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Patients Continue to Be Inadequately Informed of Risk for Breast Implant-Associated ALCL

In the News, News Stories & Editorials, We're In the News, , , , , ,

Christina Bennet, MS, Cancer Therapy Advisor: February 8, 2021

Although the risk for breast implant-associated anaplastic large-cell lymphoma (BIA-ALCL) has been well-documented, patients considering breast implants continue to be inadequately informed of the propensity for disease development. Awareness of BIA-ALCL has risen since 2020, but adequate safeguards have not yet been put in place, according to experts in the field.

“There have been efforts made [to ensure patients are informed], but they have not been successful,” Diana Zuckerman, PhD, president of the National Center for Health Research (NCHR), said in an interview with Cancer Therapy Advisor.

The most recent effort to more frontally disclose the risk for BIA-ALCL is a final guidance document released by the FDA on September 28, 2020.1 The guidance, which applies to all breast implants, advised breast implant manufacturers to add a black box warning that mentions the risks associated with breast implants such as BIA-ALCL. In the guidance, the FDA also encouraged manufacturers to incorporate a patient decision checklist in the labeling to “better ensure certain information is received and understood by patients.”1,2 Manufacturers, however, are not required to follow these recommendations.

Zuckerman, who is a member of the Breast Implant Working Group, said she was surprised by the FDA’s decision to recommend rather than require these facets of the guidance. “We don’t have the answer to that question other than we have talked to FDA officials who said that at least some of this will at some point be a requirement, but we don’t know when that is,” she said.

With no mandates in place to ensure that patients receive information about the risks for BIA-ALCL—among other breast implant-associated complications—upfront, the industry is left to educate—and this does not seem to be working.

Patient advocates Terri McGregor and Jennifer Cook, both of whom have received a BIA-ALCL diagnosis, discussed a misleading patient brochure that has further contributed to the misinformation about breast implant-associated cancer risk. Sold online by the American Society of Plastic Surgeons (ASPS), the brochure featured the symbol for breast reconstruction awareness—a modified pink ribbon—and the slogan “Closing the loop on breast cancer.”3

The brochure was sponsored by several companies, including 2 prominent breast implant manufacturers, Allergan and Mentor. Though the document was promoted on Twitter by the ASPS and users were encouraged users to “stock up now” ahead of Breast Reconstruction Day,3,4  it notably made no mention of BIA-ALCL—not even on the page that describes the risks and safety issues associated with breast implants.

Conflicts of Interest Cloud Risk Disclosure

[…]

Eric Swanson, MD, a plastic surgeon at the Swanson Center for Cosmetic Surgery in Leawood, Kansas, told Cancer Therapy Advisor that plastic surgeons’ financial ties to breast implant manufacturers are part of the reason why they have been slow to respond to the issue of BIA-ALCL. “There’s a big problem with conflict of interest in plastic surgery. Once [a person has] taken funds from a company, it is very rare for the taker to be critical of that company,” Swanson said.

[….]

Zuckerman described the ASPS brochure as “terribly” out of date. “The Institute of Medicine report is more than 20 years old, and there has been a great deal of research since then,” she said.

[….]

The ASPS Brochure: Current Status

When Cancer Therapy Advisor inquired about the content of the brochure, an ASPS representative agreed that the information was “outdated” and removed the brochure from sale on its website.

Enclosed in the ASPS brochure was a list of websites that included breastimplantsafety.org, which—despites its domain name—did not include any safety information about breast implants. Instead, the domain redirected users to a different domain, smartbeautyguide.com, the patient site for The Aesthetic Society, a professional organization for plastic surgeons. A representative for The Aesthetic Society told Cancer Therapy Advisor that breastimplantsafety.org was active until 2015, when it migrated to their patient site, Smart Beauty Guide.

“We have been developing and will launch our new Aesthetic Society website that will include a dedicated section for patient education,” the representative wrote in an email. Within days of being contacted by Cancer Therapy Advisor, The Aesthetic Society updated the breastimplantsafety.org domain name to direct users to an existing page that provides resources about breast implants, including information about BIA-ALCL and breast implant illness, a systemic condition characterized by a wide range of symptoms that is currently under FDA investigation.18

Read the full article here

Statement on Keytruda for Early Stage Triple Negative Breast Cancer

Breast Cancer, Breast Cancer, Testimony & Briefings, , ,

February 9, 2021

The National Center for Health Research is a nonprofit think tank that scrutinizes the safety and effectiveness of medical products.  We don’t accept funding from companies that make those products, so we have no conflicts of interest.  We welcome the opportunity to provide our views on Merck’s application for approval of Keytruda for the indication of high-risk early stage triple negative breast cancer.

Triple negative breast cancer has a lower survival rate than other breast cancers.  However, chemotherapy clearly improves 5-year survival.  Patients need additional treatment options but the bottom line for patients is that FDA should not approve an indication that is not proven to have clinically meaningful benefits, especially when the treatment has clear risks.   

