1 One Year Post-Exclusivity Adverse Event Review: Tolterodine Pediatric Advisory Committee Meeting June 29, 2005 Lawrence Grylack, MD Medical Officer Division.

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1 One Year Post-Exclusivity Adverse Event Review: Tolterodine Pediatric Advisory Committee Meeting June 29, 2005 Lawrence Grylack, MD Medical Officer Division of Pediatric Drug Development Center for Drug Evaluation and Research Food and Drug Administration

2 Background Drug Information Drugs: Detrol ® and Detrol ® LADrugs: Detrol ® and Detrol ® LA –Tolterodine tartrate is the active ingredient in both drugs. Therapeutic category: Muscarinic receptor antagonistTherapeutic category: Muscarinic receptor antagonist Sponsor: PfizerSponsor: Pfizer Indication: Treatment of overactive bladder with symptoms of urge urinary incontinence, urgency and frequencyIndication: Treatment of overactive bladder with symptoms of urge urinary incontinence, urgency and frequency Original Market Approval: March 25, 1998 for Detrol ® and December 22, 2000 for Detrol LA ®Original Market Approval: March 25, 1998 for Detrol ® and December 22, 2000 for Detrol LA ® Pediatric Exclusivity granted: January 5, 2004Pediatric Exclusivity granted: January 5, 2004

3 Drug Use Trends in Children Almost all pediatric (1-16 years) use for both drugs was in out-patient setting; estimated pediatric prescriptions during 2004: Detrol ® 14,448, Detrol LA ® 53,976 1Almost all pediatric (1-16 years) use for both drugs was in out-patient setting; estimated pediatric prescriptions during 2004: Detrol ® 14,448, Detrol LA ® 53, % of all Detrol ® and 0.8% of all Detrol LA ® claims during 2/04-1/05 were for children. 11.4% of all Detrol ® and 0.8% of all Detrol LA ® claims during 2/04-1/05 were for children. 1 Detrol ® usage decreased by 33% and Detrol LA ® usage increased by 50% in children from 2/02-1/03 period to 2/04-1/05 period. Detrol LA ® prescription claims were 4 times greater than Detrol ® during post-exclusivity period. 1Detrol ® usage decreased by 33% and Detrol LA ® usage increased by 50% in children from 2/02-1/03 period to 2/04-1/05 period. Detrol LA ® prescription claims were 4 times greater than Detrol ® during post-exclusivity period. 1 Pediatric hospital discharges accounted for ≤ 0.2% of all discharges in which a tolterodine product was mentioned from 7/03-6/04. 2Pediatric hospital discharges accounted for ≤ 0.2% of all discharges in which a tolterodine product was mentioned from 7/03-6/ Caremark Dimension RX™, Feb Jan 2005, Data extracted Mar Premier Inc., Jul Jun 2004, Data extracted Apr 2005

4 Pediatric Exclusivity Studies  Three pharmacokinetic (PK), pharmacodynamic (PD) [urodynamic] and safety studies  One clinical efficacy, PK and safety study in patients with overactive bladder

5 PK, PD and Safety Studies in Neurologically Impaired Patients Three 12-week, open-label, dose escalation studies:Three 12-week, open-label, dose escalation studies: –1 month-4 year olds (n=19) received 0.03, 0.06, 0.12 mg/kg/d Detrol ® immediate-release syrup –5-10 year olds (n=15) received 0.03, 0.06, 0.12 mg/kg/d Detrol ® immediate-release syrup –11-15 year olds (n=11) received 2, 4, 6 mg/day Detrol LA ® capsules Of patients in all studies, 78% had myelomeningocoele; others had spinal cord injury or anomalyOf patients in all studies, 78% had myelomeningocoele; others had spinal cord injury or anomaly Urodynamic data inconsistent within and across trials Urodynamic data inconsistent within and across trials Lack of dose-response trends across studies Lack of dose-response trends across studies

6 Phase 3 Efficacy, PK and Safety Studies in Neurologically Intact Patients Two multi-center randomized, placebo-controlled, blinded studies of tolterodine extended –release capsules, 2 mg/day for 12 weeks for the indication: treatment of overactive bladder with symptoms of urge urinary incontinence, urgency and frequencyTwo multi-center randomized, placebo-controlled, blinded studies of tolterodine extended –release capsules, 2 mg/day for 12 weeks for the indication: treatment of overactive bladder with symptoms of urge urinary incontinence, urgency and frequency year olds, 235 treated with drug, 107 with placebo year olds, 235 treated with drug, 107 with placebo –5-10 year olds, 251 treated with drug, 117 with placebo –Detrol LA ® dose was chosen after comparison of the PK of tolterodine and DD01 (the active metabolite) in children, 5 to 10 years, with adults Primary efficacy endpoints for both studies were change from baseline in number of weekly incontinence episodes during waking hours after 12 weeks of treatmentPrimary efficacy endpoints for both studies were change from baseline in number of weekly incontinence episodes during waking hours after 12 weeks of treatment No significant difference in outcome between Detrol LA ® and placeboNo significant difference in outcome between Detrol LA ® and placebo Label states that efficacy in children not demonstratedLabel states that efficacy in children not demonstrated

