Division of Biostatistics

Office of Biostatistics and Epidemiology

Center for Biologics Evaluation and Research

Food and Drug Administration

 

Cellular, Tissue and Gene Therapies Advisory Committee Meeting

March 29, 2007

 

Statistical Briefing Document

 

 

PROVENGE (Sipuleucel T)

For the treatment of men with asymptomatic metastatic androgen independent prostate cancer.

 

 

Table of Contents

 

 

INTRODUCTION ………………………………………………………………………… 2

 

OVERVIEW ……………………………………………….……………………………… 3

 

STATISTICAL EVALUSTION …………………………………………………….…… 4

                             

I.                   Study D9901 …………………………………………………………………… 4

                             

                  1.0       Statistical Analysis Plan ………………………………………………. 5

                  2.0       Efficacy Evaluation …………………………………………………… 8

                  3.0       Statistical Findings and Comments …………………………………..22

                             

II.                Study D9902A …………………………………………………………………29

                              

                  1.0       Statistical Analysis Plan ………………………………………………29

                  2.0       Efficacy Evaluation …………………………………………………...30

                  3.0       Statistical Findings and Comments …………………………………..39

 

III.             Integrated Summary and Other findings    ………………………………… 42

                              

                   1.0       Summary of Efficacy ………………………………………………… 42

                  2.0       Summary of Safety…………………………………………………… 44

                  3.0       Statistical Findings and Comments…………………………………   45

 

SUMMARY AND CONCLUSIONS ……………………………………………………. 47

 

References    ………………………………………………………………………… 48


 

INTRODUCTION

 

 

Dendreon is seeking licensure of sipuleucel-T (Provengeฎ, APC8015) for the treatment of men with asymptomatic, metastatic androgen independent prostate cancer (AIPC). The proposed indication is based upon analyses comparing overall survival between APC8015 treated and placebo groups with the relative absence of significant toxicity in this patient population.

 

Sipuleucel-T is an autologous active cellular immunotherapy product designed to stimulate an immune response against prostate cancer. APC8015 consists of autologous peripheral blood mononuclear cells (PBMCs), including antigen presenting cells (APCs), that have been activated in vitro with a recombinant fusion protein. The recombinant fusion protein, PA2024, is composed of prostatic acid phosphatase (PAP), an antigen expressed in prostate adenocarcinoma, linked to granulocyte-macrophage colony-stimulating factor (GM-CSF), an immune cell activator.

 

Sipuleucel-T falls into the class of therapies known as active cellular immunotherapies, sometimes termed therapeutic cancer vaccines. Such immunotherapy products are designed to elicit a specific immune response to a target antigen. While the precise mechanism of action is unknown, sipuleucel-T is designed to induce a cellular immune response targeted against a recombinant fusion protein containing prostatic acid phosphatase (PAP), an antigen expressed in prostate cancer tissue. During ex vivo culture, antigen presenting cells (APCs) take up and process the recombinant target antigen into small peptides that are then displayed on the APC surface. In vivo, T cells bind to and recognize the target antigen peptides on the APC surface, eliciting a response characterized by the proliferation and activation of T cells. These activated T cells are the effector cells thought to be responsible for recognition and destruction of prostate cancer cells in vivo. Sipuleucel-T has been shown to stimulate the proliferation of PAP-specific T cell hybridomas in vitro.

 

The proposed target indication for sipuleucel-T is for the treatment of men with asymptomatic metastatic androgen independent prostate cancer (AIPC).

 

All submissions are under BLA 125197.  The electronic BLA is in CTD format and organized in folders corresponding to BLA structure.  Pursuant to the Fast Track Designation agreement and the agreement to submit portions of the application (rolling Biologics License Application), the first portion of the BLA including all clinical and nonclinical sections, draft proposed labeling, and appropriate administrative documents (e.g., forms, table of contents, certifications) was submitted on August 21, 2006. The second/final portion which contains all quality sections along with the final proposed labeling was submitted on November 9, 2006. In addition, Dendreon intends to submit the 4 Month Safety Update in February/March 2007.