The first issue to address is whether there is evidence that immune checkpoint inhibitors (ICIs) are effective for TNBC.  We agree with FDA scientists that “there is still uncertainty regarding ICIs for TNBC” based on the results from several clinical trials.

  • KEYNOTE-119 failed to meet its primary OS endpoint. 
  • KEYNOTE-355 has not met its OS endpoint. 
  • IMpassion130: clinical benefits need to be confirmed
  • IMpassion131 interim OS results favored control group

The second major issue pertains to pCR data in the study.  The results indicate only 7.5% improvement in pCRs at IA3 (the most recent interim analysis), which the FDA scientists point out may not be clinically meaningful even if statistically significant.  We agree.  The problem is that it is impossible to determine how this slight improvement would affect overall survival, and even if it does, how much neoadjuvant and adjuvant use each contribute to any benefit. 

FDA scientists were clear to the sponsor that there were concerns with their study design and that the application for approval was premature since the study was not yet completed.  The agency made it clear that that the event free survival (EFS) study results were not statistically significant, not clinically meaningful, and did not show a “stable trend.” 

FDA reviewers are clear that data on overall survival “are too immature to provide a conclusive interpretation regarding the difference in OS between treatment arms.” 

What about safety?

At IA3 (the most recent interim analysis), there were 96 deaths, which FDA points out “accounts for only 32% of the events needed for the final analysis. Therefore, the OS estimate may be unreliable, and the treatment effect size reported is subject to uncertainty.”

It is notable that the study included patient-reported outcomes (PROs), but unfortunately, KEYNOTE-522 was not designed to compare differences in PROs (symptoms, side effects, health-related quality of life), nor were these patient-reported endpoints prospectively identified and statistically tested. 

PRO assessments should have been more frequent, both for neoadjuvant and adjuvant treatments

Since many high-risk, early-stage TNBC patients will be cured with standard therapy, the key issue is whether this drug has benefits that outweigh the risks.  The benefits are unclear.  Therefore, the evidence of the drug’s “added toxicity” is worrisome.  FDA scientists concluded that “Some of these toxicities may be irreversible or require lifelong medication in patients cured of their breast cancer.

Although the sponsor counted 2 deaths due to immune-mediated adverse events, the FDA counted 4.  Either way, these deaths must be considered worrisome given the lack of clear evidence of a meaningful benefit.  And, there are many other serious adverse events in addition to the small number of deaths.   All-grade and grade ≥3 immune-mediated AEs and infusion reactions occurred more frequently in Keytruda patients compared to placebo:    43% vs. 22% for all grade AEs, and 15% vs. 2% for high grade AEs.  In fact, 10% of Keytruda patients had immune-mediated AEs and infusion reactions leading to hospitalization compared to 1% of placebo.  These included the following relatively high number of adverse events:

  • Infusion reactions (18%), 
  • Hypothyroidism (15%), 
  • Severe skin reactions (6%)
  • Hyperthyroidism (5%), adrenal insufficiency (3%), pneumonitis (2%), and thyroiditis (2%).

It is important to note that these adverse events were not resolved at the last assessment in the study for 19% of Keytruda patients.   It is also important to note that 16% of the Keytruda patients initiated thyroid hormone replacement during the study.

In summary, we agree with FDA scientists that the deaths are “particularly concerning in this curative disease setting.”

  • “All grade and grade ≥3 immune-mediated AEs were increased in [Keytruda] patients.’
  • Some “may be severe or lifelong.” 
  • The adjuvant treatment has fewer adverse events but “has not demonstrated a significant effect on any efficacy endpoint, and may be adding risk without benefit.”

Based on our analysis, we agree with the overall conclusions made by FDA scientists: 

  1. Neoadjuvant Keytruda “confers only a small absolute improvement in pCR rate of questionable clinical meaningfulness.”
  2. Event-free survival and overall survival are “immature and unreliable.”
  3.  “The design and results of KEYNOTE-522 do not currently support a role for adjuvant [Keytruda].”
  4. “Supportive data of clinical benefit … are lacking.” 
  5. Adding Keytruda “is associated with increased toxicity … which may be severe, irreversible, and/or require life-long medication in potentially curable and otherwise healthy patients.” 

In conclusion, the FDA and the medical community do patients no favors to approve a treatment that is not proven to benefit them and at the same time is proven to cause harm for a substantial percentage of patients.  The studies should be continued to determine whether the benefit of adding Keytruda to other treatments outweigh the risks.

 

This written statement was submitted to the FDA on February 8, 2021 and an oral version with PowerPoint slides was presented at the FDA Advisory Committee meeting on February 9, 2021.

We are pleased that the FDA Advisory Committee agreed with our views and voted 10-0 on February 9 in favor of deferring an FDA regulatory decision until the study is completed.