7 Integrated Review of Safety from Pediatric Studies Database from pediatric exclusivity studies and other pediatric studies conducted by SponsorDatabase from pediatric exclusivity studies and other pediatric studies conducted by Sponsor unique patients exposed to tolterodine unique patients exposed to tolterodine –No deaths –24 Serious Adverse Events (SAEs) in 20 patients including 4 lower UTIs; 4 with pyelonephritis (one in placebo group) –18 patients manifested aggressive and/or abnormal behavior, categorized as non-serious AEs –Excess of UTIs and abnormal behavior in tolterodine- treated patients compared to placebo are included in Detrol LA ® label

8 Summary of Labeling Changes Resulting from Exclusivity Studies Detrol LA ® :Detrol LA ® : –Efficacy not demonstrated –PK: Dose-plasma concentration relationship linear; parent/metabolite ratios differed according to enzyme metabolizer status –Percentage of UTIs in 5-10 year olds higher with Detrol LA ® (6.6%) compared to placebo (4.5%) –Aggressive, abnormal and hyperactive behavior and attention disorders higher with Detrol LA ® (2.9%) compared with placebo (0.9%)

9 Pediatric Adverse Events for Detrol ® and Detrol LA ® : One-Year Post-Exclusivity Period No AE reports receivedNo AE reports received

10 Pediatric Adverse Event Reports after Marketing Approval for Detrol ® (03/25/1998) and Detrol LA ® (12/22/2000) through 02/05/ reports* (25 U.S.); 29 unduplicated reports 29 unduplicated reports 25 Detrol ®, 4 Detrol LA ® 25 Detrol ®, 4 Detrol LA ® Positive de-challenge in 15 patients; positive Positive de-challenge in 15 patients; positive re-challenge in one patient re-challenge in one patient * Raw counts include duplicates

11 Categories of Pediatric Adverse Event Reports for Detrol ® and Detrol LA ® (N=29) –Anti-cholinergic events (9 reports): confusion, lethargy, urine retention, overheating, constipation, flushing, dry mouth, blurry vision –CNS stimulation (8 reports): aggression*, hyperactivity*, irritability, insomnia –Anti-cholinergic plus CNS stimulation (2 reports) –UTI (2 reports) –Medication error (3 reports) –Other (5 reports) * Unlabeled in Detrol ® label Underlined = Unlabeled events in Detrol ® and Detrol LA ® labels

12 Pediatric Adverse Event Reports for Detrol ® and Detrol LA ® : Marketing Approval through 02/05/2005 In 18 reports, the outcome was reported asIn 18 reports, the outcome was reported as serious. serious. –Upon careful review of the 18 reports, there were: 0 deaths 0 deaths 5 hospitalizations 5 hospitalizations 1 disability 1 disability 2 older than 16 years (85 and 16.5 years old) 2 older than 16 years (85 and 16.5 years old) 10 non-serious 10 non-serious

13 Pediatric Adverse Event Reports for Detrol ® and Detrol LA ® with Serious Outcomes since Market Approval 6 reports with serious outcomes:6 reports with serious outcomes: –Hospitalizations One patient with breathing difficulty, nocturnal laryngitis and cough; resolved after tolterodine was discontinued; possibly related to drug;One patient with breathing difficulty, nocturnal laryngitis and cough; resolved after tolterodine was discontinued; possibly related to drug; One patient with transient blindness; event continued after drug was discontinuedOne patient with transient blindness; event continued after drug was discontinued One patient developed heart block, dizziness and chest pain; also on azathioprine; heart block resolved upon stopping tolterodineOne patient developed heart block, dizziness and chest pain; also on azathioprine; heart block resolved upon stopping tolterodine One patient with exfoliative skin rash; positive culture for HSVOne patient with exfoliative skin rash; positive culture for HSV One patient developed convulsionsOne patient developed convulsions –Disability HyperactivityHyperactivity

14 Request for Labeling Revision Issued for Detrol ® Sponsor has been requested by FDA to incorporate safety information that already exists in Detrol LA ® label into Detrol ® label in Pediatric Use sectionSponsor has been requested by FDA to incorporate safety information that already exists in Detrol LA ® label into Detrol ® label in Pediatric Use section – Increased incidence of UTIs and abnormal behavior in tolterodine-treated patients behavior in tolterodine-treated patients compared with placebo compared with placebo –Pediatric efficacy not demonstrated

15 Conclusion This completes the one-year post- exclusivity AE monitoring as mandated by BPCA.This completes the one-year post- exclusivity AE monitoring as mandated by BPCA. FDA recommends routine monitoring of AEs for this drug in all populations.FDA recommends routine monitoring of AEs for this drug in all populations. Does the Advisory Committee concur?Does the Advisory Committee concur?

16 Acknowledgments ODS DRUP Paula Gish Lisa Soule Mark Avigan George Benson Kendra Worthy Daniel Shames Gerald Dal Pan Jean Makie