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WHO Drug Information Vol 23, No. 1, 2009                            World Health Organization




WHO Drug Information
                                       Contents
Quality of Medicines                            Erlotinib: Use in hepatic impairment
                                                   and advanced solid tumours              32
WHO medicines prequalification:
                                                Generic piperacillin and tazobactam:
 progress in 2008                          3       medication errors                       33
                                                Safety of artemisinin combination therapy:
Herbal and Traditional                             pregnant women                          33
Medicines
WHO Congress on Traditional Medicine            Regulatory Action and News
 and the Beijing Declaration                8   Efalizumab: suspension of marketing
                                                   authorization                          35
                                                Contusugene ladenovec: withdrawal of
Biomedicines Update                                marketing application                  36
Global norms and standards for biological       Paliperidone: withdrawal of application
  quality, safety and efficacy            12       for extension of indication            36
                                                First EMEA meeting of Committee for
                                                   Advanced Therapies                     36
Safety of Medicines
The mobile laboratory: a new concept in
  medicines surveillance                   16   Consultation document
                                                International Pharmacopoeia
Pharmacovigilance Focus                           Oxytocin                                38
                                                  Oxytocin injection                      43
Monitoring the safety of off-label
  medicine use                             21
Drotrecogin alfa: what relation to              Recent Publications,
  thrombosis?                              22
                                                Information and Events
                                                Low availability, high prices keep
Safety and Efficacy Issues                        essential medicines out of reach        46
Genetic basis of adverse drug events       26   Sources and prices of selected
Anaesthetic infusion with pain pumps:             medicines for children                  46
   articular chondrolysis                  26   Two international summer courses
Atomoxetine: serious liver injury          27     in the Netherlands                      47
Drotrecogin alfa: ongoing safety review    28   Global politics of pharmaceutical
Clopidogrel bisulfate: ongoing safety             monopoly                                48
   review                                  29
Modafinil: adverse skin and psychiatric
   reactions                               30
                                                Recommended International
Levothyroxine update                       30   Nonproprietary Names:
Temsirolimus: hypersensitivity reactions   31
Continued vaccination with Gardasil®       32
                                                 List 61
                                                                                          49




                                                                                          1
World Health Organization            WHO Drug Information Vol 23, No. 1, 2009




                        WHO Drug Information
                     is also available online at
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WHO Drug Information Vol 23, No. 1, 2009




Quality of Medicines
WHO medicines prequalification: progress in 2008
The WHO Prequalification Programme for       considerable breakthrough in making
Medicines (PQP) was initiated in 2001 as     user-friendly formulations available that
a service provided by the World Health       will also improve efficacy of treatment.
Organization (WHO) to facilitate access
to medicines that meet unified interna-      The number of products prequalified in
tional standards of quality, safety and      2008 was the highest in six years. The
efficacy for HIV/AIDS, malaria, tuberculo-   main reasons for this were:
sis and reproductive health.
                                             • Increasing number of well prepared new
The work is carried out through:               submissions in 2007–2008.

• Stringent assessment of pharmaceutical     • Improved quality of evidence to demon-
  product dossiers.                            strate quality, safety and efficacy of
                                               products.
• Inspection of pharmaceutical manufac-
  turing sites (both for finished dosage     • Expanded staffing component in 2007.
  forms and active pharmaceutical ingre-     • Implementation of management effi-
  dients) and contract research organiza-      ciency tools which improve the evalua-
  tions (CROs).                                tion process.
• Prequalification of pharmaceutical
  quality control laboratories (QCLs).       List of prequalified medicines
                                             Inclusion in the list does not mean that
• Advocacy for medicines of assured          the prequalification status of a product is
  quality.                                   assured indefinitely. All approved medi-
                                             cines have to be checked regularly to
The Bill & Melinda Gates Foundation as       ensure that any changes undertaken by
well as UNITAID are the main financial       manufacturers do not undermine the
supporters of PQP.                           quality, safety and efficacy of the product.

