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    The Truth About Cancer - How Well Tested Are Cancer Drugs

    by Maryann Napoli

    With a certain amount of regularity a new cancer drug makes headlines, generating an enormous
    amount of hope as well as pressure to make the product swiftly available. In time, we usually learn
    that the drug’s benefit is much more modest than was originally portrayed in the media, and soon
    oncologists begin to prescribe the drug for other forms of cancer without waiting for clinical trials to
    prove its effectiveness.

    Tumor Shrinkage

    Contrary to popular belief, drug companies are not required to prove that their drugs prolong survival.
    Until the mid-1980s, all cancer drugs were approved solely on the basis of what researchers call the
    “tumor response.” In other words, a drug company needed only show that the drug caused a tumor to
    shrink, not necessarily to disappear.

    Years ago, a change in the approval process was recommended by the FDA’s own Oncologic Drug
    Advisory Committee. The committee members, primarily cancer experts unaffiliated with any government
    agency, knew that tumor shrinkage often has little or no relation to survival. The committee proposed the
    novel idea that a drug company should be required to prove that a drug provided some benefit that was
    meaningful to the patient, such as increased survival or an improvement in symptoms. The committee
    argued further that the potential benefit of tumor shrinkage did not necessarily outweigh the substantial
    toxicity of cancer drugs.

    This recommendation was made in the mid-1980s, but change at the FDA comes slowly, as a recent
    assessment of new drug approvals has demonstrated. From 1990 through 2001, the FDA approved
    66 new cancer drugs. Prolonged survival was not proven for 48 drugs. And tumor response was the
    basis of approval for 35 drugs.

    Variations in End Points

    “The FDA has a certain amount of regulatory flexibility to make an assessment of the side effects
    versus the efficacy of new products,” said Richard Pazdur in a telephone interview. The director of
    oncology drug products at the FDA’s Center for Drug Evaluation and Treatment, Pazdur had been
    asked why so few new drugs have been proved to prolong survival.

    “The drug company must prove that its product provides a longer life, a better life, or a favorable
    effect on an established end point for a better life,” he explained. The FDA’s flexibility comes into
    play on the last item, “an established end point for a better life.” One example of an established end
    point, says Pazdur, is a complete response in leukemia: that is, the bone marrow is normal and the
    blood counts have normalized.

    Even so, there is a hierarchy of established end points. “Survival is the gold standard of end points
    because it is the most meaningful to all people,” Pazdur said. There can be no misinterpretation when
    the end point concerns survival: the patient is either dead or alive. “Whereas the other end points,
    such as tumor response rate, are usually determined by X-rays or scans,” he continued. “There can
    be variations in the radiologists, the techniques of how the X-rays or scans are obtained, which can
    make it confusing and unreliable. Also, there is a subjective judgment in reading these X-rays
    and scans.”

    Accelerated Approval

    These cautions notwithstanding, the FDA still allows the use of tumor shrinkage as the sole end point
    in the approval of certain drugs. In 1992, the agency introduced an accelerated approval (AA) process.
    The idea behind AA is to get drugs quickly to advanced-cancer patients in whom all available options
    have failed. Consequently, tumor shrinkage was the sole basis of the AA for 10 of 11 new drugs.
    The rationale: Shrinking a lung tumor might, in the FDA’s view, be “reasonably likely” to alleviate
    breathing difficulties.

    The testing for AA is minimal. The new drug is given to about 30 or so participants who have run out of
    options. In what is called a phase II trial, there is no comparison group: everyone in the study gets the
    new drug. Consequently, this type of trial is not likely to provide a true picture of the drug’s toxicity or
    efficacy. That’s why a drug given AA must continue to be studied to see if it provides any benefit in
    erms of increased survival or symptom improvement. “The drug companies usually do a large trial in
    which the new drug is compared to the standard drug,” said Pazdur. “This usually takes two to four
    years.” And what if the drug company does not comply? “We have a process for rapidly removing the
    drug from the market,” Pazdur replied.

    Still, some not so well tested drugs are available for several years following an AA, and oncologists
    are free to prescribe them for cancers other than the type for which the products received approval.
    Or, more often, oncologists can add the new product to a multiple-drug regimen that in itself has
    never been studied. “Yes, this is called off-label use, which is fairly common in the practice of
    oncology in the U.S.,” Pazdur agreed. “But this involves the practice of medicine, and the FDA
    does not control the practice of medicine.” Unless their oncologists tell them, cancer patients do
    not know whether they are being given a drug off-label. “We would like patients to read the drug
    label to see the approved indications and contraindications,” advised Pazdur, who said that the
    information is freely available at the FDA’s web site.

    For More Information

    To read a drug label, go to www.fda.gov or to the Physicians’ Desk Reference (PDR), which is
    updated yearly and available at most local libraries and large bookstores. The label is daunting
    for its extensive length, tiny type and medical jargon. It is, however, the only source for results
    of the FDA-required tests. The section entitled “Indications” will identify the purpose(s) for
    which the drug has been proven beneficial. If you can’t find your type and stage of cancer
    listed under “Indications,” this signals off-label use.

    Unfortunately, only the rare cancer patient well versed in clinical trials will be able to discern
    whether the label is identifying a drug that has gone through the less-rigorous AA process.
    For example, capecitabine was given AA (on the basis of tumor response) for advanced breast
    cancer in 1998. The 2002 Physicians’ Desk Reference describes capecitabine’s testing as a
    “phase II, single-arm trial,” which signals AA. Another clue can be found under “Indications,
    ” where response rate is described as the basis for the drug’s use for metastasized breast
    cancer. However, the much watered-down patient version of the capecitabine label (which
    appears after the information aimed at professionals) does not include an explanation of these
    terms. The patient’s label makes no mention of the fact that the drug was approved through the
    accelerated process. Capecitabine is sold under the brand name Xeloda.

    Go to the web site of the National Cancer Institute, and then click into the following succession
    of options: “treatment,” “chemotherapy,” and “newly approved cancer treatments.” You will find
    explanations of phase II trials, off-label drug use (complete with Q and A: “Can off-label drug
    use be harmful?”), and many other relevant terms. People without access to the Internet can
    call the National Cancer Institute toll-free at 800/4-CANCER to get this information mailed
    to them.

    When recommending a new cancer drug to a patient, oncologists will often quote “response rate”
    without explaining what it means. Ask. This article has addressed how new drugs receive FDA
    approval. But once on the market, they are often studied eventually in large randomized,
    controlled trials as part of a multiple-drug regimen.

    Ask for the evidence to support a proposed chemotherapy regimen. Here’s one way to phrase
    the question: “Can you give me a citation for the studies that show this drug or drug-combination
    will benefit people with my stage and type of cancer?”

    The citation will allow you to do a Medline search (ask the librarian at your local public library) to locate
    the study and determine the exact nature of the benefit. Medline is a service available through the
    National Library of Medicine. It provides free access to the abstracts, or summaries, of the studies
    published in a large proportion of the world’s medical journals. Some public libraries will retrieve the
    entire article at no charge, but the article can also be purchased on-line.

    Maryann Napoli is the associate director of the Center for Medical Consumers in New York City.
    This article is adapted with permission from HealthFacts, the organization’s monthly newsletter.
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