post-marketing surveillance: one division director’s view
DESCRIPTION
POST-MARKETING SURVEILLANCE: ONE DIVISION DIRECTOR’S VIEW. RUSSELL KATZ, M.D. DIRECTOR DIVISION OF NEUROLOGY PRODUCTS/CDER. POST-MARKETING SURVEILLANCE IS:. Detecting a signal Determining causality/frequency Doing something about it Informing relevant parties about the problem. - PowerPoint PPT PresentationTRANSCRIPT
POST-MARKETING SURVEILLANCE: ONE DIVISION
DIRECTOR’S VIEW
RUSSELL KATZ, M.D.
DIRECTOR
DIVISION OF NEUROLOGY
PRODUCTS/CDER
POST-MARKETING SURVEILLANCE IS:
• Detecting a signal• Determining causality/frequency• Doing something about it • Informing relevant parties about the problem
TYPES OF SAFETY SIGNALS WE SEE
• Adverse Events• Medication Errors• Product Failures• Labeling Failures
WAYS THAT WE BECOME AWARE OF A SAFETY SIGNAL
• Literature• Spontaneous Reports (AERS)• Manufacturer• Private citizen• Trials• Registries
ADVERSE EVENTS
• Tysabri and Liver Injury• Botox and “Botulism”• Dopamine Agonists and Cardiac Valvulopathy• Pathological Gambling• Tysabri and Progressive Multifocal
Leukoencephalopathy (PML)• Anticonvulsants and Suicidality
ADVERSE EVENTS-SPONTANEOUS REPORTS (AERS)
• Tysabri and Significant Liver Injury– Several individual cases of elevated LFTs and
Bilirubin– Examination of individual cases for alternative
causes; two positive re-challenges• Botox and “Botulism”
– Several cases consistent with known pharmacology
ADVERSE EVENTS-SPONTANEOUS REPORTS (AERS)
• Adverse Events with “known” background rates
– Tolcapone and liver failure– Felbamate and aplastic anemia
HOW WE EVALUATE A SAFETY SIGNAL FROM SPONTANEOUS
REPORTS• Someone (clinical reviewer, safety reviewer, etc.)
detects a serious (possibly unlabeled) adverse event
• Task is to assess causality (also examine RCTs)• Review of individual case report usually not
definitive– Incomplete information– Logically flawed
HOW WE EVALUATE A SAFETY SIGNAL FROM SPONTANEOUS
REPORTS• EB 05
– Lower limit of the 90% Confidence Interval around the following metric:
– # of cases of event of interest/ # of total ADRs for the drug DIVIDED BY
– # of cases of event of interest of all drugs/ # of total ADRs for all drugs
– If >2, considered a possible signal
HOW WE EVALUATE A SAFETY SIGNAL FROM SPONTANEOUS
REPORTS• Calculation of a Reporting Rate (Not an
incidence)• RR = #cases reported/patient-years of exposure• Patient-years = #prescriptions/12 (assume each
prescription for 30 days)• Compare RR to background rate and other drug(s)
– Assume background rate is relevant– May not be (e.g., nefazadone)
HOW WE EVALUATE A SAFETY SIGNAL FROM SPONTANEOUS
REPORTS
• Any RR approaching the background rate is presumptive evidence that the drug caused the adverse event due to underreporting (many factors influence reporting or lack thereof)
• In many cases, the spontaneous reports serve as the basis for a definitive decision: i.e., spontaneous reports are not always just hypothesis generating
ADVERSE EVENTS-SPONTANEOUS REPORTS-LITERATURE
• Dopamine Agonists and Valvulopathy– One case control study, one echocardiographic
prevalence study in NEJM, 2007– Previous studies and AERS search in 2004 led
to conclusion about ergot-derived agonists– Recent AERS search for other agonists, 5HT2B
agonists
ADVERSE EVENTS-LITERATURE
• Dopamine agonists and Pathologic Gambling– Case series in the literature; mostly Mirapex
(some Requip)– AERS searched for all dopaminergic drugs for
impulse control disorders– Adequate background rates not available
VARIANT OF ADVERSE EVENT ASSESSMENT-LITERATURE
• Stevens-Johnson Syndrome known to occur with carbamazepine
• Literature reports of a marked increased incidence in Han Chinese patients
• Additional corroboration from international spontaneous reports
• Data “established” HLA B-1502 as an important risk factor for SJS
ADVERSE EVENTS-CLINICAL TRIALS
• Tysabri and PML– Three cases observed in open-label extensions
of controlled trials being done in Phase 4– Marketing discontinued and entire database
examined for any additional cases-none found – Causality assumed from mechanism
ADVERSE EVENTS-CLINICAL TRIALS
• AEDs and Suicidality– Sponsor notified us of a signal from their
controlled trials– Submission of a citizen petition raising
questions about another AED– All controlled trials from 11 recently approved
AEDs examined
ADVERSE EVENTS-CLINICAL TRIALS
• Hypnotics and cancer– Individual academic performed analyses of data
for recently approved hypnotics on the basis of which he concluded that they are associated with an increased risk for cancer
– Resulted in detailed review of numerous databases that did not confirm his conclusions
ADVERSE EVENTS-REGISTRIES
• Possible teratogenicity (cleft lip/palate) with Lamictal– Sponsor informed division of data from two
pregnancy registries– Analyses of other registries did not reveal
confirmatory findings
ADVERSE EVENTS-REGISTRIES
• Amendments to monitoring requirements for agranulocytosis for Clozapine– Requested by an interested party based on
family member’s experience– Resulted in detailed review of accumulated data
to date and ultimately a change to the monitoring regimen
MEDICATION ERRORS
• Lamictal/Lamisil• Reminyl/Amaryl• Fosphenytoin
HOW WE EVALUATE MEDICATION ERRORS
• Here, detailed review of cases can help pinpoint how the problem arises, and point the way to possible solutions
