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 GardasilTM : Quadrivalent
Human Papillomavirus 6, 11, 16, 18 L1 VLP Vaccine

Applicant: Merck & Co., Inc.

  • Vaccines and Related Biological Products Advisory Committee Meeting
  • May 18, 2006


  • Nancy B. Miller, M.D.
  • CBER, FDA



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Review Team
  • Chairperson: Gopa Raychaudhuri, Ph.D.
  • Regulatory Coordinator: Julienne Vaillancourt, R.Ph., M.P.H.
  • Clinical: Nancy Miller, M.D.
  •                                                Joseph Toerner, M.D., M.P.H.
  •                                                Karen Goldenthal, M.D.
  •                                                Antonia Geber, M.D.
  •                                                Douglas Pratt, M.D., M.P.H
  • Statistical: Henry Hsu, Ph.D., M.P.H.
  •                                                Lev Sirota, Ph.D.
  •                                                A. Dale Horne, Dr.Ph.
  • Product: Robin Levis, Ph.D.
  •                                                Rolf Taffs, Ph.D.
  •                Gennady Rezapkin, Ph.D.
  •                Loris McVittie, Ph.D.
  •                                                 Jerry Weir, Ph.D.
  • Non-Clinical: Sally Hargus, Ph.D.
  •                                               Marion Gruber, Ph.D.
  • Pharmacovigilance:            Hector Izurieta, M.D.
  • Robert Ball, M.D., M.P.H.
  • Bioresearch Monitoring: Robert Wesley
  • Facility:             Susan Yu, Ph.D.
  •                       Laurie Norwood, Ph.D.
  • Advertising/Promotional Labeling:      Maryann Gallagher



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Gardasil: Description
  • Each 0.5 mL dose contains
    • 20 mcg HPV 6 L1 VLP
    • 40 mcg HPV 11 L1 VLP
    • 40 mcg HPV 16 L1 VLP
    • 20 mcg HPV 18 L1 VLP
    • Adjuvant: 225 mcg aluminum
  • Administered 0, 2, and 6 months IM


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Gardasil:
Applicant’s Proposed Indications (1)
  • Prevention of HPV 16/18 related:
    • Cervical cancer
    • Cervical AIS
    • CIN 2 and CIN 3
    • Vulvar and vaginal cancer
    • VIN 2 and VIN 3
    • VaIN 2 and VaIN 3
  • Prevention of HPV 6/11/16/18 related:
    • CIN grade 1
    • Genital warts (condyloma acuminata)
    • VIN grade 1 and VaIN grade 1
    • HPV infection
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Gardasil:
Applicant’s Proposed Indications (2)


  • Children and adolescents 9 through 17 years of age and women 18 through 26 years of age.


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Gardasil:
FDA Proposed Indications
  • FDA considers the data submitted in the BLA to be supportive of use of Gardasil in preadolescent and adolescent females 9-17 years of age and females 18-26 years of age.
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Regulatory History
  • 1997:  Submission of IND for monovalent HPV 11 L1
    • VLP vaccine (Other INDs for monovalent HPV 16 and 18)
  • 2000:  Submission of IND for quadrivalent HPV 6, 11, 16, 18 L1 VLP vaccine
  • 2001 (November):  VRBPAC discussion of endpoints for Phase 3 development
  • 2002:  Product development program granted fast track status; Initiation of Phase 3 trials
  • 2005 (May):  Pre-BLA meeting, agreement to allow rolling BLA and Priority Review
  • 2005 (August):  Start of rolling BLA submisssion
  • 2005 (December):  Last section of rolling BLA received including Phase 3 study data; 6 month priority review
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Efficacy Endpoint for Preventive HPV Vaccines (Cervical Cancer)

  • November 2001 VRBPAC:
  •    CIN 2/3 histology, AIS, or worse with virology.
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Phase I/II Safety and Immunogenicity Studies
  • 001:  HPV 11 L1 VLP Vaccine
  • 002:  HPV 16 L1 VLP Vaccine
  • 004:  HPV 16 L1 VLP Vaccine
  • 006:  HPV 18 L1 VLP Vaccine


