American Association for Cancer Research
American Cancer Society Cancer Action Network
American Childhood Cancer Organization
American College of Radiation
American Society for Therapeutic Radiology and Oncology
American Society of Clinical Oncology
American Society of Hematology
Association of American Cancer institutes
Cancer Research and Prevention Foundation
Cancer Treatment Research Foundation
Coalition of Cancer Cooperative Groups
CureSearch National Childhood Cancer Foundation
International Cancer Advocacy Network
International Myeloma Foundation
Kidney Cancer Association
The Leukemia and Lymphoma Society
The Lustgarten Foundation for Pancreatic Cancer Research
Melanoma Research Affiance
Oncology Nursing Society
Pancreatic Cancer Action Network PanCAN
Prostate Cancer Foundation
Society of Nuclear Medicine
The Society of Gynecologic Oncologists
The V Foundation/or Cancer Research
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Testimony of the National Coalition for Cancer Research
House Committee on Energy and Commerce Health Subcommittee Hearing:
"Examining the Increase in Drug Shortages."
September 23, 2011
The
National Coalition for Cancer Research commends the House Committee on Energy
and Commerce Health Subcommittee for holding this important hearing to address
the severe drug shortage issue that is significantly impacting cancer research
and care.
The
National Coalition for Cancer Research is a nonprofit coalition of 24 national
cancer research, cancer care and patient organizations representing cancer
patients and survivors, children with cancer and their families, cancer
researchers, nurses and physicians, and cancer hospitals, centers, clinics and
specialized research institutions. The organization directs its efforts at
making widely known the value of cancer research and the major contributions
the National Cancer Program has made to the biomedical sciences and related
fields, patient care, to the reduction of cancer incidence, morbidity and
death, and issues faced by cancer survivors.
Drug
Shortages Impacting Cancer Clinical Trials
According
to the University of Utah Drug Information Service, there were 211 reported
drug shortages for calendar year 2010. Already this year, there have been 198
reported drug shortages as of August 25, 2011, suggesting that shortages are
continuing to increase. If the current trend continues, it is estimated that
more than 300 drugs will be in short supply by the end of 2011, an increase of
approximately one-third.
The
shortage of some cancer drugs is not just affecting patients currently
undergoing treatment, but it is also having a significant negative impact on
current and future cancer clinical trials. Of the drugs on the most current
shortage list, 22 are cancer agents. Of the 22 cancer agents on the drug
shortage list, 15 are urgently needed for clinical research purposes.
This
impact on cancer research is largely due to the fact that placebos (sugar
pills) are rarely used in cancer clinical trials, and are never used alone if
an acceptable treatment is available. Therefore, cancer clinical trials are
traditionally designed to test the safety and efficacy of the standard of care
against, or in combination with, a new treatment being investigated. When the
drug that is the standard of care is in short supply or is no longer being
manufactured, it severely compromises high priority clinical trials.
These
shortages have resulted in important cancer clinical trials being delayed,
suspended and/or halting the accrual of new patients into them. Halting a trial
wastes the investment made in the treatment, data management and time
investment by the patients and clinical scientists participating in the study
and causes the loss of valuable information. In some cases, clinical trial
sponsors have been placed in the difficult position of, when permitted,
utilizing alternative regimens that are not part of the original protocol due
to a shortage of the existing drug being used as part of the investigation. For
some clinical trials, particularly those with FDA registration implications and
requirements, substitutions of drugs used in the trial are not permitted.
Furthermore,
as patients are recruited for clinical research trials with the intent to
receive an investigational therapy, the treatment described in the consent form
details both the benefits, side effects, and other standard of care treatment
options. It is concerning that a patient who opts to receive an investigational
treatment in combination with an existing drug, which is short supply, could
have instead elected to receive alternative, standard treatment- perhaps in a
more timely way. Treatment delays of days to months are critical in the life of
a cancer patient and could limit their chances for a cure or remission of their
disease.
Another
residual impact of drug shortages is the delay in obtaining the data necessary
to bring new cancer therapeutics to patients. With more than 400 cancer agents
in various stages of development, it is imperative that cancer clinical trials
continue uninterrupted in order to obtain the necessary data to seek approval
of new anti-cancer drugs as soon as possible.