Newly prequalified medicines                 In order to achieve this objective, WHO
Forty products were added to the list of     carries out re-inspections of manufactur-
prequalified medicines in 2008, an           ing sites as well as random quality control
increase from 21 products in 2007. The       tests of prequalified medicines. Since the
total number of prequalified medicines       prequalified products list is constantly
currently stands at 196.                     being added to, information maintenance
                                             and updating becomes crucial to the
A major achievement in 2008 was the          preservation of established international
prequalification of new products specially   standards.
designed to treat HIV/AIDS in children, as
well as the first fixed-dose combination     New submissions to PQP
tablets of artesunate and amodiaquine to     Certain product groups are urgently in
treat malaria. These products represent a    need of expansion to increase available



                                                                                         3
Quality of Medicines                                   WHO Drug Information Vol 23, No. 1, 2009




    In 2008, the WHO Medicines Prequalification Programme:

    • Prequalified a total of 40 medicinal products. The list of prequalified medicines
      now contains nearly 200 products.
    • Prequalified the first ever fixed-dose combination tablets of antiretroviral medi-
      cines designed for use in children to treat HIV/AIDS, and the first fixed-dose
      combination tablets of artesunate and amodiaquine to treat malaria.
    • Organized 11 training workshops for capacity building in resource-limited coun-
      tries for staff of regulatory authorities and pharmaceutical manufacturers.
    • Provided manufacturers with scientific advice and technical assistance to sup-
      port improvements in the quality of their products.
    • Implemented the biowaiver concept to facilitate evaluation of product dossiers.
    • Prequalified six quality control laboratories.
    • Planned and implemented three comprehensive medicines sampling and testing
      programmes in countries that were recipients of drug donations.
    • Revised and updated the procedure for prequalification to increase transparency
      and accountability of prequalification performance.
    • Contributed to the development of guidelines and standards to facilitate global
      quality assurance activities, including pharmacopoeial monographs and chemi-
      cal reference standards.
    • Opened prequalification to include zinc and influenza products and considerably
      expanded the invitation list of reproductive health products.



treatment options (e.g., second-line              required. Insufficient quality specifications
antituberculosis and paediatric antiretrovi-      presented for reproductive health and
ral combination products). However, it            antimalarial products and manufacturing
was again noted that the number of                conditions are of particular concern.
products submitted for evaluation within
this category was insufficient to meet            In recent years, documented quality
current demand. This is mainly due to a           assurance of medicines has become an
lack of commercial incentives available to        essential requirement of international
manufacturers to develop products                 funding agencies for successful bidding in
intended for small or non-profitable              procuring essential medicines for devel-
markets.                                          oping countries. Manufacturers should
                                                  therefore be increasingly motivated to
In the past year, the number and quality          invest in enhancing their own manufactur-
of product dossiers submitted for assess-         ing and control processes to improve the
ment continued to present many chal-              quality of submissions to the PQP.
lenges. Newcomer manufacturers having
limited or no experience in production            Technical assistance to manufacturers
according to international standards have         Time and resources are needed from
great difficulty in submitting the evidence       applicants to obtain product prequalifica-




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WHO Drug Information Vol 23, No. 1, 2009                               Quality of Medicines



