Draft monograph: Maridebart cafraglutide — submissions
The 9 submissions received, published in full with declared interests and secretariat responses.
§2Submissions and responses
9 submissions were received. Each is published in full below with its declared interest, the secretariat response and the disposition. The Institute publishes submissions it did not accept in the same form as those it did.
Local reactions are omitted from the adverse-event table because the trials reported them separately
Having reviewed the draft on Maridebart cafraglutide, the respondent makes a single submission, on the view that one point put clearly is more use to the secretariat than six put together.
Injection-site reactions are reported in the source trials in a table of their own and do not appear in the systemic adverse-event table the monograph reproduces. The result is that the most common adverse experience of a subcutaneously administered compound is absent from the monograph’s adverse-event section.
The respondent proposes that local reactions be carried in the same table as systemic events, with the reporting convention of the source trial recorded in a footnote.
The secretariat accepts this submission. The omission arose from following the source tables and it produced a misleading total.
Local reactions are now carried in the adverse-event table wherever the source trials report them, footnoted with the convention each trial used.
The route of administration studied is not the route in which the compound is supplied
The draft on Maridebart cafraglutide is a substantial document and the respondent has confined this submission to one matter.
The clinical section describes findings obtained by one route and the supply section describes presentations intended for another. A reader moving between the two sections will carry the effect estimate across the change without noticing that it has been carried, because nothing on the page marks the transition.
The respondent proposes that where the studied route and the supplied presentation differ, the difference be stated in the assessed-outcome table itself rather than in the supply section, on the ground that a reader consults the outcome table and does not always reach §8.
The respondent notes that submission 001 has already been made and confines this submission to a matter not covered by it.
The secretariat accepts this submission. The route by which an estimate was generated is a condition of the estimate and belongs beside it.
The assessed-outcome table now carries the studied route in every row, and a standing note appears wherever the supplied presentation differs from it.
Quantitative claims are reproduced without the method that produced them
The respondent submits on the draft monograph for Maridebart cafraglutide. The observation arises from teaching the material rather than from prescribing it.
Several figures in the draft are quoted from sources that determined them by different methods. A figure obtained by one determination and a figure obtained by another are not comparable, and the draft places them in the same sentence without distinguishing them.
The respondent, an analytical chemist, proposes that every quantitative claim carry the method that produced it at the point of use rather than in the reference.
The secretariat accepts this submission. Placing two figures side by side is an implicit claim that they are the same kind of quantity, and in the cases identified they were not.
Every quantitative claim now carries the determination that produced it at the point of use, and figures obtained by non-comparable methods are no longer presented in the same row or sentence.
Open-label extension data are presented alongside randomised data without distinction
The draft on Maridebart cafraglutide was read in full. The respondent notes at the outset that this class has an unusually deep randomised evidence base, and that a monograph on it is fairly judged against a higher standard than one on a compound with none.
Long-term figures in the clinical section come from open-label extensions in which every participant received the active compound and those who did not tolerate it had already withdrawn. They are printed in the same table as randomised comparisons and in the same typeface.
The respondent proposes that extension data be presented in a separate table, or at minimum in a separately labelled block, and that the surviving-population problem be stated once where it arises.
The secretariat accepts this submission. An extension estimate answers a different question from a randomised one and should not be read as though it answered the same one.
Extension data now appear in a separate table headed as uncontrolled follow-up, with a standing note on differential withdrawal.
Registered trials that never reported are absent from the monograph
This submission concerns the draft on Maridebart cafraglutide. The respondent assesses incretin-class evidence for a national body and comments in a personal capacity.
The respondent states that the trial list appears to be drawn from published reports, and that registered trials which completed without a report are therefore invisible. The proportion of a programme that never reported is itself a finding about the evidence base.
The respondent proposes that every registered trial of the compound be listed, with its reporting status, whether or not a report exists.
The secretariat accepts this submission. A trial list built from publications reproduces publication bias in the shape of the document.
The trial list now includes every registered trial the Institute identified, with its reporting status stated, and the monograph reports the proportion of registered trials for which no result has been posted or published.
The cardiovascular result is reported without the population that generated it
The respondent read the draft on Maridebart cafraglutide alongside the approved labelling for the class, and submits on one matter arising.
The cardiovascular outcome trials in this class enrolled populations selected for established disease or for high risk. The relative risk reduction is reproduced in the monograph without that selection, and a reader will apply it to a person at ordinary risk, where the absolute benefit is a fraction of the figure shown.
The respondent proposes that the absolute event rates in both arms be printed beside every relative estimate.
The secretariat accepts the proposal in relation to absolute rates and notes that the population was already stated in §3.1.
Absolute event rates in both arms are now printed beside every relative estimate in this class, and the enrolment criterion is repeated in the outcome row rather than only in the population section.
The indication table mixes approved indications with uses for which the compound is merely supplied
The respondent has read the draft monograph on Maridebart cafraglutide against a caseload in which incretin analogues are prescribed daily.
The indication table lists indications in a single sequence. Some are approved by a competent authority, some are the subject of trials that have not reported, and some are uses observed in supply with no trial evidence at all.
The respondent states that the three categories should not share a table without being distinguished in it.
The secretariat accepts this submission. A shared table is an implicit claim of comparable standing.
The indication table now carries a status column with three values, approved, under investigation and supplied without trial evidence, and the value is stated for every row. Rows in the third category also state that no certainty rating is assigned because there is no evidence base to rate.
The monograph does not tell a reader that a stated mass may be substantially counter-ion and water
This submission addresses the draft monograph on Maridebart cafraglutide. The respondent went through the document twice, once as a specialist and once as a reader arriving without the background.
The draft quotes vial contents in milligrams without stating whether the figure refers to peptide content or to total solids. For an acetate or trifluoroacetate salt of a peptide, the difference between the two can exceed a fifth of the stated mass.
The respondent, an analytical chemist, states that this is the single most consequential misreading in the field and that a monograph that does not address it directly is leaving the reader to discover it.
The secretariat accepts this submission. Moderate certainty evidence from published analytical surveys suggests that content and total solids are routinely conflated in supply documentation, and the draft did not warn the reader.
The monograph now states, at the point where vial contents are first mentioned, that a mass figure is uninterpretable unless it states whether it is peptide content or total solids, and cross-references the content standard in the analytical series.
The absence of a rare harm in the trial set is presented as reassurance
This is a submission on the draft covering Maridebart cafraglutide, from a respondent whose work is with the people taking compounds of this class rather than with the trials that produced them.
The draft states that a specific serious event was not observed in the contributing trials. The respondent states that trials of the size conducted here could not have detected an event at the frequency in question, and that reporting the absence without that arithmetic converts an uninformative result into a reassuring one.
The respondent proposes that the detectable frequency be stated wherever the absence of an event is reported.
The secretariat accepts this submission. The Institute's own framework treats an absent event in an underpowered set as uninformative, and the draft departed from it.
Wherever the monograph reports that an event was not observed, it now states the total exposure and the frequency the contributing trials could have detected, so that the absence is read as the limit of the evidence rather than as a finding.
References cited on this page
References are numbered in order of first citation in this document. Each superscript in the text links to its entry below.
- International Organization for Standardization. ISO/IEC 17025:2017 General Requirements for the Competence of Testing and Calibration Laboratories. ISO/IEC Standard 2017;3rd edition. identifier not held by the Institute
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