Comparison of Acupuncture and Therapy as Treatments for Cancer Survivors with Insomnia

Quality Of LIfe, ,

Meg Seymour, PhD and Nina Zeldes, PhD, National Center for Health Research

Most cancer patients experience insomnia,[1] which is defined as having trouble falling and/or staying asleep. Most cancer patients with insomnia are prescribed sleep-aid medications as treatment,[2] which can have unpleasant side effects, such as memory problems and health risks.[3]  In fact, studies show that people who take sleep medication more often are more likely to develop many types of cancer (You can read this article for more information). Fortunately, in 2019, cancer researchers at Memorial Sloan Kettering found that there are safer and possibly more effective treatments for cancer patients’ insomnia: acupuncture, as well as a type of  therapy specifically developed for treating insomnia, called Cognitive Behavioral Therapy for Insomnia (CBT-I).

Acupuncture is a traditional Chinese treatment where a trained acupuncturist places special needles into the skin at specific points at the body, which are associated with different aspects of health. There are certain places on the body that acupuncturists place needles in order to treat sleep problems, as well as pain.

CBT-I is a type of therapy that uses several different approaches to treat insomnia. It uses methods such as “cognitive restructuring,” which trains patients to reduce anxious thoughts in ways that make it easier to fall asleep. Another strategy is “sleep restriction,” in which patients primarily stay in bed for sleeping, not for watching TV, reading, or other activities. The goal is to associate being in bed with sleeping, not thinking about issues that can interfere with sleeping.

Comparing acupuncture and therapy as insomnia treatments

Acupuncture and cognitive behavioral therapy had previously been proven effective for insomnia. For example, CBT-I had previously been shown to reduce insomnia among cancer survivors,[5] and acupuncture has been found to be effective for insomnia patients without cancer.[6] The goal of the 2019 study was to compare these two treatments for insomnia among cancer survivors, to determine which was more effective. 

The study compared the two treatments in 160 cancer survivors whose insomnia was severe enough that they were diagnosed with insomnia. Participants were randomly assigned to receive either 10 sessions of acupuncture treatment over 8 weeks, or 7 sessions of CBT-I over the course of 8 weeks. The researchers measured the severity of the participants’ insomnia, as well as other symptoms such as pain and anxiety. Participants’ symptoms were measured before they began treatment, right after completing the 8 weeks of treatment, and every four weeks up to 20 weeks after they finished the treatment. Measuring symptoms at these different times compared how effective the treatments were in both the short-term and the long-term.

Which treatment was most effective? 

The researchers found that both treatments were effective at reducing insomnia, and they also helped patients reduce their use of sleep aids, even at 20 weeks after finishing treatment. About 25% of patients were using at least one prescription sleep aid at the beginning of the study, but only 17% used the medication 20 weeks after treatment. CBT-I was slightly more effective than acupuncture at reducing insomnia symptoms and improving overall sleep quality, as well as reducing the amount of time it took to fall asleep and reducing the number of times participants woke up in the night. 

Twenty weeks after completing treatment with CBT-I, participants fell asleep an average of 24 minutes faster, and those who received acupuncture fell asleep an average of 11 minutes faster than before they started treatment. That might not seem like much benefit, but it is comparable to the small benefit of sleeping pills.[7] After treatment, both groups stayed asleep for longer at night. However, those who received acupuncture stayed asleep even longer than those who received CBT-I. Right after completing treatment, participants who had acupuncture treatment slept for an average of 62 more minutes a night, 27 more minutes than those who were treated with CBT-I. After 20 weeks, those who received acupuncture still slept 51 minutes more than before treatment, which was 5 and a half minutes more than those treated with CBT-I. That is much more additional sleep than is typical of sleeping pills.[7]

However, this difference in the effectiveness of the two treatments was only true for men. The two treatments were equally effective at reducing overall insomnia severity in women. The researchers also found that CBT-I was only more effective among White participants, highly educated participants, and those with lower pain levels. Otherwise, the two treatments were equally effective. 

In addition to evaluating insomnia severity, the researchers also measured participants’ fatigue, anxiety, depression, and overall quality of life as measured by mental and physical health. The two treatments were equally effective at improving those symptoms.

The bottom line

Both acupuncture and CBT-I helped reduce insomnia symptoms in cancer survivors, but CBT-I was more effective for men, Whites, highly educated participants, and those with lower pain levels. The researchers concluded that CBT-I should be used as the first line of treatment for cancer-related insomnia, but pointed out that patients might find it difficult to find CBT-I treatment. Unfortunately, there are few trained CBT-I therapists, but acupuncture is a good alternative. In addition, acupuncture was more effective for the treatment of short-term pain than CBT-I. 

Despite the shortage of well-trained CBT-I therapists, the availability of online therapy can help those who are interested get access to this treatment. For more information on online therapy, you can read this article. 

 

All articles are reviewed and approved by Dr. Diana Zuckerman and other senior staff.

The National Center for Health Research is a nonprofit, nonpartisan research, education and advocacy organization that analyzes and explains the latest medical research and speaks out on policies and programs. We do not accept funding from pharmaceutical companies or medical device manufacturers. Find out how you can support us here.

