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Institutions of Objectivity in Clinical CancerTrials: A History and Sociology of Data Monitoring Committees in Clinical Cancer Trials ,[object Object],Paper presented 03-12-08
A word from our sponsors: CIHR, FQRSC and SSHRC funded research for this presentation.
I. The emergence and development of DMCS
what are DMCs? ,[object Object],[object Object],[object Object],‘ There is irony in that, in the case of trials where we experiment on human beings,  those who do so cannot be ‘trusted’  to see the data they generate while they so experiment. Surely clinical trials must be one of the few fields of scientific inquiry in an open society where researchers are so regarded’.  [Meinert 1998a: 542] ‘ Imagine  a scientific methodology   that  bases its experimental technique on a technology that alters sample size, modifies the study design, and provides guidance to the interpretation of data, but which the methods sections of papers rarely mention and to which papers rarely allude at all. … In fact, participation on a data monitoring committee requires  a vow of silence , a silence that often remains unbroken for years’.  [Wittes 1993: 419]
DMCs in the United States: an overview ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
DMCs are deployed extensively in clinical cancer trials
participant history 1: the administrative origin ,[object Object],[object Object],[object Object],[object Object]
the original Greenberg diagram a recent representation of the NIH model  The Executive Committee has “the responsibility … to review the data analysis coming from the Coordinating Center and to prepare frequent reports to the participants, as well as annual reports to the National Heart Institute”
participant history 2: the statistician’s view ,[object Object]
Armitage and McPherson ( NEJM  1973) ,[object Object]
[object Object],‘ In the early days of ECOG ... we would look at the data formally every six months because we prepared … the agendas for a group. … So we were looking every six months, but we knew even as the theory was just developing, every statistician, every trained statistician knows that if you look too often you might stop a trial for which there is no difference; you stop it by chance alone. … And those were rules of thumb, quite useful rules and there was a very early paper by Haybittle [1971] that made that a bit more formal, that said you know, any decent rule of thumb in sequential design says: “look as often as you want”, well, not exactly but: “look fairly often, and only stop the trial or think about stopping the trial if you see a difference that’s more than 3 standard deviations above the null, or below the null”’.  [Interview with David Harrington, Boston, 22 April 2005]
[object Object],[object Object]
Sequential (2X2) medical trial: Hodgkin’s Disease, Stanford Medical Center, 1967   The group methods replaced the 2X2 sequential methods first developped and used in the 1960s
[object Object],statistics and the ‘mechanical’ mandate of DMCs  ,[object Object],[object Object],[object Object]
‘ I was involved in a trial in which there were no boundaries set in advance and the co-ordinating centre said that if we had used Pocock stopping rules we would have just barely crossed, if we used O’Brien-Fleming stopping rules we wouldn’t have, if we had used stochastic curtailing... and it became completely meaningless’.  [Michael Proschan, 1994] ,[object Object]
what do the participant histories omit? ,[object Object],[object Object]
cancer clinical trials: a new style of practice ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],Style of practice = distinctive configuration of institutions, epistemic concerns and materials that generates specific ways of identifying and investigating research questions, of producing and assessing results, and of regulating these activities [Hacking] ,[object Object],[object Object],[object Object],[object Object],[object Object]
the elements of style in clinical cancer reseach ,[object Object],[object Object],[object Object],[object Object],[object Object]
The Groups are often international in scope
SWOG-S0106  includes 17 sites in Canada and 8 sites in Sweden
the data center ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
The EORTC Data Center: An instance of ‘Central Command’
CALGB 2006 The protocol lies at the core of the new style of practice
DMCs as a solution to the problem of too much information and too few patients ,[object Object],[object Object],[object Object],[object Object]
DMCs were thus established in order to: ,[object Object],[object Object],[object Object],[object Object],‘ Because clinical trials are under increasing public scrutiny, we must use procedures that  protect our research  against the appearance of impropriety’  [R. Simon and R. Ungerleider, NCI, 1997]
the road since 1992 ,[object Object],[object Object],‘ Monitoring a clinical trial is a complex task, best conducted by a small group integrating all the issues that must be addressed. This group should freely and confidentially discuss patient safety, the accuracy of accrual and outcome predictions made at the design stage, protocol compliance, unexpected side effects, recent results from other, similar trials, the place of the trial in the scientific program of the organization conducting the study, and, when appropriate, outcome data. These issues are not separable and should not be discussed in isolation’.   [Statisticians for seven major cooperative groups] ,[object Object],‘ I watched [the independent DMC] grow from a group of ten or twelve people who really didn’t know about the trials they were monitoring to a group that worked very hard to understand the context of those trials in cancer research. … I didn’t see the conflict of interest issue being as large as the NCI people did. I still don’t but I have seen the external data monitoring committees work reasonably well and have even been on a few of them, so in that sense I think it’s turned out to be a good thing’.   [Interview with David Harrington, Boston, 25 April 2005]
