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80 Teofilovici and Wentworth<br />

In the metastatic disease setting, surrogate markers related to tumor<br />

response can be utilized. In the earlier-disease/adjuvant treatment setting, however,<br />

in which tumor response cannot be assessed, a reliable marker has yet to be<br />

identified. In this better-prognosis setting, there are many scientific and technological<br />

hurdles to be overcome, even ones as basic as availability of immunoassays<br />

that are amenable to routine use and can undergo adequate validation.<br />

Work continues in the development of reliable immunological biomarkers.<br />

Following the 2006 Meeting of the Cancer Vaccine Consortium, Finke<br />

et al. identified the challenges of developing effective anticancer immunotherapies<br />

as related to the following factors: (1) underlying heterogeneity in<br />

some of the cancers and patient cohorts selected for study, (2) the longer time<br />

required to establish an effective cellular immune response versus the observation<br />

period designed into the study, and (3) diminished immunocompetence in<br />

patients with high tumor burden. Planning for phase 3 trials also encounters the<br />

difficulty that arise when using historical data to estimate the mean survival time<br />

or other end points in the control or experimental groups and aggressive projections<br />

of the ultimate benefit of active cancer immunotherapy. Finally, there is<br />

the long time and high cost of running clinical studies with cancer vaccines (31).<br />

REGULATORY CONSIDERATIONS AND A NEW CLINICAL PARADIGM<br />

There are a few regulatory considerations that have the opportunity to facilitate<br />

clinical development of cancer vaccines. In December 2006, the U.S. FDA issued<br />

a proposed rule to amend the regulation concerning charging patients for investigational<br />

new drugs (INDs). If the proposed role becomes effective as currently<br />

written, it will permit charging for a broader range of investigational uses than<br />

presently allowed. This allowance could provide a potential mechanism to help<br />

partially fund the necessary long and expensive late-stage trials of cancer vaccines.<br />

A new mechanism for drug approval was recently adopted in Europe that<br />

allows for granting a conditional marketing authorization (CMA) prior to full<br />

marketing approval for a treatment that preliminarily indicates a positive riskbenefit<br />

assessment in late-stage trials. In life threatening or orphan disease settings,<br />

CMAs allow patient access to treatments that have demonstrated clinically meaningful<br />

but less statistically robust findings, which require subsequent confirmation<br />

in post-marketing trials. CMAs provide an opportunity for more comprehensive<br />

cost recovery compared with charging patients for investigational treatments.<br />

A new development paradigm for cancer vaccines was recently proposed by<br />

the Cancer Vaccine Clinical Trial Working Group (CVCTWG), a group of more<br />

than 50 experts from academia, regulatory bodies, and the biotech/pharmaceutical<br />

industry from America and Europe (32). The authors propose a clinical development<br />

model in which therapeutic cancer vaccines are investigated in two general<br />

types of clinical studies: proof-of-principle trials and efficacy trials. Designed to<br />

account for biologic features of cancer vaccines, the proposed paradigm “supports<br />

a more flexible, expeditious, and focused clinical developmental process with

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