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Following
are examples of the impact the current drug shortages are having on cancer
clinical trials:
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Cooperative Group research sites report they are unable to enroll patients in
certain clinical trials, even though the patients meet protocol eligibility
requirements, due to the lack of an existing cancer drug being used in the
clinical trial.
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Due to a shortage of the drug doxorubicin, two important clinical trials have
been delayed. These clinical trials were designed to test this drug in
combination with novel agents in patients with Advanced Recurrent Epithelial
Ovarian Cancer and those with Hepatocellular Carcinoma of the liver, which is
one of the most common tumors in the world and is a leading cause of cancer
deaths.
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Daunorubicin is a chemotherapy treatment for children and adults with Acute
Lymphoblastic Leukemia and Acute Myelogenous Leukemia. In one adult trial, a
comprehensive cancer center in Alabama reported that, although a patient was
eligible to participate in a study, they had no daunorubicin at the center.
Drug substitutions are not allowed for this study, so they were unable to
enroll the patient into the study.
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The Children's Oncology Group reports difficulties in obtaining daunorubcin for
its pediatric Acute Lymphoblastic Leukemia studies. In one trial, a
substitution is allowed by the National Cancer Institute when no drug is
available; however, the substitution is more toxic, resulting in increased risk
for patient harm and side effects.
These
are but a few examples of how the shortages of existing cancer therapeutics are
impacting cancer clinical trials. Additional examples from various parts of the
country are provided in the attached supplemental information accompanying this
testimony.
This
unprecedented drug shortage situation comes at a time when tremendous advances
are being made in the treatment of cancer.
A robust and sustained cancer clinical trial
enterprise is essential if this positive trend in
cancer survivorship is to continue, particularly
given that there are some forms of cancer for which the five year survival rate is
still below 50%. Addressing the drug shortage issue is a critical component to
the continued advances in clinical cancer research and treatment.
We
understand and appreciate the complexity of this issue. We are working with our
colleagues in the biomedical research and provider communities to identify
potential regulatory and legislative solutions to address this ever-growing
problem. However, we cannot overemphasize the urgent need for continued
bipartisan efforts to act thoughtfully and expeditiously in order to resolve
this critical issue.
The
National Coalition for Cancer Research looks forward to working with the
members of the United States House of Representatives and Senate, the
Department of Health and Human Services, the Food and Drug Administration and
the biomedical research community to address this urgent matter.
We
thank you for the opportunity to provide this testimony for your consideration.
American
Association for Cancer Research
American Cancer Society Cancer Action Network
American Childhood Cancer Organization
American College of Radiology
American Society of Clinical Oncology
American Society of Hematology
American Society for Radiation Oncology Association of American Cancer
Institutes/Gateway for Cancer Research
Coalition of Cancer Cooperative Groups
CureSearch Childhood Cancer Foundation
Friends of Cancer Research
International Cancer Advocacy Network
International Myeloma Foundation Kidney Cancer Association
Leukemia and Lymphoma Society
The Lustgarten Foundation
Melanoma Research Alliance
Oncology Nursing Society
Pancreatic Cancer Action Network Prevent Cancer Foundation
Prostate Cancer Foundation
Society of Gynecologic Oncologists
V Foundation for Cancer Research
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Addendum to testimony of the National Coalition for Cancer Research House
Committee on Energy and Commerce Health Subcommittee Hearing:
"Examining
the Increase in Drug Shortages."
September 23, 2011
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Following
are additional examples of cancer research studies which have been impacted by
drug shortages:
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One large phase III trial compares outcomes for lung cancer patients
given an accepted standard treatment (either carboplatin and paclitaxel or
carboplatin, paclitaxel, and bevacizumab) and patients given the same treatment
plus an additional drug - cetuximab. A research site in Lexington, KY
reports not being able to offer participation in this clinical trial because
the center cannot guarantee availability of paclitaxel to these patients.
