Correspondence Misleading data analyses in salmeterol (SMART) study In 1996, due to reports of paradoxical bronchospasm associated with the use of GlaxoSmithKline’s (GSK’s) newly approved, long-acting inhaled agonist salmeterol, and previous epidemics of asthma-related deaths in patients taking other long-acting agonists,1 the company initiated a randomised trial comparing salmeterol (Serevent, known as Advair when combined with the steroid fluticasone) to placebo. The results have never been published. We only know the detailed results of this crucial study because the drug came before the US Food and Drug Administration’s (FDA’s) PulmonaryAllergy Drugs Advisory Committee on July 13, 2005, and because the FDA now provides the Advisory Committee briefing materials, including reviews by its own medical officers, on its website before the meeting.2 These documents provide insight into the manner in which the company manipulated the data it submitted to the FDA in an apparent attempt to convince the agency that the drug’s risks were smaller. The Salmeterol Multicenter Asthma Research Trial (SMART) was designed to randomise 60 000 asthma patients to either salmeterol 42 g twice daily or placebo. The study duration was 28 weeks, with patients examined about every 4 weeks. Investigators were also asked to report (but not actively seek out) any serious adverse event that occurred within 6 months after the patient completed the trial. The primary outcome was combined respiratory-related deaths and lifethreatening experiences; secondary outcomes included asthma-related deaths, asthma-related deaths or lifethreatening experiences, and all-cause deaths. In September, 2002, the SMART Data Safety Monitoring Board (DSMB) www.thelancet.com Vol 366 October 8, 2005 e-mail submissions to correspondence@lancet.com Relative risk (95% CI) Respiratory-related deaths and life-threatening experiences Asthma-related deaths Asthma-related deaths or life-threatening experiences All-cause deaths 28-week study 28-week study plus 6 months 1·39 (0·91–2·13) 1·16 (0·78–1·72) 4·33 (1·24–15·21) 1·68 (0·99–2·85) 2·50 (0·97–6·44) 1·52 (0·92–2·52) 1·31 (0·83–2·08) 1·04 (0·70–1·55) Table: Relative risks of primary outcome and major secondary outcomes in SMART study with and without inclusion of post-trial data met to review the data on the 25 858 patients who had been enrolled to date. Based on nearly significant treatment-related increases in both the primary outcome variable and asthma-related deaths, the DSMB offered two alternatives: either increase the target sample size by at least 10 000 patients or terminate the study “with dissemination of findings as quickly as possible”. GSK selected the latter option. GSK presented the interim analysis of the SMART data at the 2003 meeting of the American College of Chest Physicians, claiming that “The interim analysis was inconclusive”.3 Based on the interim data, on Aug 11, 2003, the FDA modified the labelling for both Serevent and Advair to include a black box warning of a “small but significant increase in asthma-related deaths”. With the interim results in hand, the company finalised a statistical methods appendix, which it submitted to the agency for the first time on Aug 29, 2003, along with the final study data. In a significant deviation from the original protocol, the appendix permitted including in the study dataset adverse events that were reported in the 6 months after the termination of the trial. The table presents the results of the SMART study according to whether or not the post-trial results are included. For the primary outcome variable, as well as for each of the three major secondary outcome variables, the inclusion of the posttrial data produces an apparent diminution of the dangers associated with salmeterol. GSK did not specify to the FDA which dataset it had submitted. Only on April 26, 2004, after the FDA specifically enquired as to which dataset had been provided, did the agency learn that the company had provided only the dataset that included the 6-month data. The medical officers state that “The Division presumed the data represented [only] the 28-week period as the 28-week period is clinically the period of interest”. The FDA recommended that any further labelling changes be based on the protocolspecified 28-week study, which it forced the company to provide. At the July 13, 2005, Advisory Committee meeting, the committee recommended strengthening the labels for both Serevent and Advair to encourage concomitant inhaled corticosteroid use.4 The agency has not made a final decision on the label. It is now approaching 3 years since the SMART study was terminated. The results have still not found their way into print (GSK told the Advisory Committee that they have been accepted for publication in Chest) and the drugs’ labels have still not been finalised. Instead, the company, seemingly under little pressure from the FDA, has succeeded in drawing out the process and initially misleading the agency, physicians, and patients with not-per-protocol analyses that diminished the drug’s apparent risks. In the absence of the transparency associated with Advisory Committee meetings, these deceptions would never have come to public attention. In 2001, however, only 21% of new drug approvals were preceded by Advisory 1261 Correspondence Committee meetings, allowing most drugs to avoid similar public scrutiny.5 We declare that we have no conflict of interest. *Peter Lurie, Sidney M Wolfe plurie@citizen.org Public Citizen’s Health Research Group, 1600 20th Street NW, Washington, DC 20009, USA 1 2 3 4 5 Stolley PD. Why the United