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Gardasil BLA:  Protocols Contributing to Combined Efficacy Analysis
  • 005:  “Proof of Concept” Phase II Efficacy     Trial (HPV 16)
  • 007:  Quadrivalent Dose-Ranging and       Efficacy Study
  • 013:  CIN/Warts Efficacy Study
  • 015:  CIN 2/3 Efficacy Study
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Gardasil:
Protocol 013 Substudies

  • 011:  Hepatitis B Concomitant      Use Substudy


  • 012:  HPV 16 Bridging Substudy
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Immunogenicity and Safety Studies in Adolescents

  • 016:  Adolescent/Adult Bridging and      End-Expiry Study


  • 018:  Adolescent Immunogenicity and      Safety Study


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Comparison of Study Design:
Protocols That Contribute to Combined Analysis
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Comparison of Study Design:
Baseline Characteristics of Subjects
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Comparison of Study Design:
Pap Tests and Referral for Colposcopy
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Comparison of Study Design:
Triage Abnormal Pap Tests for Colposcopy
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Comparison of Study Design:
Laboratory Tests, Pathology Panel
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Comparison of Study Design:
 Number of Subjects, Median Age, and Duration of Follow-up In Efficacy Population
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Number of Subjects Enrolled:
Distribution by Protocol and Region
(Efficacy Population)
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Subjects Excluded from Efficacy Analysis
Because of Baseline HPV Status
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Role of Baseline HPV Status and Endpoint Counting for Prophylactic Vaccine Efficacy Analyses
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Role of Baseline HPV Status and Endpoint Counting for Prophylactic Vaccine Efficacy Analyses
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Efficacy Analysis Populations (1)
  • Per Protocol Population for Efficacy (PPE):  Received all 3 vaccinations, naïve to relevant vaccine HPV type through Month 7, did not deviate from protocol; cases counted after Month 7.
  • Modified Intent to Treat -1 Population (MITT-1):  Same as PPE, but included protocol violators
  • Modified Intent to Treat-2 Population (MITT-2): Received at least 1 vaccination, naïve to relevant vaccine HPV type at Day 1, and had any follow-up visit after the first vaccination; cases counted from 30 days after dose 1.
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Efficacy Analysis Populations (2)
  • Restricted MITT-2 Population (RMITT-2):  Seronegative and PCR negative to all four vaccine HPV types at Day 1 and a normal Pap test at Day 1; cases counted 30 days after dose 1.
  • All MITT-1 Population:  Naïve to all four vaccine HPV types through Month 7, and cases counted starting after Month 7.


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Efficacy Analysis Populations (3)
  • Modified Intent to Treat-3 Population (MITT-3):  Received at least one vaccination and had any follow-up visit one month after dose 1.  Cases were counted from 30 days after dose 1.  Subjects were included regardless of baseline HPV status.


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Baseline Characteristics
of Subjects in Efficacy Population (Protocols 005, 007, 013, and 015)
  • Squamous intraepithelial lesion (SIL) present at baseline: 12%
  • PCR positive and/or seropositive to a vaccine HPV type: 27%


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Endpoints from Efficacy Protocols
(Protocols 005, 007, 013, and 015)
  • Primary Endpoints:


  • HPV 16/18 related CIN 2/3 or worse [015, combined analysis]
  • HPV 6/11/16/18 related CIN [013]
  • HPV 6/11/16/18 related External Genital Lesions (EGLs) [013]



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Other Endpoints
  • Other Endpoints of Interest:


  • HPV 16/18 related EGLs
  • CIN 2/3 due to any HPV type and non-vaccine HPV types
  • EGL due to any HPV type and non-vaccine HPV types
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"Efficacy Against HPV 16/18 CIN..."


