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:
Date received:
Review completed:
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............................................................................................ 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.
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
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.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
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.
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.
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.
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.
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.
According to the sponsor’s report, ximelagatran has
following PK/PD profiles.
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.
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).

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