 

References 

  1.     Savard J, Ivers H, Villa J, et al. Natural course of insomnia comorbid with cancer: an 18 month longitudinal study. Journal of Clinical Oncology. 2011; 29(26):3580–3586.
  2.     Berger AM, Matthews EE, Kenkel AM. Management of sleep-wake disturbances comorbid with cancer. Oncology. 2017 Aug 16;31(8).
  3.     Kripke DF. Hypnotic drug risks of mortality, infection, depression, and cancer: But lack of benefit. F1000Res. 2016;5:918.
  4.     Garland SN, Xie SX, DuHamel K, Bao T, Li Q, Barg FK, Song S, Kantoff P, Gehrman P, Mao JJ. Acupuncture versus cognitive behavioral therapy for insomnia in cancer survivors: a randomized clinical trial. JNCI: Journal of the National Cancer Institute. 2019; 111(12):1323-31.
  5.     Johnson JA, Rash JA, Campbell TS, et al. A systematic review and metaanalysis of randomized controlled trials of cognitive behavior therapy for insomnia (CBT-I) in cancer survivors. Sleep Medicine Review. 2016;27:20–28.
  6.     Yin X, Gou M, Xu J, et al. Efficacy and safety of acupuncture treatment on primary insomnia: a randomized controlled trial. Sleep Medicine. 2017;37:193–200.
  7. Carr, T. The Problem With Sleeping Pills. Consumer Reports.com. https://www.consumerreports.org/drugs/the-problem-with-sleeping-pills/. Updated December 2018.

A C.D.C. analysis describes anaphylaxis after people have received the Pfizer-BioNTech vaccine as ‘rare’

We're In the News, , , , ,

Roni Caryn Rabin, New York Times: January 11, 2021

Any site that administers the currently authorized vaccines must be prepared to recognize and treat a severe allergic reaction that may occur, though it is “a rare outcome,” federal health officials said.

Of the nearly 2 million Americans who received coronavirus vaccinations developed by Pfizer and BioNTech during a 10-day stretch last month, 21 experienced a serious and potentially life-threatening allergic reaction called anaphylaxis, federal health officials said Wednesday.

Although the risk is ten times higher than the risk for anaphylaxis after a seasonal flu vaccine, officials described the reaction as “a rare outcome.”

The rate of anaphylaxis following vaccination was estimated to be 11.1 per million doses administered, compared with 1.3 cases of anaphylaxis per million doses of influenza vaccine administered, officials said.

“We know that safety is one of the public’s biggest concerns about the Covid vaccine,” said Dr. Nancy Messonnier, director of the National Center for Immunization and Respiratory Diseases at the Centers for Disease Control and Prevention.

“The anaphylaxis rate may seem high compared to the flu vaccine, but I want to reassure you: This is still a rare outcome.”

Any site that administers the vaccine must be prepared to recognize and treat a severe allergic reaction that may occur, federal health officials said. And though there is less information about reactions to the Moderna vaccine than to the Pfizer-BioNTech vaccine, Dr. Messonnier said, “At this point we really don’t have enough data to say there’s any difference in the risks, so the recommendations apply to both.” Recipients who experience anaphylaxis after receiving the first dose of the vaccine should not receive the second dose, officials said.

Other than the anaphylaxis reactions, which occurred shortly after vaccination, “Our vaccine safety systems haven’t picked up any worrisome signals,” Dr. Messonnier added. “The known and potential benefits of the Covid vaccine outweigh the risk of getting Covid-19.”

The C.D.C.’s analysis of adverse reactions, published on Wednesday, included only those to the Pfizer-BioNTech vaccine administered between Dec. 14 and Dec. 23.

[…]

The vast majority of anaphylaxis reactions — 90 percent — occurred in women, who made up slightly more than half of vaccine recipients. A surprising number of those who went into anaphylaxis — 14 of the 21 — had never experienced an anaphylactic reaction prior to receiving the vaccine, and four had no known allergies at all.

Of the 21 who had reactions, 20 had recovered or been discharged home, and information was lacking on one individual. Nineteen were treated with epinephrine, and four were hospitalized, including three in intensive care. Seventeen were treated in an emergency department.

The C.D.C. said it was still investigating another seven reports of anaphylaxis following the vaccine, which have not been confirmed. The Vaccine Adverse Event Reporting System also identified 83 cases of nonanaphylaxis allergic reactions after the Pfizer-BioNtech vaccination; these people developed symptoms like rash and mild respiratory symptoms within a day of receiving the vaccine.

Among the 21 vaccine recipients who experienced anaphylaxis, 17 were known to have allergies to a variety of triggers, including foods, insects, pets and medications. The median time for anaphylactic reaction was 13 minutes after immunization, but one patient developed the reaction two and a half hours afterward.

Patients with known allergies have been warned to bring an epinephrine injector when they get vaccinated, and providers have been advised to keep patients with allergies for observation for 30 minutes following inoculation.

