Draft monograph: orforglipron — submissions
The 10 submissions received, published in full with declared interests and secretariat responses.
§2Submissions and responses
10 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.
Open-label extension data are presented alongside randomised data without distinction
The draft on Orforglipron 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extensions in which every participant received the active compound and those who did not tolerate it had already withdrawn.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.
The mechanism section is written with more confidence than the clinical section it precedes
The respondent submits on the draft monograph for Orforglipron. The observation arises from teaching the material rather than from prescribing it.
The pharmacology section states what the compound does at its receptor in the indicative mood and without hedging. The clinical section then reports that the effect has not been demonstrated in people. A reader who stops after the first section, as many will, takes away a claim the document goes on to withdraw.
The respondent does not propose that the pharmacology be hedged, which would be inaccurate, but that each pharmacology section close with a sentence stating which of the described actions has been shown to produce a clinical effect and which has not.
The secretariat accepts the proposal in part. Receptor pharmacology is often well established and hedging it would misdescribe the literature.
Every pharmacology section now closes with a statement identifying which described actions are supported by clinical evidence assessed in §3 and which are not. The pharmacology itself is stated as the sources state it.
Quantitative claims are reproduced without the method that produced them
Having reviewed the draft on Orforglipron, the respondent makes a single submission, on the view that one point put clearly is more use to the secretariat than six put together.
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 respondent has read submission 001 with interest and adds one observation the secretariat may find useful.
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.
The absence of a rare harm in the trial set is presented as reassurance
This submission addresses the draft monograph on Orforglipron. The respondent went through the document twice, once as a specialist and once as a reader arriving without the background.
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.
This submission should be read alongside submission 003, which arises on the same draft.
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.
The pharmacokinetic section does not connect half-life to the dosing schedule
The respondent works on cardiometabolic outcomes and read the draft on Orforglipron with that literature in view.
The draft reports a half-life and, separately, a dosing interval. The respondent, a clinical pharmacologist, states that the relationship between the two is what determines accumulation and time to steady state, and that the monograph leaves the reader to derive it.
The respondent proposes that time to steady state be stated explicitly, with the assumption from which it was derived.
The respondent has read submission 001 and puts a further matter to the secretariat.
The secretariat accepts this submission. The derivation is short, it is decision-relevant, and leaving it to the reader invites it to be done wrong.
The pharmacokinetic section now states approximate time to steady state alongside the half-life and dosing interval, with the assumption of first-order elimination stated, and records where the assumption is not supported for this compound.
What happens when the compound is stopped is not addressed
The respondent has read the draft monograph on Orforglipron against a caseload in which incretin analogues are prescribed daily.
The draft assesses the effect of the compound while it is being taken. The respondent, who declares having used a compound in the class under prescription, states that the question a person actually faces is what happens afterwards, and that the monograph is silent on it.
The respondent proposes that the trajectory after discontinuation be an assessed outcome wherever any contributing trial measured it, and a recorded evidence gap wherever none did.
The secretariat accepts this submission. The omission was one of framing rather than of evidence, and the framing followed the trials rather than the decision.
Discontinuation trajectory is now an assessed outcome in every monograph where a contributing trial measured it, and a recorded evidence gap in every monograph where none did, so that its absence is visible rather than silent.
A near-isobaric analogue is not distinguished by the identity determination described
The respondent read the draft on Orforglipron alongside the approved labelling for the class, and submits on one matter arising.
The identity determination described in the draft resolves the compound from unrelated substances but would not distinguish it from a closely related analogue whose mass differs by approximately one dalton.
The respondent proposes that the monograph state the resolution required for that discrimination, and state that a nominal-mass instrument reporting an integer mass has not made it.
The secretariat accepts this submission. The point is decisive where one member of a near-isobaric pair is an approved medicine and the other is not.
The analytical section now states the resolving power required to discriminate the pair, names the pair explicitly, and records that an identity claim made below that resolution is not conformant with the identity standard.
The population to which the headline estimate applies is not stated with the estimate
The draft on Orforglipron is a substantial document and the respondent has confined this submission to one matter.
The draft carries a headline effect estimate in the abstract without the eligibility criteria of the trials that produced it. The respondent states that the estimate applies to a trial population with specific age, comorbidity and baseline criteria, and that a reader will apply it to whoever is in front of them.
The respondent proposes a one-line population statement adjacent to every headline estimate.
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. An estimate detached from its population is an estimate of nothing in particular.
Every headline estimate now carries a one-line statement of the population in which it was observed, and the full eligibility criteria are reported in the included-studies table rather than only in the source.
What happens to weight after the compound is stopped is not in the assessed outcomes
This submission concerns Orforglipron and makes one point.
Several trials in the evidence base ran a withdrawal period and reported what happened. That evidence is the single most useful thing a person considering the compound could be told, and it appears in the monograph only as a sentence in the discussion.
The respondent proposes that post-withdrawal trajectory be an assessed outcome in its own right for every compound where a withdrawal period was studied, with its own certainty rating.
The respondent has read submission 001 above and makes this submission independently of it.
The secretariat accepts this submission. The evidence exists, it is directly relevant, and it was not being assessed.
Post-withdrawal trajectory is now an assessed outcome wherever a withdrawal period was studied, rated on the same scale as the others. Where no withdrawal period was studied the outcome is recorded as not assessed.
Glycaemic trials and weight-management trials are drawn on interchangeably
This is a submission on the draft covering Orforglipron, from a respondent whose work is with the people taking compounds of this class rather than with the trials that produced them.
The compound has two trial programmes with different populations, different doses and different endpoints. The monograph draws on both without saying which programme a given estimate came from, so a reader takes a weight figure obtained at one dose in one population as though it applied at the other.
The respondent proposes that the programme be named against every effect estimate in the assessed-outcome table.
Submission 006 raises an adjacent matter. The respondent regards the two as separable and addresses only this one.
The secretariat accepts this submission. The two programmes are separable and were not being separated.
Every effect estimate now names its programme, and the assessed-outcome table is split where a compound has more than one.
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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