 


Study overview

 

 

Clinical studies of sipuleucel-T have been performed under BB-IND 6933 and include Phase 1, 2, and 3 studies in men with prostate cancer.

 

Early Phase 1 and 2 clinical studies in men with AIPC were conducted to test the safety and preliminary efficacy of sipuleucel-T (Small 2000, Burch 2000, Burch 2004). The results demonstrated the following: 1) Intravenous infusions of sipuleucel-T in subjects with prostate cancer were generally well tolerated with no dose limiting toxicities observed; 2) Prostate-specific antigen (PSA) reductions of >50% in approximately 10% of subjects were noted, as well as one striking objective response; 3) Three doses of sipuleucel-T resulted in substantial PAP-specific immune responses.  Results of open-label Phase 2 trials in men with androgen dependent prostate cancer (ADPC) also demonstrated that intravenous infusions of sipuleucel-T were generally well tolerated with no dose limiting toxicities observed. Additionally, prolongation of PSA doubling time was observed in these studies (Rini 2005a, Rini 2005).

 

The Phase 3 clinical development program for sipuleucel-T was originally designed based on the results of Phase 1 and 2 trials in men with AIPC and guidance received from the Center for Biologics Evaluation and Research (CBER) and practicing oncologists and urologists. The program consisted of Protocols D9901 and D9902, two identically designed, multicenter, randomized, double blind, placebo-controlled studies in men with asymptomatic, metastatic AIPC. The target number of subjects to be enrolled was 120 in each study, and the primary endpoint for both studies was time to objective disease progression (TTP). Each of the 2 studies was powered to independently meet the primary endpoint of TTP; a pooled analysis of the combined studies was required for sufficient power to meet the secondary endpoint of time to onset of disease-related pain (TDRP). In 1999, no therapy had been shown to prolong survival in men with asymptomatic metastatic AIPC, and there were no Phase 1 or 2 survival data specifically for sipuleucel-T. Therefore, survival was not used as the primary endpoint. However, in both trials, subjects were to be followed until death or until a pre-specified cut-off of 36 months from the time of randomization, whichever occurred first.

 

The second study (D9902) was initiated shortly after the first study. The trial design, patient eligibility, objectives and statistical considerations were the same as those in the study 1 with a planned sample size of 120 subjects.  After the first study results became available showing no overall significance of TTP in 2002, the sponsor did a subset analysis of the study 1 and found that there was a difference of TTP favoring Provenge arm for subjects who had Gleason score ≤ 7.  At this point, the study 2 had already enrolled 98 subjects.  The sponsor decided to split the second study into two parts (A and B).  Part A (D9902A) contained the initial 98 subjects with Gleason scores ≤ 7 or ≥ 8, and part B to enroll subjects only with Gleason score ≤ 7.  The BLA contains data from the two pivotal studies:  Studies D9901 and D9902A.

 

Since data/results from the two pivotal trials were submitted as the main efficacy evidence under this BLA to support the licensing application, the focus of the statistical review is mainly on the two Phase 3 trials (Studies D9901 and D9902A).

 

 

Statistical evaluation

 

 

I.          Study D9901

 

This was a prospective Phase 3, multicenter, double blind, placebo-controlled, randomized trial of immunotherapy with APC8015 for the treatment of subjects with asymptomatic metastatic AIPC. A total of 127 subjects were randomized at multiple investigative centers (19 clinical study centers) across the United States. Following a pre-registration and screening process, eligible subjects were randomized to either active treatment or control in a 2:1 ratio (active treatment: control).  

 

An independent third party was employed to generate the randomization schedule for the study. The specifics about the method of randomization employed (block size and degree of imbalance at each study site) were not made known to Dendreon until after the study was unblinded.  Subjects were stratified by clinical study center and use of bisphosphonate therapy (yes or no) prior to being randomized.  The allocation of subjects to treatment utilized multiple blocks, each of size 6, to generate a separate master randomization schedule for each stratum. A centralized, adaptive randomization procedure was employed to maintain the overall enrollment in the study at an approximately 2:1 randomization, while preventing the enrollment at any clinical study center from departing from the 2:1 randomization ratio by a large amount.