  • Efficacy Against HPV 16/18 CIN 2/3 or Worse
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Analysis of Efficacy Against
HPV 16/18 Related CIN 2/3 or Worse
(Protocol 015)
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Analysis of Efficacy Against
HPV 16/18 Related CIN 2/3 or Worse
(Protocols 005, 007, 013, 015)
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Analysis of Efficacy of Against HPV 16/18 Related
CIN 2/3 or Worse by HPV Type – MITT 3 Analysis (Protocols 005, 007, 013, 015)
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"Efficacy Against"

  • Efficacy Against
  • HPV 6/11/16/18 CIN


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Analysis of Efficacy Against
HPV 6/11/16/18 Related CIN
(Protocol 013)
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Analysis of Efficacy Against
HPV 6/11/16/18 Related CIN
(Protocols 007, 013, 015)
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Cases of HPV 6/11/16/18
Related CIN in PPE Population
  • Four cases occurred in the Gardasil group for the PP analysis (Protocol 015).
  • All four cases had HPV 16 related CIN 1 at Month 12-13.
    • One subject had anti-HPV 16 level just below level of detection and LSIL at Day 1 and HSIL at Mo 7, and possibly had prior exposure to HPV 16; also non-naïve to HPV 18 at Day 1 and colposcopy triggered by the HSIL at Mo 7, led to a diagnosis of HPV 18 related CIN 3 at Mo 9.
    • Three other subjects developed LSIL at Mo 7 and
    •     Mo 12, which led to colposcopies with the resulting diagnoses.  One had anti-HPV 16 level at Mo 7 higher than GMT seen in Per Protocol Immunogenicity (PPI) population.

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Analysis of Efficacy Against HPV 6/11/16/18
Related CIN by HPV Type – MITT-3
(Protocols 005, 007, 013, 015)
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Efficacy Against HPV 6/11/16/18 Related CIN 2/3 or Worse and AIS (Protocols 005, 007, 013, and 015)
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Selected Characteristics for Subgroup of Vaccine Related HPV PCR Positive and Seropositive Subjects at Day 1
(Protocol 013)
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"Efficacy Against Any HPV Type..."

  • Efficacy Against Any HPV Type and Non-Vaccine HPV Type Related CIN
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Overall Impact on CIN 2/3 or Worse
Due to Any HPV Type
(Protocols 007, 013, and 015)
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Analysis of Efficacy Against Non-HPV 6/11/16/18 Related CIN 2 or CIN 3 Among Subjects in All MITT-1 Population
(Protocols 007, 013, 015)
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"Efficacy Against HPV 6/11/16/18"


  • Efficacy Against HPV 6/11/16/18
  • Related External Genital Lesions (EGLs)
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Analysis of Efficacy Against
HPV 6/11/16/18 EGL (Protocol 013)
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Analysis of Efficacy Against
HPV 6/11/16/18 Related EGLs
(Protocols 007, 013, 015)
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Analysis of Efficacy Against HPV 6/11/16/18
Related EGLs by HPV Type (Protocols 007, 013, 015)
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Analysis of Efficacy Against HPV 16/18 Related EGLs (Protocols 007, 013, 015)
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Analysis of Efficacy Against HPV 6/11/16/18 Related EGL by Severity of Disease –
PPE Population (Protocols 007, 013, 015)
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Analysis of Efficacy Against HPV 6/11/16/18 Related EGL by Severity of Disease –
MITT-3 population (Protocols 007, 013, 015)
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Efficacy Against HPV 6/11/16/18 Related EGLs (Protocols 007, 013, and 015)
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Impact of Gardasil on Incidence of EGLs Due
to Any HPV Type by Severity of Disease
 (Protocols 007, 013, 015)
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Efficacy Against Non-HPV 6/11/16/18
Related EGL in All MITT-1 Population
 (Protocols 007, 013, 015)
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Safety
  • Safety Population
  • Safety Surveillance
  • Deaths
  • SAEs
  • Pregnancies/Lactation


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Safety Population:
Detailed and General
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Vaccine Exposure in 9-15 Year Old
Female Subjects
 (Protocols 016 and 018)
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Safety Surveillance
(Detailed Safety Cohort)
  • Vaccine Report Cards for 14 days after each vaccination (Protocols 005, 007, 013 + NSAE 015)
    • Solicited local AEs:  Pain, tenderness, redness for 5 days after vaccination
    • Temperatures for 5 days after vaccination
    • > 100° F oral
    • Solicited  and unsolicited systemic AEs:  Sore muscle, sore joints, headache, rash, diarrhea for 14 days after vaccination