tion and this includes dedication to           Capacity building of
implementation of corrective action to         regulatory authorities
meet international quality standards. It       In 2008, the PQP continued to offer
follows that an increase in the number of      national regulatory personnel from
available prequalified medicines can only      resource-limited countries a three-month
be achieved based on increased capacity        full-time post at WHO. These rotational
building and technical assistance activi-      positions for quality assessors are aimed
ties.                                          at creating links and form a network
                                               between WHO and the countries in-
Consequently, since 2006, the PQP has          volved, as well as enhance information
provided coordinated technical assistance      exchange between both parties.
aimed at resolving specific practical
problems encountered by manufacturers          In addition, assessors from less re-
or quality control laboratories. Assistance    sourced regulatory authorities continue to
is provided by qualified professionals in      participate in PQP assessment sessions
the form of an audit and training in           where they account for one-third of the
technical or regulatory areas.                 total external assessor contribution.
                                               Since 2008, inspectors from these
Such action in resource-limited countries      authorities are invited to take part in
has become one of the core activities of       WHO inspections as observers. Regula-
PQP since 2007 and will remain so for          tors from the WHO Africa Region have
the following years. In 2008, PQP pro-         been especially active in this process.
vided eight technical assistance missions
to pharmaceutical manufacturers in five        Dossier assessments
different countries.                           and expert advice
                                               In 2008, seven assessment sessions
Training                                       were organized at the UNICEF Supply
WHO recognizes the crucial role of             Division in Copenhagen where product
capacity building through training and         dossiers are received and stored. The
hands-on practice. In 2008, PQP organ-         number of assessment reports for 2008
ized 11 training courses and co-organized      increased to 732 compared to 463 in
four training activities together with other   2007. In addition to regular assessment
partners in 10 different countries (see        activities, provision of expert scientific
table on page 7).                              advice to applicants remained high on the
This tuition on general or specific techni-    agenda. In 2008, a total of 13 bioequiva-
cal issues is also offered to larger groups    lence study protocols were reviewed,
formed by manufacturers, national              more than 60 bioequivalence queries
medicines regulatory agency staff and          answered, and close to 80 separate
professionals from quality control labora-     quality issues handled by the respective
tories. Training courses include group         expert panels.
sessions as well as focused communica-
tion between the involved parties, such as     Inspections
manufacturers and lecturers who are part       A total of 38 inspections of pharmaceuti-
of the assessment or inspection teams          cal manufacturers and 14 inspections of
working with PQP. In 2008, these courses       CROs were carried out in seven different
involved more than 600 participants and        countries in 2008. As in all previous
46 lecturers and trainers provided by          years, the national inspectorates from
PQP.                                           well established regulatory authorities
                                               continued to provide staff inspectors for




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Quality of Medicines                              WHO Drug Information Vol 23, No. 1, 2009



Prequalification assessment and inspection statistics

                                                                2007         2008
     Dossier Assessment
     Assessment sessions in Copenhagen                             6            7
     Total number of assessment days                              42           46
     Total number of assessment reports                          463          732
     Assessment reports on HIV/AIDS products                     298          494
     Assessment reports on TB products                           100          100
     Assessment reports on malaria products                       54          115
     Assessment reports on reproductive health products           11           19
     Assessment reports on influenza products                      -            4

     Inspections                                                  46            62
     Manufacturing sites of finished product manufacturers        26            27
     Manufacturing sites of active pharmaceutical ingredients      6            11
     Contract research organizations                              13            14
     Pharmaceutical quality control laboratories                   1            10


prequalification purposes. France was the     of delivery to the recipient country. How-
leading country in terms of providing         ever, quality can deteriorate during
inspection support.                           transportation and storage. To verify that
                                              the quality of essential medicines is
Prequalification of quality                   maintained throughout the supply chain
control laboratories                          until the medicines reach the end user,
The prequalification of quality control       several sampling and testing programmes
laboratories was restarted in 2007 when       have been designed and implemented.
12 laboratories expressed interest in
prequalification. In 2008, PQP carried out    Programme strengthening
10 inspections of quality control laborato-   and development of standards
ries with six gaining prequalification        Major procedural improvements to PQP
status.                                       in 2008 include:
Testing of medicines                          • Revision and update of the procedure
The prequalification status of a medicinal      for prequalification to increase transpar-
product guarantees its quality at the time      ency and accountability of PQP.

Major medicines testing programmes organized by WHO PQP in 2008

        Aim of sampling                  Countries involved             Total number
          and testing                                                    of samples

    Quality survey of anti-        Cameroon, Ethiopia, Ghana,
    malarial medicines              Kenya, Nigeria, Tanzania                   936
    Quality monitoring of products Kenya, Tanzania, Uganda,
     funded by UNITAID              Zambia                                     378
    Quality survey of anti-TB      Armenia, Azerbaijan, Belarus,
     medicines in Eastern Europe Kazakhstan, Ukraine, Uzbekistan               360




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WHO Drug Information Vol 23, No. 1, 2009                               Quality of Medicines



Training workshops organized by WHO PQP in 2008
 Date               Location                    Content of training

 25–29 February     Brasilia, Brazil            New approaches to quality risk manage-
                                                ment in manufacture of medicines.

 21–25 April        Lahore, Pakistan            Development of PQP submission dossiers.

 28 April–1 May     Mumbai, India               Pharmaceutical development with a
                                                focus on paediatric formulations.

 2–6 June           Dar-es-Salaam, United       Evaluation of generic products focusing
                    Republic of Tanzania        on bioequivalence and biowaiver data.