The new information is disconcerting, said Diana Zuckerman, president of the National Center for Health Research.

“The flaw in the system is that there was a small number of people who had a reaction 30 minutes or later,” she said. “It’s one thing to say everybody should hang around for 15 minutes. But the range was up to 150 minutes, and people aren’t going to hang around that long.”

To read entire article, see https://www.nytimes.com/live/2021/01/06/world/covid-19-coronavirus

Congressman calls for FDA to continue vaccine trials

In the News, News Stories & Editorials, We're In the News, , , , ,

D’Andre Henderson, ABC News: December 29, 2020.

WASHINGTON, D.C. (WRIC) — Americans are hopeful that the COVID-19 vaccines will make 2021 a better year than 2020. However, there are concerns that Pfizer and Moderna will stop their clinical trials and immediately treat everyone in their placebo group.

Some scientists, doctors and now a Congressman argues that can be dangerous because they said there is still so much unknown about the vaccines.

Rep. Llyod Doggett of Texas wrote a letter to the Food and Drug Administration (FDA) urging for the clinical trials to continue.

“the continuation of clinical trials is critical to our understanding of the efficacy and length of immunity the vaccines offer,” Doggett wrote.

In the letter, Doggett said while the initial results received from Pfizer and Moderna are showing positive results, it’s not definitive given the limited data.

[…]

“Clinical trials have suffered from a lack of diverse participant enrollment and evaluation of subpopulations,” Doggett said. “Including individuals with comorbidities, children, pregnant and breastfeeding patients, long-term care residents and individuals with diverse racial and ethnic backgrounds.”

Diana Zuckerman, President of the National Center for Health Research, a non-partisan think tank in Washington D.C., agrees that the clinical trials should continue. She said healthcare workers who volunteered for the clinical trials should have immediate access to the vaccine if they want it.

“Like most public health experts, I’ve been very concerned that Pfizer and Moderna told the FDA that they want to stop their clinical trials of the COVID vaccine and instead immediately inoculate everyone in their placebo groups,” Zuckerman said. “While I understand the desire to reward the clinical trial volunteers for their service, it would be a huge loss of information from a public health point of view. Losing the placebo group means we’d have no way to scientifically determine which of the vaccines – if any — have 95% efficacy rates that last more than 2 or 3 months. Or how long the vaccine works on people over 75.”

Zuckerman added the people who volunteer for the clinical trials shouldn’t be vaccinated before those in priority groups such as teachers, essential workers, etc.

“Since many of the study volunteers are young and healthy, it also seems unfair for them to “cut in line” for a vaccine while healthcare workers and others at high risk are still waiting their turn,” she said.

[…]

Read the full article here

Covid-19: Should vaccine trials be unblinded?

In the News, News Stories & Editorials, We're In the News, , , , ,

Jeanne Lenzer, BMJ: December 29, 2020.

The lack of planning for how to treat participants in covid-19 vaccine trials is a bad precedent, with the loss of potentially valuable safety and efficacy data, say research experts. Jeanne Lenzer reports:

 

In October the US Food and Drug Administration issued non-binding guidance to manufacturers of covid-19 vaccines urging them to devise a method to allow volunteers in their studies’ placebo arms to receive the vaccine while also maintaining the integrity of ongoing scientific data collection.1 Emergency use authorisation was not “grounds for stopping blinded follow-up,” said the agency.23

The companies say they have an ethical obligation to unblind volunteers so they can receive the vaccine. But some experts are concerned about a “disastrous” loss of critical information if volunteers on a trial’s placebo arm are unblinded.45

To try to tackle the problem the FDA invited Steven Goodman, associate dean of clinical and translational research at Stanford University, for a recommendation that could balance the right of volunteers to find out whether they were in the placebo arm and the simultaneous need to preserve scientific data.

Goodman recommended a study design endorsed by Anthony Fauci, director of the National Institute of Allergy and Infectious Diseases: a blinded crossover study in which placebo recipients would be given the vaccine, and vice versa.235 That would ensure that all volunteers receive the vaccine but would be unaware of which shot they received at which time. This would allow ongoing surveillance of safety issues and more time to observe any waning effects of the vaccine and the possible need for booster doses.

But the companies said that the demands of a blinded crossover design were “onerous” and might not be feasible.6 And even before the FDA advisory committee meeting on Moderna’s vaccine on 17 December, the company notified volunteers that they could learn their status if they chose to receive the vaccine.

Pfizer also sent a letter to its trial participants one week after its vaccine was authorised on 10 December.7 It told them that, on request, they could learn whether they were in the placebo arm so they could receive the vaccine as it became available and according to recommendations of the US Centers for Disease Control and Prevention.

Asked by The BMJ whether the FDA had set any baseline requirements for the companies regarding the removal of blinding, the agency declined to answer, referring the journal to the respective companies for their plans.

Pfizer told The BMJ that the “move from the placebo group to the vaccine group would be completely optional, and participants would be encouraged to remain blinded throughout the full study duration.” Moderna failed to respond to several requests for comment.