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Serious Adverse Event Reporting
  • Any SAE for day of consent to 14 days postdose 1, and 14 days postdose 2 and 3 regardless of attribution
  • Any death or SAE which resulted in study discontinuation
  • Any SAE throughout study which was possibly vaccine or procedure related or whose relationship was unclear
  • Pregnancy related SAEs throughout study
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Reporting New Medical
Conditions

  • Pre-vaccination
  • Study period through Month 7
  • Study period after Month 7
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Pregnancy and Lactation Reporting
  • All pregnancies were to be followed to outcome
  • SAEs were reported for mothers and infants
  • Lactation outcomes were followed
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"Safety Results"


  • Safety Results
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Deaths
(Protocols 007, 013, 015, 016, 018)
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Serious Adverse Events
(Protocols 007, 013, 015, 016, 018)
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New Medical Conditions (Number and Percent) During Vaccination Period (through Month 7) and after Month 7 for Selected Organ Systems
(Protocols 007, 013, 015, 016, 018)
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Pregnancy Outcome Summary
(Protocols 013, 015, 016, 018)
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Distribution of Congenital Anomalies by Estimated Dates of Conception (EDCn) Timing in Relation to Vaccination (Protocols 013, 015, 016, 018)
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Adverse Events in Pregnancy/Lactation (1)
(Protocols 013, 015, 016, 018)
  • A similar pattern and occurrence of SAEs and AEs in pregnancy were reported in women who were vaccinated with Gardasil (N=40, 4.2%) or placebo (N=41, 4.3%).
    • These events included conditions leading to C-section, premature labor, and conditions associated with pregnancy.

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Adverse Events in Pregnancy/Lactation (2)
(Protocols 013, 015, 016)
  • Higher proportion of children with SAEs in women who received Gardasil while breastfeeding in the vaccination period (Gardasil N=17, 3.4%; placebo N=9, 1.8%);  the events were of similar nature in both groups.
    • In both the vaccine and placebo groups, these included respiratory infections, gastroenteritis, and asthma.


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Adverse Events in Infants/Lactation(3)
(Protocols 013, 015, 016)
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FDA Safety Conclusion (1)
  • Although no obvious safety signal was identified, post-marketing pharmacovigilance activities will continue to collect AEs that occur post-vaccination in a larger population.
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FDA Safety Conclusion (2)
  • An imbalance was noted regarding the EDCn of infants who had congenital anomalies (five cases for mothers who received Gardasil vs. none for mothers who received placebo).  However, there did not appear to be a pattern among the congenital anomalies.
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Immunogenicity
  • Bridging immune response in adolescent girls to adult women
  • Duration of immune response
  • Co-administration with Hepatitis B vaccine
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Bridging Immune Response from Females 16-26 Years to
Females 9-15 Years of Age
  • Females naïve to the four vaccine HPV types are expected to benefit most from the vaccine.


  • Efficacy studies cannot be conducted in preadolescent girls.



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Month 7 HPV 6 GMTs and 95% CI by Age at Enrollment - 9 to 26 Year Old Female Recipients of Gardasil  (PPI)
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Immunogenicity Bridging Between 9-15 Year Old Females in the Immunogenicity Studies to 16-26 Year Old Females in the Efficacy Studies (PPI)
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"Duration of Immune Response"


  • Duration of Immune Response
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Persistence of Anti-HPV 18 Immune Responses in 18 to 26 Year Old Female Recipients of Gardasil (Seronegative at Day 1 and PCR Negative Through Month 7) Versus Placebo Recipients (Seropositive and PCR Negative at Day 1)
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Seropositivity Rates for Anti-HPV 6, 11, 16, and 18 at Month 24 (Vaccinated Women 18-26 years) with Serology Data at All Time Points (N=2818)
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Co-administration of Gardasil with Hepatitis B Vaccine
  • Anti-HPV 6, 11, 16, and 18 immune responses were non-inferior when Gardasil was given with or without Recombivax (SC rates, GMT ratios)
  • Anti-Hepatitis B immune response was similar when Recombivax was given with or without Gardasil (SC rates)
    • Anti-Hep B GMTs lower in coadministration group
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Applicant’s Proposed
Post-marketing Commitments