 16–20 June         Amman, Jordan               Introduction to PQP and technical
                                                requirements.

 16–20 June         Teheran, The Islamic        Introduction to PQP and technical
                    Republic of Iran            requirements.

 23–27 June         Beijing, China              GMP for reproductive health products
                                                and dossier requirements.

 8–11 July          Rabat, Morocco              GMP – air and water treatment systems

 20–24 October      Jakarta, Indonesia          GMP for reproductive health products
                                                and dossier requirements.

 3–7 November       Accra, Ghana                Regulatory requirements and data
                                                assessment of artemisinin-based fixed
                                                dose combination medicines.

 1–5 December       Nanchang, China             GMP training for SFDA inspectors



• Opening of new tracks for the prequalifi-    development and updating of new and
  cation of zinc and influenza products.       existing WHO guidelines and standards
                                               continued to facilitate global quality
• Implementation of the biowaiver concept      assurance activities. Such guidance
  to facilitate evaluation of product dossi-   includes pharmacopoeial monographs
  ers.                                         and chemical reference standards. The
                                               procedure for prequalification of active
• Publication of the first “notices of con-    pharmaceutical ingredients was approved
  cern” highlighting good manufacturing        by the WHO Expert Committee on Phar-
  practice (GMP) violations observed           maceutical Specifications for implementa-
  during inspections.                          tion in 2009.
PQP activities are based on scientifically     Reference: The Medicines Prequalification
sound and updated internationally ac-          Programme (PQP). http://www. who.int/
cepted quality standards. In 2008,             prequal




                                                                                           7
WHO Drug Information Vol 23, No. 1, 2009




Herbal and Traditional
Medicines
WHO Congress on Traditional Medicine
and the Beijing Declaration

    Representatives of over 70 Member States attended the first WHO Congress on
    Traditional Medicine held on 7–9 November 2008 in Beijing, China. Satellite sympo-
    sia were held to discuss related technical topics. Presentations were given by repre-
    sentatives of organizations such as the World Self-Medication Industry (WSMI), the
    World Federation of Acupuncture-Moxibustion Societies (WFAS), the International
    Pharmaceutical Federation (FIP), and the World Federation of Chiropractic (WFC).
    Almost 1500 people were present at the events.

    Highlights of the Congress included adoption of the Beijing Declaration promoting
    the safe and effective use of traditional medicine and calling on WHO Member States
    and other stakeholders to take steps to integrate traditional medicine, complemen-
    tary and alternative medicines (TM/CAM) into national health systems.

    Sharing of national experience and information by Member States in five areas aimed
    at leveraging future action.

    • National policy on TM/CAM.
    • National regulation of traditional and herbal medicines.
    • TM use in Primary Health Care.
    • National regulation of TM/CAM practice.
    • Research on TM/CAM.

    Participants visited community health centres, clinics and hospitals for traditional
    medicine. These models showed how traditional and Western medicine can work
    together and be successfully integrated into China’s health system.



In 2008, WHO marked its 60th anniver-           health care by WHO and its Member
sary and the 30th anniversary of the Alma       States.
Ata Declaration, adopted by UNICEF and
WHO in 1978. Although traditional               Use of traditional medicine has changed
medicine has been used for thousands            dramatically over the past thirty years.
of years and has made a fundamental             Due to its affordability, availability and
contribution to human health, the Alma          accessibility, traditional medicine has
Ata Declaration was the first formal            played an important role in meeting the
recognition of the role of traditional          demands of primary health care in many
medicine and its practitioners in primary       developing countries.