II. What kind of institution is a DMC? DMCs are reflexive institutions.
reflexivity as a form of endogenous critical inquiry ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
A typical DMC charter Informal reflexion and formal coding
The Guidance process i) 2001 Draft Guidance document issued ii) 2001 Public Meeting iii) 2006 Guidance document issued Forums for Reflexion
(1) role and purposes of DMCs ,[object Object],‘ In at least three DMCs that I’ve been a part of, rather acrimonious fights erupted at the beginning about my raising these kinds of issues, charges being made that this is a data monitoring committee; those are IRB or steering committee functions; it’s not for the DMC to do’.  [Norman Fost, FDA meeting]
should a DMC be allowed to change sample size? ‘ A clinical trial ... is not a fixed quantity. It’s almost like a living thing. It evolves; it changes; it can change. One of the obvious ways in which a clinical trial might need to be modified has to do with the sample size. When the sample size is calculated, different things are assumed about the rate in the control arm, the rate in the treatment arm. Those assumptions may or may not be valid. And it may turn out that the trial is underpowered and the sample size needs to be adjusted. A data monitoring committee, although it’s not easy, can grapple with this’.  [Gregory Campbell, FDA meeting]
should a DMC be allowed to change sample size? ‘ [a DMC] is seeing data on efficacy and for it to have the ability and the right to change end points and to change crucial aspects of design I think can sacrifice the integrity of the design’.   [Janet Wittes, FDA meeting] ‘ the unblinded data monitoring committee really can’t credibly change end point, sample size, subset plans or anything, any more than an unblinded sponsor could without at a minimum affecting alpha or introducing bias that we don’t know how to correct’.   [Robert Temple, FDA meeting]
should a DMC be allowed to change sample size? ‘ Not all studies are  confirmatory  but those studies that are confirmatory, I’d like to be able to interpret them in that manner. It means ... I’d like to have a pre-specified hypothesis that I then confirm. At the same time, there can well be during the course of a long trial  external information  that could enlighten us as to what the hypothesis really ought to be. I actually don’t have a problem if I’m certain that it’s external data that leads to refinement and this is the essence of where this independence and separation enables or empowers the sponsor to have that flexibility’.   [Thomas Fleming, FDA meeting]
at what point does monitoring become intervention? ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
(2) structure and membership of DMCs ,[object Object],[object Object],[object Object],[object Object],‘ I’ve often had it said that we have to have an odd number of people on the DMC so that when we vote it won’t come out tied. I object strongly to votes on DMCs. I believe that the DMC’s responsibility should include discussing issues at a length and in a depth to arrive at consensus about what ought to be done’.   [Thomas Fleming, FDA meeting]
the issue of interests ,[object Object],[object Object],[object Object],[object Object],[object Object],[object Object]
how many statisticians? ,[object Object],[object Object],[object Object],[object Object],‘ Some wag said that this document is a full employment act for statisticians’.  [DeMets, FDA Meeting] The problem: ‘Suppose that a trial steering committee were considering changing the primary endpoint of the trial. The statistician, knowing the interim results to that point, would know whether the drug being tested was in fact showing a stronger effect on the ‘new’ endpoint than the original endpoint, and would therefore be in an awkward position during this discussion. If the change were to be made, and if final analysis showed a significant effect on the new endpoint, there could be the perception that the interim data influenced the change – that if the trend for treatment effect had been different, the statistician would somehow have found a way to discourage the change in endpoint’.
Does the independent staistician have the expertise? ‘ In the multicenter, cancer cooperative group setting … the trial data manager prepares the data for the interim analysis which is carried out by the trial statistician. Within this setting we feel that it is difficult for a completely independent third party to carry out the analysis for the following reasons: 1. They will not be as familiar with the trial or the data as the trial data manager and trial statistician and are thus more likely to make mistakes in the analysis. 2. With a large number of trials it becomes much more difficult both practically and financially to have the trial analyzed by a third party’. [Richard Sylvester, FDA Dockets]
Should the committee itself remain blind? ,[object Object],[object Object],[object Object],[object Object]
Is there a DMC culture and know-how? ‘ [DMC] decisions and the discussions are very complicated, they’re very nuanced, and they reflect a certain sociology of a committee that varies from committee to committee ... go to every DMC … that you can go to because you can learn a lot, it’s the only way you’re going to understand it and it’s really fun’.   [Wittes, FDA Meeting] ‘ the need for folks specifically experienced and mentored in the process of DMC activities is really very critical and the confidence with which folks are able to invest the responsibilities into the groups is very importantly based on the talent base that exists to accomplish those goals’.  [Conner, FDA Meeting] ,[object Object],‘ Since there are no accepted standards of what constitutes conclusive evidence, the process by which (DMC members) arrive at their decisions must be made transparent’  [NEJM 2004]
III. DMCs and objectivity
[object Object],[object Object],[object Object],[object Object],[object Object],a new form of objectivity for biomedicine
True to nature: selection and synthesis
Mechanical objectivity: automatic transfer
Trained  judgment: pattern recognition
a new form of objectivity for biomedicine ,[object Object],[object Object],[object Object],[object Object]
DMCs and regulatory objectivity ,[object Object],[object Object],[object Object]
Following the rules ,[object Object],[object Object],[object Object]

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Peter Keating Dec2008

  • 1.