 

Following randomization, subjects from both groups underwent a series of 3 standard leukapheresis procedures (in Weeks 0, 2, and 4), and each procedure was followed 2 days later by infusion of either autologous antigen loaded APCs (APC8015; active treatment) or autologous quiescent APCs without antigen (APC-Placebo; control). The treatment phase of the protocol was complete following the third (Week 4) infusion.  For subjects on the control arm, the remaining two-thirds of the quiescent APCs from each leukapheresis that were not used to make APC-Placebo were cryopreserved for possible later use in the preparation of APC8015F for the Phase 2 salvage trial D9903.

 

At the time that subjects developed disease progression, study treatment could be unblinded. Subjects in the APC8015 group were then treated at the physician’s discretion. Subjects in the APC-Placebo group had the option to enter a Phase 2, open label, single-arm salvage trial (Protocol D9903) with a product similar to APC8015. Subjects treated with APC8015 on D9901 were not eligible to participate in the salvage trial.

 

Regardless of subsequent treatment, subjects without disease-related pain at the time of disease progression were to be followed with weekly pain logs for 4 additional weeks. After subjects developed disease progression, follow-up documentation included treatment-related AEs, first anticancer treatment, and survival for 3 years from the time of randomization or until death, whichever occurred first. Per the statistical analysis plan (Appendix 16.1.9.8), the final analysis of survival was performed 36 months following randomization of the last subject.

 

1.0       Statistical Analysis Plan

 

1.1       Efficacy variables

 

The primary efficacy variable, overall time to disease progression (TTP), was defined as the time from randomization to the first observation of disease progression.  Disease progression was defined by any of the following:

 

Measurable Disease

 

• A greater than 50% increase in the sum of the products of the perpendicular diameters of all bidimensionally measurable lesions. The change was measured against the smallest sum observed, or compared with baseline if there was no response, using the same techniques as baseline.

 

• An appearance of at least 2 new lesions or the reappearance of any lesion that had disappeared. All lesions had to have a minimum size of at least 2 cm in 1 dimension to be considered measurable.

 

Evaluable Disease

 

• Unidimensionally measurable disease: at least 50% increase in the sum of the measurements of all unidimensionally measurable lesions over the smallest sum observed (over baseline if no response) using the same techniques as baseline.

 

• Nonmeasurable disease: Clear worsening of nonmeasurable, evaluable disease.

 

• “Scan only” bone disease: The appearance of at least 2 new areas of abnormal uptake on bone scan. Increased uptake of pre-existing lesions on bone scan did not constitute progression.

 

Development of Prostate Cancer-Related Events

 

• The development of a prostate cancer-related event (e.g., spinal cord compression, a pathologic fracture, the development of a requirement for radiation therapy, or other clinically significant disease specific event) constituted progression.

 

• Failure to return for evaluation due to death or deteriorating condition constituted progression unless the event was clearly unrelated to prostate cancer.

 

Development of Prostate Cancer-Related Pain

 

• On the basis of the Investigator’s opinion, all of the following criteria had to be met: pain that had the quality and consistency of cancer-related pain, pain that occurred since enrollment in the trial, and pain that occurred in a location that correlated with a site of cancer, as demonstrated by objective radiographic means.

 

Secondary efficacy measures included time to development of disease-related pain, objective response rate, and duration of response, time to clinical progression, time to treatment failure, and incidence of Grade 3 or greater treatment-related AEs in all subjects who underwent at least 1 leukapheresis for trial purposes.

 

Survival as an endpoint was not defined in the protocol and its amendments though the sponsor stated that all subjects would be followed for survival for 36 months after their date of randomization or until death, whichever occurred first.  Regarding survival analysis, the sponsor did state that “This study is not powered to show a survival effect. However, survival data will be summarized descriptively.”   The definition for a survival endpoint was later added to the study report in the BLA submission as:

 

The survival times for subjects who died during the 3-year follow-up period were defined as the time span (in months) from the date of randomization to the date of death. The survival times for subjects who were alive at the end of the 3-year follow-up period were censored and defined as the time span (in months) from the date of randomization to the censor date of 3 years after the date of randomization.