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No daunorubicin in supply at a research site in Birmingham, Alabama
led to physicians being unable to enroll a patient with Acute Myeloid
Leukemia in a cooperative group protocol, and there was no
substitution allowed.
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Standard initial treatment for children with Acute Myeloid Leukemia,
which has a survival rate of between 50-60%, involves the drug daunorubicin,
which is in short supply.
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A cancer center in Boston, MA almost missed an opportunity for
one of its patients to participate on the trial due to the shortage of
daunorubicin. Fortunately, the patient was randomized to the clofarabine arm of
the trial. If the patient had been randomized to the daunorubicin arm, the
center may not have been able to keep the patient on study due to the
daunorubicin shortage. Until the drug shortage is resolved, the center may not
be able to continue to accrue patients onto this trial.
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The same center reports that lack of availability of paclitaxel, one of the
drugs used in a clinical trial, has been affected by this drug shortage and
substitution for paclitaxel is not allowed for this study. If the paclitaxel
supply is expected within three weeks from the planned date of treatment,
treatment can be delayed for those three weeks by the participating clinical
trial sites. After a three-week delay, participating clinical trial sites are
asked to remove patients from the study. Until the shortage of paclitaxel
is resolved, the center may not be able to accrue patients to this trial
because of uncertainty over drug supply.
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Shortage of drug daunorubicin for a cooperative group are impacting a study
testing a new therapy for patients (ages 18-60) with newly diagnosed Acute
Myeloid Leukemia, as reported by a research site in Pittsburgh,
PA, where drug has not been available since June I, 2011.
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A cancer center in St. Louis, MO reports that a clinical trial
for breast cancer that has had scientific approval for over two months, but
has not begun because the clinical trial involves a study drug in combination
with doxorubicin. Due to the shortage of doxorubicin, the
investigator is rewriting the trial protocol to change the doxorubicin to
another drug. This will delay final approval and activation of the study, which
delays this treatment option for its patients.
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Due to the national shortage and allocation of doxorubicin, a cancer center in
Tampa, FL has had to limit accmal to a study involving patients with Advanced
Recurrent Epithelial Ovarian Cancer. It has also been extremely difficult to
obtain sufficient supplies of doxorubicin for patients that were previously
enrolled in the trial prior to the shortage. One of its active patients is
currently on the "waiting list" to receive an allocation of the drug.
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The Albuquerque, NM, cancer center recently lost 21 breast cancer patients to
accrual to a cooperative group trial due to the lack of doxorubicin. The trial
is exploring improved treatment methods for women with breast cancer who have a
high risk of recurrence. This same research site was unable to enroll an
additional 19 patients to other trials for breast, melanoma or ovarian cancer
primarily due to the doxorubicin and doxorubicin shortages.
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A research site in Lombard, IL reported shortages of 5FU and Taxol. The site
had three patients with stage 3 colon cancer eligible for a cooperative group
study, who were not able to go on protocol due to the shortage of 5FU. In
another study involving 5FU a center in St. Louis, MO reported a 5FU shortage
that impacted one of its active colon trials. The investigator is working on
adding language allowing capecitabine to be substituted for 5FU.
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Shortages of Taxol reported by a research site in Wheeling, WV, had led to loss
of patient accrual to a cooperative group study for patients with inoperable
non-small cell lung cancer, stage III. The site seeks to ensure that supply
will be available prior to placing patients on study, and the pharmacy at the
site is advising that it cannot guarantee supply.
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The same location in Wheeling, WV reported shortage of Taxol had led to loss of
patient accrual in a cooperative group study testing a second line treatment
for patients with metastatic esophageal or GE (gastro-esophageal) junction
cancer. Adenocarcinoma of the esophagus and the gastro-esophageal junction is
reportedly one of the fastest rising malignancies.
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Without Taxol, 5FU, or Leucovorin, many patients have been unable to
participate in trials at a research site in Columbus, OH. Access to drug varies
with hospitals in this community network, but priority in the shortage is given
to the adjuvant patient population. The site is now getting Taxol in but it is
not promised to study patients at this time nor can the site assure its
physicians that if they start a patient that there will be enough of the drug
for the entire treatment plan.
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