  • Routine pharmacovigilance
  • Phase 4 studies
  • Other studies


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Routine Pharmacovigilance
  • Passive reporting of adverse events (AEs) including:
      • Monthly submission of non-serious AE reports
      • Regular FDA-CDC-Sponsor conference calls
  • Pregnancy registry
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Phase 4 Studies
  • Observational safety surveillance study in large U.S. MCO
      • Investigation of serious AEs that occur in close temporal association with vaccination (60 days follow-up)
  • Nordic Long Term Follow-up Study
      • Longitudinal evaluation of subjects in Protocol 015 enrolled in Nordic countries using national registries
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Nordic Long Term Follow-up Study:  Outcomes
  • HPV-related diseases
  • Long term effectiveness and duration of immune response
  • Potential safety signals
  • Pregnancy outcomes
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Other Studies
  • Evaluation of long term effectivenesss and duration of immune response:
      • Extension of protocol 007
      • Extension of protocol 018
  • Detection of unanticipated safety signals through active surveillance in all studies.


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Gardasil:
FDA Review Conclusions
  • The efficacy, safety, and “bridging” immune response data submitted to the BLA support licensure of Gardasil in females 9-26 years of age naïve to the relevant vaccine HPV type for prevention of the following diseases/events:
    • HPV 16/18 related cervical cancer, CIN 2/3 and AIS.
    • HPV 6/11/16/18 related VIN 2, VIN 3, VaIN 2, VaIN 3
    • HPV 6/11/16/18 related CIN 1, genital warts, VIN 1 and VaIN 1
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Gardasil:
FDA Review Concerns (1)
  • Applicant’s Per Protocol HPV type-specific analyses that indicated a very high level of efficacy in naïve subjects may not reflect the efficacy of Gardasil for all HPV related disease on a population basis.
  • HPV related disease occurred in Gardasil recipients.
    • Some vaccine recipients were non-naïve at baseline for one or more vaccine HPV type(s), and some of these subjects developed HPV disease related to that HPV type(s).
    • Subjects who were naïve to all four vaccine HPV types could still develop disease related to an HPV type not included in the vaccine.
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Gardasil:
FDA Review Concerns (2)
  • Modified Intent to Treat analysis (MITT-3) of all vaccinated females across studies 005, 007, 013, and 015 demonstrate modest efficacy against CIN 2/3:
    • MITT-3:  Overall efficacy CIN 2/3 or worse due to HPV6/11/16/18 [39.0% (23.5, 51.7%)]
    • MITT-3:  Overall efficacy CIN 2/3 or worse due to any HPV type [12.2%
    •   (-3.2%, 25.3%)].

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Gardasil:
FDA Review Concerns (3)
  • Longer-term efficacy
    • Study 005 results suggest favorable longer term efficacy
  • Duration of immune response
    • Post-licensure commitments
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Questions for the Committee
  • Do the data from studies 005, 007, 013, and 015 support the efficacy of Gardasil for the prevention of HPV 16/18 related  cervical cancer, cervical AIS, and CIN 2/3 or worse in females 16-26 years of age?


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Questions for the Committee
  • Do the data from studies 007, 013, and 015 support the efficacy of Gardasil for the prevention of HPV 6/11/16/18 related VIN 2/3 and VaIN 2/3 in females 16-26 years of age?


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Questions for the Committee
  • Do the data from studies 007, 013, and 015 support the efficacy of Gardasil for the prevention of HPV 6/11/16/18 related condyloma acuminata, VIN 1 and
  • VaIN 1?
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Questions for the Committee
  • Do the immunogenicity data support bridging of the younger female population (9-15 years of age) to the efficacy population (females 16-26 years of age)?


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Questions for the Committee
  • Do the safety data from studies 007, 013, 015, 016 and 018 support the safety of Gardasil for use in females 9-26 years of age?
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Questions for the Committee
  • Please comment on post-marketing commitments.