Loss of data

Diana Zuckerman, president of the National Center for Health Research, told The BMJ that the FDA could have demanded that companies use the blinded crossover design for them to win full approval for their vaccines. She said that failure to do that meant the loss of future reliable data, which is especially concerning given that preliminary data are insufficient to determine efficacy.

“I’m especially concerned that Pfizer’s vaccine trials included only five people aged 75 and older who were diagnosed with covid-19, with an unspecified number of those defined by Pfizer as severe cases,” she said. “That makes it impossible to determine how effective the vaccine is for frail elderly patients.”

Although the FDA has granted the vaccines emergency use authorisation, to get full licence approval two years of follow-up data are needed. The data are now likely to be scanty and less reliable given that the trials are effectively being unblinded.

Consumer representative Sheldon Toubman, a lawyer and FDA advisory panel member, said that Pfizer and BioNTech had not proved that their vaccine prevents severe covid-19. “The FDA says all we can do is suggest protection from severe covid disease; we need to know that it does that,” he said.

He countered claims, based on experience with other vaccines, six weeks of follow-up was long enough to detect safety signals. Six weeks may not be long enough for this entirely new type of “untested” [mRNA] vaccine, Toubman said.

Goodman wants all companies to be held to the same standard and says they should not be allowed to make up their own rules about unblinding. He told The BMJ that, while he was “very optimistic” about the vaccines, “blowing up the trials” by allowing unblinding “will set a de facto standard for all vaccine trials to come.” And that, he said, “is dangerous.”

Footnotes

  • Correction: On 30 December we amended the final paragraph to clarify Steven Goodman’s comment.

This article is made freely available for use in accordance with BMJ’s website terms and conditions for the duration of the covid-19 pandemic or until otherwise determined by BMJ. You may use, download and print the article for any lawful, non-commercial purpose (including text and data mining) provided that all copyright notices and trade marks are retained.

https://bmj.com/coronavirus/usage

References

  1. ↵ Food and Drug Administration. Emergency use authorization for vaccines to prevent covid-19: guidance for industry. 2020. https://www.fda.gov/media/142749/download.
  2. ↵ Food and Drug Administration. Vaccines and Related Biological Products Advisory Committee meeting December 10, 2020. 2020. https://www.fda.gov/media/144245/download.
  3. ↵ Food and Drug Administration. Vaccines and Related Biological Products Advisory Committee December 17, 2020 meeting briefing document. 2020 https://www.fda.gov/media/144434/download.
  4. ↵ WHO Ad Hoc Expert Group on the Next Steps for Covid-19 Vaccine Evaluation. Placebo-controlled trials of covid-19 vaccines—why we still need them. N Engl J Med2020. doi:10.1056/NEJMp2033538.
  5. ↵ Weiland CZ. Noah. Many trial volunteers got placebo vaccines. Do they now deserve the real ones? New York Times. 2 Dec 2020. https://www.nytimes.com/2020/12/02/health/covid-vaccine-placebo-group.html.
  6. ↵ Karlin-Smith S. Covid-19 vaccine sponsors want US FDA to find alternatives for control-arm data after first EUA. Pink Sheet. 2020. https://pink.pharmaintelligence.informa.com/PS143143/COVID-19-Vaccine-Sponsors-Want-US-FDA-To-Find-Alternatives-For-Control-Arm-Data-After-First-EUA.
  7. ↵ Tanne JH. Covid-19: FDA panel votes to approve Pfizer BioNTech vaccine. BMJ2020;371:m4799.  doi:10.1136/bmj.m4799 pmid:33310748 FREE Full TextGoogle Scholar 

Read the full article here

NCHR Statement by Dr. Diana Zuckerman at FDA Covid Vaccine Advisory Committee

Testimony & Briefings, , , ,

October 22, 2020

I’m Dr. Diana Zuckerman, president of the National Center for Health Research. Our center scrutinizes the safety and effectiveness of medical products, and we don’t accept funding from companies that make those products, although I’ve personally inherited stock in Johnson & Johnson. My expertise is based on post-doc training in epidemiology and as a faculty member and researcher at Vassar, Yale, at Harvard. I’ve also worked at HHS, the U.S. Congress and White House.

We’ve heard today that the agencies are doing many things right, but the vaccine trials have serious design flaws. The standards set in FDA guidances and the study protocols make it likely that vaccines that will be authorized or approved won’t achieve what the public and policy makers expect. Instead, these vaccines will only be proven to reduce the risk of mild infections but not proven to reduce the risk of hospitalization, ICU use, or deaths.