 

1.2       Analysis plan

 

The statistical analysis plan included 2 interim analyses and a final analysis. The first analysis was conducted on data from control subjects only for the purpose of sample size confirmation so no alpha adjustment was made and the sample size was not adjusted based on the results. The second interim analysis was performed on data from 79 subjects from both treatment arms to assess the conditional probability of trial success (i.e., futility analysis) and was conducted at the 0.001 level. The final analysis was conducted at the 0.049 level using an O.Brien-Fleming adjustment. Both interim analyses were conducted by an independent third party and Dendreon personnel remained blinded to treatment assignments.

 

These data were analyzed using the ITT and Safety populations. The ITT population included all randomized subjects, and the Safety population included all subjects who underwent at least 1 leukapheresis. Since all randomized subjects underwent at least 1 leukapheresis in this trial, both populations are identical.

 

 

1.3       Analysis of primary efficacy data

 

The time to disease progression curves were constructed with the Kaplan-Meier technique for the two treatment groups, and the primary null hypothesis (no difference between treatment groups) was tested using the log rank test.

 

The date of data cut-off for the primary efficacy evaluation was April 30 2002. Subjects who did not experience disease progression by the time of the efficacy analysis were censored at the time of their last known radiographic imaging study. Similarly, if a subject had no disease progression and was lost to follow-up prior to the data analysis, the subject was censored at the date of last radiographic imaging study.

 

The primary efficacy variable was also summarized by the following subgroups:

 

• PAP immunohistochemistry expression: 2 subject groupings based on the proportion of cancer cells staining positive for PAP (25% to 74%, = 75%).

 

• Baseline alkaline phosphatase (within normal limit [WNL] versus above ULN of local reference range).

 

• Baseline serum PAP levels (WNL of local reference range, > 1 ื ULN to < 3 ื ULN; = 3 ื ULN).

 

• Prior systemic therapy (castration only, combined androgen blockade, combined androgen blockade plus other; castration plus other was also considered if there were sufficient numbers in the data).

 

Inferential tests with appropriate adjustment for multiplicity were carried out for the above mentioned variables, but such inferential statistics were only carried out for time to disease progression. Treatment by subgroup interactions were tested to evaluate if any of them represented effect modifiers. These interactions were tested before simple effects and the latter only tested in the event of a significant interaction. Adjustments were made for the 4 interaction tests using the Sidak-Holm method. The tests for simple effects were not considered reportable unless the corresponding interactions were significant (at the P ≤ 0.10 level).

 

Subjects were followed for survival for 3 years following their date of randomization. Subjects who were alive at 3 years following randomization were censored at 3 years from their date of randomization. Survival was analyzed using the Kaplan-Meier technique. Survival rate estimates at 3, 6, 9, 12, and every 6 months thereafter and median survival were obtained from the Kaplan-Meier method. Corresponding confidence intervals (CIs) were also computed.

 

Sample size

 

The most current version of the protocol (amendment 7, dated 25 JUL 2002) indicates that approximately 120 subjects were planned, with 80 subjects in the APC8015 group and 40 subjects in the APC-Placebo group. A 2:1 randomization was used in order to increase the number of subjects exposed to APC8015. Based on past experience and a review of the literature, a median time to disease progression for subjects treated with APC-Placebo was assumed to be 4 months. A delay in the time to disease progression of 3.7 months (from 4 to 7.7 months) was considered clinically significant for subjects with metastatic AIPC. This represents a hazard ratio (HR) of 1.925 assuming an exponential distribution. It was further assumed that accrual into this study would be done within 16 months and that each subject would be followed for up to 3 years. With a 2-sided 5% level of significance and a 2:1 subject-allocation ratio between the APC8015 and APC-Placebo groups, a total of 80 events was needed to achieve 80% power to detect the specified difference of 3.7 months in median time to disease progression; it was projected that 87 subjects would be sufficient to attain the 80 events (Lachin 1981). To account for non-uniform subject entry and 5% loss to follow-up (Lachin 1986) a total of 96 subjects (64:32 subjects for APC8015:APC-placebo) was necessary.