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WHO Drug Information Vol 23, No. 1, 2009                    Herbal and Traditional Medicines



Since the 1990s, the use of traditional        and western medicine can blend together
medicine has surged. It not only main-         in beneficial harmony, using the best
tains its function in primary health care in   features of each system.
developing countries (70–80% of the
population in Ethiopia and India still         Delegates were welcomed by the Minister
depend on traditional medicine and             of Health, People’s Republic of China. In
practitioners for primary health care), its    their presentations, the Minister of Health
use has expanded widely in many devel-         of the Union of Myanmar and the Deputy
oped countries where it is referred to as      Minister of Health of South Africa ex-
complementary or alternative medicine          plored the role of integration of traditional
(CAM). For instance, 70% of the popula-        medicine into primary health care and
tion in Canada and 80% in Germany have         actions that their respective countries
used CAM. National health authorities          have taken. The need for appropriate
were asked to consider how to integrate        regulatory oversight of complementary
TM/CAM into their national health sys-         medicine products was expressed by the
tems and significant progress has been         National Manager of the Therapeutic
made since initiation of the WHO Tradi-        Goods Administration of Australia.
tional Medicine Strategy in 2002.
                                               During the International Forum on Inte-
WHO Congress on                                gration of Traditional Medicine/CAM into
Traditional Medicine                           Health Systems, 26 delegates presented
To further assess the role of traditional      short national reports outlining the regula-
medicine/CAM, review the progress of the       tory framework for traditional medicine,
countries and help Member States               products and practice in their respective
integrate traditional medicine/CAM into        countries. To facilitate discussion, the
their national health systems, the first       presentations were separated into five
WHO Congress on Traditional Medicine           topic areas:
on 7–9 November 2008, was organized in
Beijing, China. The Congress was hosted        • National Policy on TM/CAM and integra-
by the Ministry of Health and the State          tion into national health systems.
Administration of Traditional Chinese
Medicine of the Government of China, in        • National regulation of traditional and
cooperation with four nongovernmental            herbal medicines.
organizations (NGOs) in official relations
with WHO — the World Self-Medication           • Traditional medicine in primary health
Industry (WSMI), the World Federation of         care.
Acupuncture-Moxibustion Societies              • National regulation of traditional medi-
(WFAS), the International Pharmaceutical         cine/CAM practice.
Federation (FIP), and the World Federa-
tion of Chiropractic (WFC).                    • Research and development of tradi-
                                                 tional medicine.
During the opening ceremony, the Direc-
tor-General of WHO identified the impor-       While presentations showed that it is
tance of traditional medicine in primary       often necessary to tailor legislation and
health care, the role of research, the need    delivery to reflect the needs and traditions
for appropriate licensing or registration of   of individual countries, a number of
practitioners and the importance of            common themes and issues did emerge.
patient-practitioner interaction. It was       Most notable of these were the impor-
noted that within the context of primary       tance of practitioner training, issues
health care, the two systems of traditional    related to safety, need to enhance re-




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Herbal and Traditional Medicines                 WHO Drug Information Vol 23, No. 1, 2009



search into both products and practices,      created to discuss and harmonize the
importance of labelling and information as    comments submitted to WHO prior to the
it relates to supporting informed choice,     Congress and to enable the Declaration
and the need for appropriate integration      to be presented to the Congress.
into primary health care.
                                              Congress delegates adopted the Beijing
Delegates also heard from two WHO             Declaration during the WHO Congress on
partners (The Nippon Foundation and the       Traditional Medicine. In addition to a
Regional Government of Lombardy) who          preamble text noting a number of related
described their work in this area. The four   initiatives and reflecting the importance of
nongovernmental organizations hosting         national contexts with regard to capacity,
satellite conferences were also given the     priorities and relevant legislation, the
opportunity to make presentations and         Beijing Declaration is set out below.
observe the Congress.
                                              The Beijing Declaration will serve to
A key outcome of the Congress was the         promote the safe and effective use of
Beijing Declaration, which identified         traditional medicine, and calls on WHO
common aims and principles reached by         Member States and other stakeholders to
participants at the Congress. Preparation     take steps to integrate traditional medi-
of the declaration was structured, starting   cine/CAM into national health systems.
some months prior to the Congress with        During the closing of the International
circulation of the first draft. Comments      Forum the WHO Assistant Director-
were collected and modifications made         General for Health Systems and Services
with a subsequent draft sent to partici-      said, “This is a landmark declaration, after
pants before the Congress. During the         a landmark Congress.”
Congress, an ad hoc drafting team was


                                   Beijing Declaration
              Adopted by the WHO Congress on Traditional Medicine,
                        Beijing, China, 8 November 2008