The major flaws are as follows:

  • The FDA’s proposed primary endpoint is defined as symptomatic Covid-19 that can include only 1 very mild symptom, such as a mild cough or sore throat – as long as the person has tested positive.
  • FDA’s requirement of at least 2 months median follow-up after vaccination or placebo is too short to study efficacy.  Even if a person is exposed during that time, we don’t know the correlates of protection and so we need a longer follow-up to know how long an effective vaccine remains effective.  We can’t rely on post-market studies for that information, because once a vaccine is on the market, many people in the placebo control group will switch to a vaccine.
  • We don’t know whether diversity of study participants will be achieved in terms of age, race, or co-morbidities, especially for people who are exposed to the virus.
  • The requirement of at least 5 serious Covid-19 cases in the placebo group is completely inadequate for 2 reasons:
    • Serious Covid-19 cases are too loosely defined, and could include a case of mild Covid-19 if the patient has a blood oxygen saturation under 93%. But thousands of otherwise healthy Americans have levels below that.
  • Even if the definition were more stringent, such as requiring hospitalization or death, and even if there were no such cases among the vaccinated patients, the absolute difference in disease between 0 and 5 serious cases would not be clinically meaningful to individuals and could easily have occurred by chance.

The American public has been told for months that life can go back to normal when we have a vaccine.  It isn’t FDA’s job to achieve that overly optimistic goal for any vaccine, but it is FDA’s job to make sure that a vaccine has meaningful benefits for the health and lives of most Americans, and especially those most at risk.

Testimony of Dr. Diana Zuckerman of NCHR before the FDA Advisory Committee on Pfizer COVID Vaccine

Testimony & Briefings, , ,

December 10, 2020

I’m Dr. Diana Zuckerman, president of the National Center for Health Research.  Thank you for the opportunity to speak today.

Our center scrutinizes the safety and effectiveness of medical products, and we don’t accept funding from companies that make those products. My expertise is based on post-doc training in epidemiology and as a previous faculty member and researcher at Vassar, Yale, and Harvard, and a fellow in bioethics at University of Pennsylvania.  I’ve also worked at HHS, the U.S. Congress and the White House.  

Today I will focus on 2 major concerns and how to improve the data:

#1:  The 2 month median follow-up is too short, so it’s essential that the randomized controlled trial be continued, to learn about long-term safety and efficacy.

#2:  There’s a lack of diversity in COVID cases:  There were 0 Black cases in the vaccine group, and only 7 Black cases in the placebo group.  

There were 0 cases who are ages 75+ in the vaccine group, 5 in placebo group  

We need more cases in these groups in order to understand the efficacy.  I’m concerned that conclusions will be inappropriately drawn, as when an article in the Wall Street Journal article included a chart saying the vaccine was 100% effective in Blacks.

THERE are also too few severe cases to draw conclusions:

There were only 4 severe cases after the 2nd dose:  3 of which were in the placebo group.  Not all these cases required hospitalization.  In summary, there are too few severe cases to draw conclusions about whether the vaccine prevents severe COVID.

Long-term care patients were not included in the study.  About 800 people ages 75 and older were in the study but only 5 were cases (all of them placebo).

We want to save their lives, but how can we ensure informed consent to nursing home patients with no data?  How many frail elderly or their family members can make an informed decision based on so little information?

We need longer-term data to fully understand if benefits outweigh the risks for frail patients and all races/ethnicities, and for everyone else as well.  That’s why it is essential that FDA ensure the continuation of the randomized controlled trial.

In conclusion, EUA is not approval and it should have more restrictions than approval would have:

  • FDA should require continuation of the RCT while targeting EUA to priority populations, especially healthcare workers.  Study participants in the placebo group should not “jump the queue.”  Continuing the RCT for at least a few more months will make an important difference in knowledge.
  • EUA should not allow off-label use, and celebrities and others should not be allowed to jump the queue.  Off label use could occur when urgently needed under FDA’s Expanded Access program.
  • FDA should delay access to vaccines by placebo group unless they are in priority populations.  I am concerned about the blinded crossover proposal, because if the vaccine is effective very long-term, such as 9 months or a year, we would lose that information if placebo participants were crossed over after just 3-9 months.   Blinded crossover would only provide useful information if the efficacy doesn’t last long.  Let’s hope that isn’t true. 

Dr. Diana Zuckerman’s Testimony on Moderna’s COVID Vaccine Before the FDA Advisory Committee

Testimony & Briefings, Uncategorized, ,

December 17, 2020.

I’m Dr. Diana Zuckerman, president of the National Center for Health Research.  Thank you for the opportunity to speak today.

Our center scrutinizes the safety and effectiveness of medical products, and we don’t accept funding from companies that make those products. My expertise is based on post-doc training in epidemiology and as a previous faculty member and researcher at Vassar, Yale, and Harvard, and a fellow in bioethics at University of Pennsylvania.  I’ve also worked at HHS, the U.S. Congress and the White House.

Today I will focus on 3 major concerns:

#1:  The 2 month median follow-up is too short, so Moderna’s proposal to immediately unblind and offer to vaccinate the entire placebo group should be rejected.

#2:  Moderna made a good effort to include a diverse group of participants, but only 4 COVID cases were in Black patients, and there were even fewer in other racial groups.  We can’t assume that the vaccine was highly effective in demographic groups with so few cases because just 1 Covid case in the vaccinated group would have greatly reduced the efficacy rate.

