The FDA approval of weight-loss drug Lorcaserin (to be sold as BELVIQ) a week ago symbolizes a recent shift in the regulatory climate from an extremely conservative,
risk-averse one (remember Vioxx and Avandia) to one that tries
to better balance the safety concern with providing patients and physicians
with new treatment options. This is also
good news for the field of RNAi Therapeutics as the technically lowest-hanging
fruits happen to be for targeting genes in the liver, an organ
rich in well-validated gene targets related to the metabolic and cardiovascular disease, the two therapeutic fields that arguably suffered the most from the risk-averseness
as they had grown heavily reliant on biomarkers in favor of outcomes. Of course, Tekmira’s SNALP delivery
technology, already clinically validated for target gene knockdown in the
liver (SNALP Works!), is first in line to benefit from the change, although companies like
Merck, Arrowhead Research, and Silence Therapeutics are trying hard to
replicate Tekmira’s success with similar and also differentiated approaches.
Lorcaserin Symbolic
The approval path of Lorcaserin
has been symbolic for the shift in the regulatory climate. Despite meeting- in large clinical trials- the
FDA’s very own guidelines for weight loss efficacy with what was one of the most
benign safety profiles that I have seen, the agency, in briefing documents and Advisory
Committee meetings alike seemed about to change the goal-post in the middle of the
game by demanding greater degrees of weight loss which it was clear Lorcaserin,
as a single agent, could never achieve.
To further justify the negative stance on Lorcaserin, theoretical safety
concerns, particularly stemming from clinically irrelevant cases of breast
cancer in rats were suddenly picked up on.
If you are a scientist, this scenario might sound familiar to you: if a
reviewer of a scientific paper does not like your study or even you personally
[on a personal note, the term ‘blogger’ is often used here in a derogative way], he/she will always come up with a reason to reject your
study. In other words, as in publishing, also in drug regulation, no matter how good, anything can be made to look bad if that's the motivation.
To add insult to injury, Lorcaserin’s two main competitors,
Qnexa from Vivus and Contrave from Orexigen, came up ahead of Lorcaserin at least from
the AdCom meetings 1-2 years ago, despite these formulations being nothing more than the
combination of two established ingredients, the type of life-cycle
re-formulation strategy that has pushed the pharmaceutical industry and the healthcare system to the brink of financial viability.
Thankfully, these events prompted a wide public outcry,
including vocal, often ridiculed ‘retail’ shareholders which together with the
recognition of the enormous unmet medical need (obesity) caused a remarkable
turnaround in the regulatory fortunes of the drug climaxing in a broad label
with the main restrictions being that Arena Pharmaceuticals and partner Eisai conduct a number of post-marketing cardiovascular outcome and safety studies- reasonable. Such a preliminary
approval process (witness also the Avastin-breast cancer controversy) that post-pones these studies to a post-marketing setting was
also in recognition of the fact that demanding them pre-approval would be
financially prohibitive for most small and medium-sized pharmaceutical companies. Moreover,
the fact that the only new, single agent among the three weight loss contenders
happens to be the first one approved, should be further encouragement for
innovative drug developers.
What it means for
RNAi Therapeutics
The acceptance of biomarkers such as weight loss, LDL-cholesterol,
and glycated hemoglobin, together with postponing hard outcomes studies to the
post-marketing setting are the two key ingredients that should greatly increase
the attractiveness of harnessing the liver-targeting potential of RNAi
Therapeutics to go after metabolic and cardiovascular disease opportunities. What is more, what in the end may have tilted
the agency’s opinion in favor of Lorcaserin (in addition to bowing to political
pressure) was the fact that the drug not only promoted weight loss, but also
provided clear benefits in terms of other biomarkers such as lowering blood
sugar levels in diabetic patients.
RNAi Therapeutics candidates should be particularly well
positioned to take advantage of the regulators valuing the totality of the
efficacy data rather than myopically focusing on single end-points that may have been met just marginally. This is because RNAi Therapeutics have the unique potential to simultaneously go after multiple targets (multi-targeting). At the risk of repeating myself, an RNAi
Therapeutic that could reduce not only atherogenic lipids, but also hepatic fat
and increase insulin sensitivity
should be very welcome in such an environment.
The experience with ISIS Pharmaceutical’s mipomersen for
which an NDA has been submitted recently, however, also shows that while the
emerging approach can speed up drug approval, it can also limit the initial
market potential (here, the rare homozygous FH population) and costly outcomes trials may be necessary to address wider patient populations. It can be argued that ISIS and partner
Genzyme simply got unlucky as, unlike the European counterpart, the FDA will
only accept LDL-cholesterol lowering as a sufficient end-point for the hoFH
population; there should be other cases, however, where the first population in
such a staged approval process will justify the investment in the drug development
program already.
In this environment, I look forward to TKM-ApoB and ALN-PCS02 being followed by more metabolic/cardiovascular RNAi Therapeutics candidates, particularly of the multi-targeting type, SNALP-delivered, multi-cassette ddRNAi or otherwise. With the biomarker-based and staged approval approach, it should be possible again for even small companies like Tekmira to bring such programs into later-stage development on their own.
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