 

It was assumed that the same HR would apply to time to disease-related pain. Therefore, a total of 80 pain progression events would also be required to power the disease-related pain endpoint at 80%. However, it was further assumed that 60% of the pain events would be censored when the requisite number of progression events had been recorded. This high level of censoring would result in 32 pain progression events from Study D9901 alone. Increasing the sample size from 96 to 120 would result in a projection of approximately 40 events from pain progression. In order to achieve 80% power and capture 80 pain events for the disease-related pain endpoint, enrollment of 240 subjects was required. Therefore, enrollment of 120 subjects in each of the Phase 3 trials (D9901 and D9902A) was planned with a final pooled analysis for this endpoint.

 

 

2.0       Efficacy Evaluation

 

2.1       Disposition of subjects

 

As shown in Figure 1, 127 of the 186 subjects screened for eligibility were randomized between 04 JAN 2000 and 08 OCT 2001. Of these, 82 subjects were randomized to receive APC8015 and 45 subjects were randomized to receive APC-Placebo. All 127 subjects underwent at least 1 leukapheresis procedure and received at least 1 infusion.

 

Of the 59 subjects who were screened for the trial but were not randomized, the majority of subjects failed to satisfy the inclusion criteria (52 of 59 subjects, 88%). Five subjects (8.5%) chose not to participate in the trial following their registration visit. Two additional subjects (3.4%) withdrew for other reasons (aortic aneurysm and participation in a separate clinical trial).

 

Twelve subjects discontinued the 3-year study before completing the trial, but survival at 36 months following randomization was available for all 12 subjects. Four subjects treated with APC8015 and 1 subject treated with APC-Placebo withdrew consent prior to meeting the primary endpoint of disease progression. Rising PSA was not reported as the primary reason for any subject to discontinue the trial. 

 

Figure 1          Schematic of Subject Disposition

 

 

 

 


 

Major protocol eligibility deviations occurred for 7.9% of subjects (8 subjects treated with APC8015 and 2 subjects treated with APC-Placebo) and included the following: no evidence of metastatic disease at entry, evidence of pleural effusion at study entry, not medically or surgically castrate at study entry or medical castration therapy discontinued during trial, PSA values demonstrating or confirming androgen independence obtained outside the protocol-specified window, and radiation therapy received during the active period.

 

 

2.2       Demographics and other baseline characteristics

 

A summary of demographics and baseline characteristics is provided in Table 1. The demographic characteristics were similar between the 2 treatment groups.  All subjects enrolled in this trial were male, and the majority of subjects were Caucasian (90.6%). The median age in this population was 73.0 years; ages ranged from 47 years to 86 years. The majority of subjects from both treatment groups had a baseline ECOG performance status of 0 (75.6% of subjects treated with APC8015 and 82.2% of subjects treated with APC-Placebo).

 

Baseline laboratory evaluations were well matched between the treatment groups and are provided in Table 1.

 

The estimated median time from diagnosis to randomization for subjects treated with APC8015 was 397.6 weeks (approximately 7.6 years) compared to 356.9 weeks (approximately 6.9 years) for subjects treated with APC-Placebo.

 

Table 1           Summary of Subject Demographics and Baseline Characteristics, ITT

 

 

 

The protocol required subjects to have a tumor specimen (tissue block, core biopsy, or pre-cut unstained slides) submitted to a central pathology facility for immunohistochemistry testing of PAP. Eligibility required a positive PAP immunohistochemistry reaction in ≥ 25% of cells. The PAP immunohistochemistry results are summarized in Table 2. A higher percentage of subjects in the APC8015 group than in the APC-Placebo group had tumor specimens with at least 75% PAP-positive cells.

 

   Table 2        Summary of PAP Immunohistochemistry, ITT

 

 

For this study, 116 of 127 subjects (91.3%) had a Gleason score assigned by a central pathology laboratory prior to randomization. The Gleason scores obtained by local pathology facilities were used for those subjects not given Gleason scores by the central pathology facility. Gleason score and tumor status at baseline is presented in Table 3. Overall, a majority of the subjects had a Gleason score ≤ 7 (75 subjects [59.1%] versus a Gleason score ≥ 8 (52 subjects [40.9%]). Differences between the treatment groups were not statistically significant.