The data on cases for participants with co-morbidities was slightly more substantial, with 24 placebo cases and only 1 vaccinated case

#3  I’m glad to see that unlike Pfizer, Moderna provided info on the total number of  participants who reported 1 or more adverse events.  That’s important.  Unfortunately, the total of severe systemic adverse events after the 2nd dose was over 17% for vaccinated group compared to 2% for the placebo group.

There are also too few severe cases to draw conclusions:

There were 30 severe cases after the 2nd dose, and none were in the vaccine group.  This is a strong finding.  However, only 9 of the severe cases required hospitalization; 12 involved the questionable criteria of at least slightly low blood oxygen saturation.

Long-term care patients were not included in the study.  About 1300 people ages 75 and older were in the study, almost half of them vaccinated, but only 3 were cases (all of them placebo).  Only 15 cases were in patients over 65.

We want to save their lives, but with no data it’s not possible to provide useful informed consent to nursing home patients.  That puts a tremendous burden on those patients and their family members to decide whether or not to be vaccinated.

We need longer-term data to fully understand the benefits and risks for different types of patients.  The vaccine is clearly effective, but does that last 2 months, 4 months, or a year?  We need to know that, and that’s why it is essential that the blinded randomized controlled trial is continued.

In conclusion, EUA is not approval, and it should have more restrictions than approval would have.  The EUA should be targeted to priority populations, because if the EUA applies to all adults, celebrities and others who are well-connected will cut in line.  We’ve already seen that this week.

Other people could apply for the vaccine under FDA’s Expanded Access program.

We need at least 1 year of blinded, randomized, controlled data.  We agree with Dr. Goodman’s proposal that FDA should delay access to vaccines by members of the placebo group unless they are in priority populations.  Blinded crossover has limitations because it can’t control changes in the community spread of the virus, but it is better than not continuing a blinded controlled study, if continuing the current study is not possible.

How Effective Is the Mask You’re Wearing? You May Know Soon

News Stories & Editorials, We're In the News,

A CDC division is working with an industry standards group to develop filtration standards — and products that meet them will be able to carry labels saying so.

Sheila Kaplan, The New York Times: December 16, 2020

More than 100,000 varieties of face masks are currently for sale. They come in silk, cotton and synthetics; with filters and without; over-the-head and over-the-ears. They have sparkles and sunflowers; friendly greetings and insults; cartoon characters and teeny reindeer.

What they don’t have is a label that shows how well they block infectious particles, an omission that has frustrated public health officials during the coronavirus pandemic. Those experts note that there is a big range in the effectiveness of various designs, and some barely filter out particles at all.

“The most fundamental, basic question is, What is the safest mask and how do I assure that I have that, and my family members and children have that?” said Fran Phillips, who stepped down in August from her post as deputy health secretary of Maryland. “It’s so startling that we are here in this moment and we don’t have that information.”

That may change soon. A division of the Centers for Disease Control and Prevention is working to develop minimum filter efficiency standards, and labels showing which products meet them, for the vast and bewildering marketplace for masks and other face coverings.

The National Institute for Occupational Safety and Health, a division of the C.D.C. known as NIOSH, has been quietly writing guidelines with an industry standard-setting organization, ASTM International (formerly the American Society for Testing and Materials), that are expected to be made public next month.

“By having a standard in place you will be able to know what level of protection is being achieved and you’ll have a consistent way of evaluating these products,” said Maryann D’Alessandro, director of the NIOSH National Personal Protective Technology Laboratory.

Since the pandemic began, there has been little federal oversight of masks and other face coverings. Both the Food and Drug Administration and the C.D.C. have some authority over the industry. The F.D.A., which regulates medical devices, shares authority with NIOSH for oversight of N95 respirators, which are the most protective devices available. But most of the masks the general public wears are just pieces of cloth and don’t come under any regulatory oversight.

Sales of masks took off after the F.D.A. issued an emergency measure in April that said in part that the agency would not take action against companies selling them to the general public. At the same time, however, the F.D.A. also noted that these products “may or may not meet fluid barrier or filtration efficiency levels.” That warning didn’t hurt the market, and some critics now blame the F.D.A. for the poor quality of many of the products being sold.

“There were many things the F.D.A. could have done to improve the situation, especially after research started coming out about which masks worked and which didn’t,” said Diana Zuckerman, president of the National Center for Health Research, a nonprofit health policy group. “F.D.A. could have issued a guidance that masks should be fitted, at least two layers of cloth, not made of stretchy materials, etc. Instead, there was a free-for-all.”

The effectiveness of masks can range “from 0 to 80 percent, depending on material composition, number of layers and layering bonding,” said Dale Pfriem, president of Protective Equipment Consulting Services and a member of the standards development working group addressing mask guidelines.

[…]

Read the full article here https://www.nytimes.com/2020/12/16/health/covid-masks-effectiveness.html