• Name confusion– Lamictal/Lamisil
• Written/verbal prescription
• Carton appearance; overlapping strengths
• Drug locations on pharmacy shelf
HOW WE EVALUATE MEDICATION ERRORS
• Here, detailed review of cases can help pinpoint how the problem arises, and point the way to possible solutions
• Name confusion– Reminyl/Amaryl
• Similar written appearance
• Several deaths due to hypoglycemia
HOW WE EVALUATE MEDICATION ERRORS
• Here, detailed review of cases can help pinpoint how the problem arises, and point the way to possible solutions
• Product Label– Fosphenytoin
• Total units in vial (100 mg/2 mL) vs concentration (50mg/mL)
• Automated displays still use old description
PRODUCT FAILURES
• Sometimes, the causes (or the errors) are obvious• Example:
– Diastat Accudial (prefilled syringes of diazepam for rectal administration)
• Leakage from cracked tips
• Inappropriate dialing of doses
PRODUCT FAILURES
• Potential “failures” of generic AEDs to perform adequately (possible ADRs and/or breakthrough seizures) reported to Agency by expert community
• Personal experience• Surveys• Literature
LABELING FAILURE-PHASE 4 STUDIES
• Novantrone (mitoxantrone): approved for progressive multiple sclerosis
• Two required Phase 4 studies– A study to evaluate incidence of
cardiomyopathy in patients prospectively monitored
– A “real-life” study to see if patients monitored according to labeling-insurance records for 400+ patients
LABELING FAILURE-PHASE 4 STUDIES
• Novantrone (mitoxantrone): approved for progressive multiple sclerosis– Data show:
• Cardiomyopathy occurs at much lower cumulative doses than previously believed
• Very few patients are monitored appropriately
AVAILABLE ACTIONS
• Early communications– Press Release, Public Health Announcement
• Pergolide and valvulopathy• Diastat failures
– Physician information sheets• AEDs and suicidality• Teratogenicity and Lamictal
– Early communications• Botox and botulism
AVAILABLE ACTIONS
• Labeling changes– Tysabri and PML, Liver injury– Dopamine agonists and impulsive behaviors– Novantrone– Carbamazepine
AVAILABLE ACTIONS
• Dear Health Care Practitioner Letters• Name Change
– Reminyl to Razadyne• Removal from Market
– Tysabri– Pergolide (“compassionate IND” instituted)
AVAILABLE ACTIONS
• Require studies– AEDs and generic “failures”
• Restricted distribution/observational studies– Tysabri
• Extensive education campaigns and other changes– Lamictal/Lamisil errors– Change carton appearance
FOOD AND DRUG ADMINISTRATION AMENDMENTS ACT
• Title IX-Drug Safety• Sec. 901
– FDA may require studies or clinical trials at the time of approval (or after approval if new safety information)
FOOD AND DRUG ADMINISTRATION AMENDMENTS ACT
• May require studies or clinical trials to:– Assess known serious risk related to drug use– Assess signals of serious risk related to drug
use– Identify an unexpected serious risk when
available data indicates the potential for a serious risk
FOOD AND DRUG ADMINISTRATION AMENDMENTS ACT
• Before a study/trial may be required, FDA must find:– AE reporting and “active postmarketing risk
identification and analysis system” are not sufficient to meet the purposes;
– A post-approval study is not sufficient before requiring a clinical trial
FOOD AND DRUG ADMINISTRATION AMENDMENTS ACT
• Required labeling changes– Agency must promptly inform sponsor of new
safety information– Within 30 days, the sponsor must submit a
labeling supplement or tell us why not– Rapid turnaround by Agency
FOOD AND DRUG ADMINISTRATION AMENDMENTS ACT
• Required labeling changes– Within 15 days of conclusion of discussions,
Agency can issue an order for a labeling change– Within 15 days of an order, sponsor must
submit a labeling supplement, or within 5 days, sponsor may appeal the order
FOOD AND DRUG ADMINISTRATION AMENDMENTS ACT
• Risk Evaluation and Mitigation Strategies (REMS)-Timetables Required– Pre-approval
• FDA may determine REMS needed to ensure benefits outweigh the risks
– Post-approval (if new safety information)• If needed to ensure benefits outweigh risks
NEW AGENCY SAFETY INITIATIVES
• Safety First– Associate Directors for Safety– Dedicated Project Manager for Safety– Standardized Record Keeping for Safety Issues– Deadlines to be applied for action on safety
issues
WHERE AGENCY CAN IMPROVE
• No systematic surveillance outside AERS• Most assessments take too long• Have not consistently followed up requests to
industry adequately (either for review of the data or requested labeling changes)
• Coordination with consulting divisions can be more efficient
WHERE AGENCY CAN IMPROVE
• May propose action with little prior notification to industry
• May confuse, mislead, (anger?) relevant constituencies with early communications, public announcements
WHERE INDUSTRY CAN IMPROVE
• Slow to respond to Agency requests• Unnecessary negotiations over labeling
– Class labeling• Often don’t inform Agency of a problem (even if
considerable work has been done)• May meet technical requirements for informing
Agency (e.g., PSUR) but problems not flagged
WHERE INDUSTRY CAN IMPROVE
• Even if Agency informed, may not have a proposal for a comprehensive plan
• On the other hand, some proposals appear to be overly “negative”– Proposed labeling may describe adverse event
which we all agree is not causally related to drug
THE FUTURE
CHANGE WE CAN BELIEVE IN
OR
SOLUTIONS FOR AMERICA