 

 

    Table 3       Summary of Gleason Score and Tumor Status at Baseline, ITT

 

It should be noted that p-values provided by the sponsor in the above tables should not be considered as those from a hypothesis test for the difference between the two arms.  They just reflect the chance of obtaining the observed difference (and more extreme) between the two arms in these demographic and baseline characteristics factors when in fact the two samples were randomly drawn from the same population.

 

 

 

 

 

2.3       Efficacy results

 

The protocol prospectively designated time to disease progression as the primary endpoint and specified that complete survival data (up to 36 months) would be collected. Survival is the focus of this study report. Survival is objectively ascertained, represents the standard for establishing clinical benefit in oncology clinical trials, and best represents the therapeutic effect of APC8015. To be consistent with the prospectively defined protocol, time to disease progression and the secondary endpoints are presented first in this study report, but the most extensive information and critical analyses are focused on survival.   

 

The efficacy review focuses on the survival endpoint.

 

2.3.1    The primary endpoint

 

The sponsor states in this BLA that the primary efficacy endpoint was the overall time to disease progression.  The following analyses for the primary endpoint presented in the study report by the sponsor were based on the unblinded review data.  The terminology change for the primary endpoint and the adequacy of using unblinded review data will be discussed later in the section “Statistical Findings and Comments”.

 

Out of 127 subjects randomized on this study, 115 subjects (90.6%) contributed a progression event. Ninety-eight subjects (77.2%) had progression documented by imaging (as determined by independent, blinded, radiology review). Of the 98 subjects who progressed based on imaging studies, 48 subjects treated with APC8015 and 24 subjects treated with APC-Placebo progressed based on bone disease, while 15 subjects treated with APC8015 and 11 subjects treated with APC-Placebo progressed based on soft tissue disease. Ten subjects (7.9%) had progression based on clinical events other than radiographic events, as defined in the protocol, and 7 subjects (5.5%) had progression based on the onset of cancer-related pain. Additionally, 6 subjects (4.7%) were censored prior to meeting the disease progression endpoint and 6 subjects (4.7%; all in the APC8015 group) were censored without disease progression at the primary efficacy evaluation cut-off date (30 APR 2002).

 

When the Kaplan-Meier curves for time to disease progression were compared, there was a delay from randomization to disease progression in the APC8015 group compared with the APC-Placebo group (P = 0.052, log rank; unadjusted HR = 1.45 [95% CI: 0.99, 2.11]; Figure 2).  After Week 8 the Kaplan-Meier curves showed a marked separation that persisted throughout the remainder of follow-up.  The estimated median time to disease progression was 11.7 weeks in the APC8015 group compared with 10.0 weeks in the APC-Placebo group.

 

Figure 2   Primary Efficacy Endpoint, Time to Disease Progression (Kaplan-Meier Method), ITT

 

 

The sponsor also reported time to objective disease progression confirmed by imaging studies as follow (p74 of the Study Reports for D9901): During the trial, available imaging studies were evaluated for all subjects by a central, independent radiology facility. A supplementary analysis was conducted on the time from randomization to objective disease progression confirmed by imaging studies. Results of this analysis indicated that statistical significance was not reached in the ITT population (P = 0.183, log rank; unadjusted HR = 1.32 [95% CI: 0.87, 2.00]).

 

2.3.2    The secondary endpoints

 

There was no statistically significant difference between the treatment groups with respect to time to onset of disease-related pain progression (P = 0.210 log rank; unadjusted HR = 1.47 [95% CI: 0.80, 2.68]). The median time to onset of disease-related pain in subjects treated with APC-Placebo was estimated to be 24.0 weeks, while the median time to onset of disease-related pain in subjects treated with APC8015 was not estimable. The pain-free rate estimate at 12 weeks, 71.5% of the subjects treated with APC8015 and 69.7% of the subjects treated with APC-Placebo had not experienced onset of disease-related pain progression.

 

Since no subjects experienced a tumor response based on review by the central radiology facility, there is no evaluation on tumor response rate and duration of response.