  • 2. A word from our sponsors: CIHR, FQRSC and SSHRC funded research for this presentation.
  • 3. I. The emergence and development of DMCS
  • 4.
  • 5.
  • 6. DMCs are deployed extensively in clinical cancer trials
  • 7.
  • 8. the original Greenberg diagram a recent representation of the NIH model The Executive Committee has “the responsibility … to review the data analysis coming from the Coordinating Center and to prepare frequent reports to the participants, as well as annual reports to the National Heart Institute”
  • 9.
  • 10.
  • 11.
  • 12.
  • 13. Sequential (2X2) medical trial: Hodgkin’s Disease, Stanford Medical Center, 1967 The group methods replaced the 2X2 sequential methods first developped and used in the 1960s
  • 14.
  • 15.
  • 16.
  • 17.
  • 18.
  • 19. The Groups are often international in scope
  • 20. SWOG-S0106 includes 17 sites in Canada and 8 sites in Sweden
  • 21.
  • 22. The EORTC Data Center: An instance of ‘Central Command’
  • 23. CALGB 2006 The protocol lies at the core of the new style of practice
  • 24.
  • 25.
  • 26.
  • 27. II. What kind of institution is a DMC? DMCs are reflexive institutions.
  • 28.
  • 29. A typical DMC charter Informal reflexion and formal coding
  • 30. The Guidance process i) 2001 Draft Guidance document issued ii) 2001 Public Meeting iii) 2006 Guidance document issued Forums for Reflexion
  • 31.
  • 32. should a DMC be allowed to change sample size? ‘ A clinical trial ... is not a fixed quantity. It’s almost like a living thing. It evolves; it changes; it can change. One of the obvious ways in which a clinical trial might need to be modified has to do with the sample size. When the sample size is calculated, different things are assumed about the rate in the control arm, the rate in the treatment arm. Those assumptions may or may not be valid. And it may turn out that the trial is underpowered and the sample size needs to be adjusted. A data monitoring committee, although it’s not easy, can grapple with this’. [Gregory Campbell, FDA meeting]
  • 33. should a DMC be allowed to change sample size? ‘ [a DMC] is seeing data on efficacy and for it to have the ability and the right to change end points and to change crucial aspects of design I think can sacrifice the integrity of the design’. [Janet Wittes, FDA meeting] ‘ the unblinded data monitoring committee really can’t credibly change end point, sample size, subset plans or anything, any more than an unblinded sponsor could without at a minimum affecting alpha or introducing bias that we don’t know how to correct’. [Robert Temple, FDA meeting]
  • 34. should a DMC be allowed to change sample size? ‘ Not all studies are confirmatory but those studies that are confirmatory, I’d like to be able to interpret them in that manner. It means ... I’d like to have a pre-specified hypothesis that I then confirm. At the same time, there can well be during the course of a long trial external information that could enlighten us as to what the hypothesis really ought to be. I actually don’t have a problem if I’m certain that it’s external data that leads to refinement and this is the essence of where this independence and separation enables or empowers the sponsor to have that flexibility’. [Thomas Fleming, FDA meeting]
  • 35.
  • 36.
  • 37.
  • 38.
  • 39. Does the independent staistician have the expertise? ‘ In the multicenter, cancer cooperative group setting … the trial data manager prepares the data for the interim analysis which is carried out by the trial statistician. Within this setting we feel that it is difficult for a completely independent third party to carry out the analysis for the following reasons: 1. They will not be as familiar with the trial or the data as the trial data manager and trial statistician and are thus more likely to make mistakes in the analysis. 2. With a large number of trials it becomes much more difficult both practically and financially to have the trial analyzed by a third party’. [Richard Sylvester, FDA Dockets]
  • 40.
  • 41.
  • 42. III. DMCs and objectivity
  • 43.
  • 44. True to nature: selection and synthesis
  • 46. Trained judgment: pattern recognition
  • 47.
  • 48.
  • 49.