24 mg bid dosing.

 

2.7      Analysis of adverse events of pancreatic effects

 

Pancreatic hyperplasia has been observed in pre clinical studies in rats. A “pancreas sub-study” was performed as part of study SH-TPA-0005 to determine if there was a safety concern for ximelagatran regarding pancreatic hyperplasia.  CCK plasma concentrations were measured after approximately 3 months of receiving study drug in a subset of patients.  The objective of this assessment was to determine whether ximelagatran was associated with elevations in plasma CCK after a standard meal because this is the mechanism by which rats undergo pancreatic trophic stimulation, possibly leading to pancreatic adenomas and occasionally, pancreatic carcinoma.  In addition, special abdominal CT scans were performed, which were designed to measure pancreas volume, obtained prior to drug exposure and then again after 12 months’ exposure to study drug.  The objective of this assessment was to determine whether long-term administration of ximelagatran was associated with increased pancreas volume because a trophic effect on pancreas would yield increased volume of pancreatic tissue.

 

2.7.1 CCK in plasma – laboratory findings

 

A total of 130 patients (62 ximelagatran, 68 warfarin) were enrolled in the CCK subset, of whom 119 (56 ximelagatran, 63 warfarin) provided CCK plasma data at 3 months.  Mean (SD) CCK plasma concentration was 14.97±18.32 picomolar for the ximelagatran-treated patients and 11.39±16.51 picomolar for the warfarin-treated patients.  Median CCK plasma concentration was 6.63 (range 2.00 to 62.50) picomolar for the ximelagatran-treated patients and 4.50 (range 2.00 to 62.50) picomolar for the warfarin-treated patients.  There was no statistically significant difference in the plasma concentrations between the 2 groups,  p=0.225 (Mann-Whitney test).  The data were not normally distributed and no transformations were applied and hence the Mann-Whitney test was used. 

 

2.7.2 Pancreas volume – laboratory findings

 

Complete sets of pancreatic CT scans were available for a subset of 34 patients in the ximelagatran group and 28 patients from the warfarin group.  The mean ±SD change from baseline in pancreatic volume was -10.85±13.63 for the ximelagatran group and  -10.49±13.85 for the warfarin group and was statistically significant for both treatment groups (p=0.0001 and 0.0004, respectively).  However, the between group comparison was not statistically significant, p=0.92 (Student’s t-test).  Pancreatic volume change over one year did not correlate with CCK plasma concentration at 3 months.  Treatment, CCK, and treatment-CCK interaction did not affect pancreatic volume.

 

2.7.3 Analysis of AEs affecting the pancreas:  long-term exposure (LTE) pool

 

During the program, 13 patients (2 ximelagatran, 11 comparator) were diagnosed with a pancreatic cancer. Fifteen patients developed pancreatitis during active treatment in the program (6 ximelagatran, 9 comparator). A further 2 patients had an AE of pancreatitis in the follow-up period, one after treatment with ximelagatran (SH-TPA-0003-096-2960) and one after treatment with warfarin (SH-TPA-0005-2690-7288).

 

Taking into account both the AE profile and the sub study data, there is no safety concern for ximelagatran regarding pancreatic events.

 

2.8 Analysis of adverse events of coronary artery disease

 

Patients with coronary artery disease (CAD) adverse events are summarized in Table 40.

 

Table 40: Summary of patients with adverse events of coronary artery diseases (safety population)

 Population with

  CAD AE

Ximelagatran

(AF, n= 3836)

(VTE-T, n=1236)

(VTE-P, n=612)

n                   %

Warfarin

(AF, n= 3719)

(VTE-T, n=1248)

(VTE-P, n=611 placebo)

n                  %

p-value

AF:        Total CAD

                   MI

268                            7.0

62                1.6

248                                6.7

52                  1.4

P=0.584

VTE-T   Total CAD

                   MI

16                                  1.3

3                   0.2

1                                        0.1

    0                    0

P=0.00024

VTE-P   Total CAD

                   MI

16                                  2.6

10                 1.6

12                                    2.0

3                    0.5

P=0.447

P=0.05131

VTE       Total CAD

                   MI

32                 1.7

13                 0.7

13                  0.7

  3                    0.16

P=0.00411

P=0.01183

VTE=VTE-T + VTE-P

 

 

In all study populations except the post ACS, the proportion of patients with coronary artery disease adverse events was higher in the ximelagatran groups than in the comparator groups (7.0% and 6.7% for the AF pool, 1.3% and 0.1% for the VTE-T pool and 2.6% and 2.0% for the VTE-P pool, for the ximelagatran and comparator groups, respectively).  This trend was consistent across the pools for myocardial infarction; however, the difference in event rates (%/patient year) was small (0.9% and 0.6% for the AF pool,  0.6% and 0% for the VTE-T pool and 1.1% and 0.2% for the VTE-P pool, for the ximelagatran and comparator groups, respectively). Proportion of patients with coronary artery disease adverse events was statistically significantly higher in the ximelagatran group (32/1848, 1.7%) than in the warfarin/placebo group (12/1859, 0.7%) in VTE (VTE-T + VTE-P) population (p=0.00411). Proportion of patients with MI was also significantly higher in the ximelagatran group (13/1848, 0.7%) than in the warfarin/placebo group (3/1859, 0.16%) in VTE population (p=0.01183). There were no appreciable differences between the treatment groups for underlying diseases including hypertension, hypercholesterolemia, diabetes mellitus, coronary atherosclerosis, as well as age, gender and weight. Considering ximelagatran as an anticoagulant with potential to treat MI, these results are worrisome.

 

 2.9 Clinical Laboratory Evaluations

 

The analyses of clinical laboratory data in the individual studies in this application have not identified any adverse findings with the exception of increases in LFTs.  

 

Microscopic hematuria was more common in the ximelagatran group than in the placebo group in the post ACS pool; however, in the warfarin comparison pools there was no difference.

 

A reduction in triglycerides, cholesterol and LDL was seen in the ximelagatran group in the AF pool.

 

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