 

Time to clinical progression was analyzed to determine the difference in the primary endpoint in cases where both subjective evidence and independently confirmable evidence of disease progression were present. For the time to clinical progression analysis, the first evidence of disease progression for each subject was used, whether based on subjective or independently confirmable evidence. (For the primary endpoint of time to disease progression, the date of independently confirmable disease progression was used when available.) Twenty-two subjects treated with APC8015 and 18 subjects treated with APC-Placebo had a clinical progression date that differed from their time to disease progression date.  There was a trend toward a prolonged time from randomization to clinical progression in the APC8015 group compared with the APC-Placebo group, which approached but did not reach statistical significance (P = 0.061, log rank; unadjusted HR = 1.44 [95% CI: 0.98, 2.10]).

 

Time to treatment failure was defined as the time from randomization until any of the following occurred: disease progression, death, or withdrawal for any reason except withdrawal of consent. (Withdrawal of consent caused the subject to be censored at the time of the last visit.) Initiation of other primary anticancer therapy, including radiation therapy, in the absence of study withdrawal was considered treatment failure for the purpose of this endpoint, as of the date the therapy was initiated. The difference between APC8015 and APC-Placebo in time to treatment failure was not statistically significant (P = 0.124, log rank; unadjusted HR = 1.34 [95% CI: 0.92, 1.94]).

 

2.3.3    Overall survival

 

The primary comparison between two arms in overall survival WAS NOT pre-specified in the protocol and the statistical analysis plan before unblinding the data. 

 

The analysis of the 3-year survival data was based on the ITT population of all 127 randomized subjects.  Every subject was followed until death or the pre-specified cut-off of 36 months(i.e.: the cutoff date should be in October 2004 since the last patient was enrolled in October 2001); there were no censored events prior to the 36th month of follow-up.  Although there was one subject who lost to follow-up as shown in Figure 1, this is just specific for the time to disease progression endpoint. 

 

The first analysis of the survival data were based on the Kaplan-Meier technique and the log rank test. Subjects treated with APC8015 demonstrated an improvement in overall survival, compared to those treated with APC-Placebo (P = 0.010, log rank; Figure 3). The unadjusted HR was 1.71 (95% CI: 1.13, 2.58), indicating a 41% reduction in the death rate for subjects treated with APC8015 compared to APC-Placebo. The median survival time for subjects treated with APC8015 was 4.5 months longer than that for subjects treated with APC-Placebo (median survival times of 25.9 months and 21.4 months, respectively).  Table 4 and Table 5 present key summary statistics that characterize the differences between the 2 treatment arms.

 

Figure 3          Overall Survival (Kaplan-Meier Method), ITT

 

Table 4           Summary Statistics, ITT

 

Table 5           Kaplan-Meier Survival Rate Estimates, Percent ITT

 

Following study closure, Dendreon attempted to obtain death certificates and other source documents to confirm the cause of death. Based on a review of these additional documents as well as data obtained from the death summary CRF, all causes of death were ascertained. Given the importance of the death date, Dendreon also compared the death date recorded by the clinical study center (on the Death Summary CRF) to the date listed on the Social Security Death Index (SSDI) for 93 of the 94 subjects who died during the 36 month follow-up (An SSDI death date was not available for 1 subject). In the majority of these cases (86 of 93 cases) the death dates from the 2 sources were identical.  Discrepancies were noted for 4 subjects treated with APC8015 and for 3 subjects treated with APC-Placebo. The observed differences are minor and would not substantively change the survival difference observed between APC8015 and APC-Placebo (Detailed results of these findings are contained in Section 12.3.3.1).

 

Several other sensitivity analyses were performed to test the robustness of the survival results. Specifically, these sensitivity analyses included the following:

 

• Removal of influential subjects

• Removal of investigational study centers

• Reversing the treatment assignment of subjects with randomization errors

• Removal of subjects with protocol deviations

• Assessing the influence of cell processing centers (CPCs) on survival

• Comparison of use of chemotherapy during long-term follow-up

• Assessing the influence of prognostic factors on the observed survival effect

 

Six of the longest surviving subjects in the APC8015 group had to be removed before the p-value exceeded 0.05.