States was spared an epidemic of deaths due to asthma. Am Rev Respir Dis 1972; 105: 883–90. US Food and Drug Administration. Medical officer review. Provided for: Meeting of Pulmonary-Allergy Drugs Advisory Committee, July 13, 2005. http://www. fda.gov/ohrms/dockets/ac/05/briefing/20054148B1_03_02-FDA-Smart-Study.pdf (accessed July 20, 2005). Knobil K, Yancey S, Kral K, Rickard K. Salmeterol Multi-center Asthma Research Trial (SMART): results from an interim analysis. Meeting of American College of Chest Physicians, Orlando, FL, USA; Oct 27, 2003. Anon. Serevent, Foradil use with steroids should be strongly urged in labeling. The Pink Sheet July 18, 2005: 12–13. Office of the Inspector General. FDA’s review process for new drug applications: a management review. Washington, DC: Department of Health and Human Services, 2003. GlaxoSmithKline’s reply Contrary to the assertions posed by Peter Lurie and Sidney Wolfe, GSK has acted responsibly and transparently and communicated with a sense of urgency to ensure that health-care professionals and patients had access to the results of SMART. SMART was a 28-week, randomised, double-blind safety surveillance study consisting of a single clinic visit at which patients ( 12 years) received seven canisters (120 doses per canister) of salmeterol or placebo, added to their usual asthma therapy. Patients were not required to return for clinic visits, but were contacted every 4 weeks by phone to collect information about serious adverse events. Respiratory-related deaths or lifethreatening experiences was the primary endpoint, which required an estimated sample size of 30 000. However, after 15 000 patients were enrolled, the actual rate of primary 1262 events was about half that expected, and the sample size was increased to 60 000. The protocol specified collection of reported events during the 28-week study period and a 6-month follow-up, since patients might have had access to, and used, study medication during this period. Study data were collected and analysed by a clinical research organisation. The only dataset analysed for the interim analysis included events from the 28-week plus 6-month period and were provided to an independent DSMB, not to GSK. The interim analysis suggested worse outcomes in salmeterol-treated patients, mainly African-Americans, and the DSMB recommended that, ideally, the study be completed within 2 years, or if that was not possible, the study should be terminated and the results disseminated. After discussions with the DSMB, GSK was provided with unmasked results of the interim analysis and subsequently terminated the study due to difficulties in enrolment and findings in AfricanAmericans. In collaboration with the FDA, numerous activities were undertaken to immediately communicate SMART results to health-care professionals. On the day SMART was stopped (Jan 23, 2003), a Dear Healthcare Professional letter was delivered by overnight mail to all US health-care professionals who had prescribed salmeterol or salmeterol-containing products within the previous year. Simultaneously, notices on both the FDA and GSK websites were posted. A second letter was sent when the prescribing information for Serevent and Advair was changed to include a boxed warning with the results of the interim analysis (Aug 11, 2003). Results of the interim analysis were presented at the American College of Chest Physicians meeting as a latebreaking abstract on Oct 27, 2003, which was the first national meeting with high attendance of respiratory physicians. There were non-reviewed cases present when SMART was terminated. Furthermore, because outstanding deaths from patients lost to follow-up might have altered the results, two searches of the National Death Index database were done, which resulted in a final dataset (December, 2003). This final dataset was analysed and reported to the FDA in February, 2004. Subsequently, the FDA requested that GSK further refine the analysis to include data from the 28-week treatment period because the power calculations were based on 28 weeks of study treatment. These data were reported to the FDA in May, 2004. There were no substantive differences between the final data for SMART and those for the interim analysis. The labelling for Serevent and Advair were again updated in September, 2004, to reflect this final analysis for SMART. SMART results have also been posted on the GSK Clinical Trial Registry1 and contain both the 28-week and 28-week plus 6-month analyses. In addition, the SMART paper,2 submitted in November, 2004, to Chest, contains both analyses, and has been accepted for publication. In summary, GSK has acted responsibly, transparently, and has communicated rapidly through multiple channels to ensure that the findings from SMART were available to healthcare professionals and patients. Kathy A Rickard kathy.a.rickard@gsk.com Vice President, Clinical—North America, Respiratory Medicine Development Center, GlaxoSmithKline, 5 Moore Drive, Research Triangle Park, NC 27709, USA. 1 2 SLGA5011: a double-blind, randomized, placebo-controlled surveillance study of asthma event outcomes in subjects receiving either usual pharmacotherapy of asthma or usual pharmacotherapy plus salmeterol 42 mcg twice daily. http://ctr.gsk.co.uk/ Summary/salmeterol/studylist.asp (accessed Sept 20, 2005). Nelson HS, Weiss ST, Bleecker ER, Yancey SW, Dorinsky PM, and the SMART Study Group. The Salmeterol Multicenter Asthma Research Trial (SMART): a comparison of usual pharmacotherapy for asthma or usual pharmacotherapy plus salmeterol. Chest (in press). www.thelancet.com Vol 366 October 8, 2005