In phase 2, the drug is studied in patients with the target disease to determine its efficacy (“proof of concept”), and the
CHAPTER 1 Introduction: The Nature of Drugs & Drug Development & Regulation doses to be used in any follow-on trials. A modest number of patients (100–200) are studied in detail. A single-blind design may be used, with an inert placebo medication and an established active drug (positive control) in addition to the investigational agent. Phase 2 trials are usually done in special clinical centers (eg, university hospitals). A broader range of toxicities may be detected in this phase. Phase 2 trials have the highest rate of drug failures, and only 25% of innovative drugs move on to phase 3.
In phase 3, the drug is evaluated in much larger numbers of patients with the target disease—usually thousands—to further establish and confirm safety and efficacy. Using information gathered in phases 1 and 2, phase 3 trials are designed to minimize errors caused by placebo effects, variable course of the disease, etc. Therefore, double-blind and crossover techniques are often used. Phase 3 trials are usually performed in settings similar to those anticipated for the ultimate use of the drug. Phase 3 studies can be difficult to design and execute and are usually expensive because of the large numbers of patients involved and the masses of data that must be collected and analyzed. The drug is formulated as intended for the market. The investigators are usually specialists in the disease being treated. Certain toxic effects, especially those caused by immunologic processes, may first become apparent in phase 3.
If phase 3 results meet expectations, application is made for permission to market the new agent. Marketing approval requires submission of a New Drug Application (NDA)—or for biologicals, a Biological License Application (BLA)—to the FDA. The application contains, often in hundreds of volumes, full reports of all preclinical and clinical data pertaining to the drug under review. The number of subjects studied in support of the new drug application has been increasing and currently averages more than 5000 patients for new drugs of novel structure (new molecular entities). The duration of the FDA review leading to approval (or denial) of the new drug application may vary from months to years. If problems arise, eg, unexpected but possibly serious toxicities, additional studies may be required and the approval process may extend to several additional years.
Many phase 2 and phase 3 studies attempt to measure a new drug’s “noninferiority” to the placebo or a standard treatment. Interpretation of the results may be difficult because of unexpected confounding variables, loss of subjects from some groups, or realization that results differ markedly between certain subgroups within the active treatment (new drug) group. Older statistical methods for evaluating drug trials often fail to provide definitive answers when these problems arise. Therefore, new “adaptive” statistical methods are under development that allow changes in the study design when interim data evaluation indicates the need. Preliminary results with such methods suggest that they may allow decisions regarding superiority as well as noninferiority, shortening of trial duration, discovery of new therapeutic benefits, and more reliable conclusions regarding the results (see Bhatt & Mehta, 2016).
In cases of urgent need (eg, cancer chemotherapy), the process of preclinical and clinical testing and FDA review may be accelerated. For serious diseases, the FDA may permit extensive but controlled marketing of a new drug before phase 3 studies are completed; for life-threatening diseases, it may permit controlled marketing even before phase 2 studies have been completed. “Fast track,” “priority approval,” and “accelerated approval” are FDA programs that are intended to speed entry of new drugs into the marketplace. In 2012, an additional special category of “breakthrough” products (eg, for cystic fibrosis) was approved for restricted marketing after expanded phase 1 trials (Table 1–5). Roughly 50% of drugs in phase 3 trials involve early, controlled marketing. Such accelerated approval is usually granted with the requirement that careful monitoring of the effectiveness and toxicity of the drug be carried out and reported to the FDA. Unfortunately, FDA enforcement of this requirement has not always been adequate.