 

The exclusion of study center 69 was the only one that resulted in a non-significant p-value (P = 0.062, log rank). This was the largest study center with a total of 20 subjects (15.8% of all subjects).  Each of the other study center exclusions yielded a significant survival finding.

 

2.3.4    Proportional model for survival analysis

 

The sponsor evaluated the individual effect of the 21 potential prognostic factors as listed in Appendix 16.1.9.11 and found that eight of these prognostic factors (age, alkaline phosphatase, hemoglobin, lactate dehydrogenase [LDH], localization of disease, number of bone metastases, PSA, and weight) could be independently identified as predictors of survival at the 0.05 level. The sponsor also stated that each one of these 8 variables has previously been identified in the literature as a significant prognostic factor of survival.  Additional prognostic factor, serum PAP, was also identified as a significant prognostic factor by the sponsor, but the sponsor excluded it from the model since they believed that it had substantially more missing data.

 

In order to build a model that was predictive of survival, the 9 prognostic factors (including serum PAP) identified in the univariate analyses were considered as candidates and included in a multivariate PHR model.

 

The backwards stepwise selection method (P = 0.05 for entry and P = 0.10 for removal, likelihood ratio test) was then used to identify the prognostic factors that added significantly to the fit of the model. Serum PAP was found not to be significant following the backwards elimination procedure. This analysis was repeated without serum PAP as a covariate since there was a relatively large number of missing PAP values. The results of this analysis reduced the number of prognostic factors remaining in the model to 5. The 5 baseline prognostic factors that remained in the final model were LDH (ln), PSA (ln), localization of disease, number of bone metastases, and body weight (lbs). It should further be noted that the treatment effect continued to be significant at every step of the backward elimination procedure and was a predictor of survival in the final model. Following identification of these 5 prognostic factors and in order to utilize all of the data available, the PHR analyses were conducted with just these 5 variables and the treatment effect in the model because the 3 eliminated variables had missing data. The results of these analyses are presented in Table 6. Note that the p-value for localization was greater than 0.05 but less than 0.10. The treatment effect was significant (P = 0.002, Wald.s test; adjusted HR = 2.16).

 

   Table 6        Proportional Hazards Regression Model of Survival – Cox model (I)

 

2.3.5    Cell dose and product potency

 

While the design of the study was not one in which the cell dose was specified, the analysis of cell dose and product potency was requested as a means of examining the relationship between survival and cell dose. To this end, survival data for subjects treated with APC8015 were assessed in the context of the key release specification parameters of the product, notably, the TNC, CD54 cell count, and the upregulation of CD54. CD54 cell count and CD54 upregulation were chosen as biologically relevant release specifications because of CD54’s uniform expression on APCs, its role in the immunologic synapse between APCs and T cells, and its role as a marker of APC activation. Specifically, experiments have demonstrated that the CD54+ population of mononuclear cells possesses the ability to take up the PA2024 antigen and present epitopes of PAP to hybridoma cell lines recognizing PAP epitopes.

 

In the simple Cox PHR model, subjects who had a CD54 cell count at or above the median of 2.5 x 109 cells, or CD54 upregulation ratio at or above the median of 23.3, had an improved survival compared to those subjects below the median (HR = 0.63 and HR = 0.79, respectively). A significant effect on survival was observed between subjects above and below the median TNC count of 10.8 x 109 cells (HR = 0.52; P = 0.018; Table 7).  A multivariate Cox PHR model was used to determine whether cell counts correlated with survival when correcting for the 5 key prognostic variables of baseline PSA, lesion count, localization of disease, baseline LDH, and weight. A similar trend was observed when TNC was included in the multivariate Cox PHR model (P = 0.054; HR = 0.56).  As in the simple Cox model, there was no statistically significant correlation for total CD54 cell count (P = 0.233; HR = 0.70) or CD54 upregulation (P = 0.274, HR = 0.72) in the multivariate Cox PHR model.

 

It should be noted that there was no information on the cell dose and characteristics from the placebo group and the study was not designed to provide confirmative evidence for relationship between survival and cell dose.  The significant result below may just