 Participants at the World Health Organization Congress on Traditional Medicine,
 meeting in Beijing this eighth day of November in the year two thousand and eight:
 Recalling the International Conference on Primary Health Care at Alma Ata thirty
 years ago and noting that people have the right and duty to participate individually
 and collectively in the planning and implementation of their health care, which may
 include access to traditional medicine.
 Recalling World Health Assembly resolutions promoting traditional medicine, includ-
 ing WHA56.31 on Traditional Medicine of May 2003.
 Noting that the term “traditional medicine” covers a wide variety of therapies and
 practices which may vary greatly from country to country and from region to region,
 and that traditional medicine may also be referred to as alternative or complementary
 medicine.
                                                                                      .../



                                                                             .../ Continued



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WHO Drug Information Vol 23, No. 1, 2009                   Herbal and Traditional Medicines




Beijing Declaration (continued)

  Recognizing traditional medicine as one of the resources of primary health care
  services to increase availability and affordability and to contribute to improve
  health outcomes including those mentioned in the Millennium Development
  Goals.

  Recognizing that Member States have different domestic legislation, approaches,
  regulatory responsibilities and delivery models.

  Noting that progress in the field of traditional medicine has been obtained in a
  number of Member States through implementation of the WHO Traditional
  Medicine Strategy 2002-2005.

  Expressing the need for action and cooperation by the international community,
  governments, and health professionals and workers, to ensure proper use of
  traditional medicine as an important component contributing to the health of all
  people, in accordance with national capacity, priorities and relevant legislation.

  In accordance with national capacities, priorities, relevant legislation and circum-
  stances, hereby make the following Declaration:

  I. The knowledge of traditional medicine, treatments and practices should be
  respected, preserved, promoted and communicated widely and appropriately
  based on the circumstances in each country.

  II. Governments have a responsibility for the health of their people and should
  formulate national policies, regulations and standards, as part of comprehensive
  national health systems to ensure appropriate, safe and effective use of tradi-
  tional medicine.

  III. Recognizing the progress of many governments to date in integrating tradi-
  tional medicine into their national health systems, we call on those who have not
  yet done so to take action.

  IV. Traditional medicine should be further developed based on research and
  innovation in line with the “Global strategy and plan of action on public health,
  innovation and intellectual property” adopted at the Sixty-first World Health
  Assembly in resolution WHA61.21 in 2008. Governments, international organiza-
  tions and other stakeholders should collaborate in implementing the global
  strategy and plan of action.

  V. Governments should establish systems for the qualification, accreditation or
  licensing of traditional medicine practitioners. Traditional medicine practitioners
  should upgrade their knowledge and skills based on national requirements.

  VI. The communication between conventional and traditional medicine providers
  should be strengthened and appropriate training programmes be established for
  health professionals, medical students and relevant researchers.




                                                                                         11
WHO Drug Information Vol 23, No. 1, 2009




Biomedicines Update
Global norms and standards for
biological quality, safety and efficacy

 WHO Expert Committee on Biological Standardization
 Established in 1947, the Expert Committee on Biological Standardization (ECBS) is
 one of the longest standing World Health Organization (WHO) committees and has
 overall responsibility for setting written standards and establishing reference prepa-
 ration materials. Standards developed through the ECBS relate to the production
 and quality control of safe and effective biological products. They provide guidance
 for national regulatory authorities and manufacturers and serve as the standard for
 prequalification of vaccines for supply to countries through international agencies.
 Reference preparation materials are available from designated WHO laboratories
 and provide the basis for comparison of materials used in biologicals worldwide.

 Members of the ECBS are scientists from national control agencies, academia, re-
 search institutes and public health bodies. These scientists act as individual experts
 and not as representatives of their respective organizations or employers. The deci-
 sions and recommendations of the ECBS are based entirely on scientific principles
 and public health considerations.

 The ECBS reports directly to the WHO Executive Board, which is the executive arm
 of the World Health Assembly. The outcome of each ECBS meeting is subsequently
 published in a technical report. This report provides updated information on stand-
 ards for assuring the quality, safety and efficacy of biological products as well as on
 the establishment of new or updated WHO international standards for designating
 the activity of biological substances. ECBS technical reports are available at:
 http://www.who.int/biologicals/publications/trs/en/index.html


Highlights of the                            The WHO Expert Committee on Biologi-
2008 ECBS meeting                            cal Standardization (ECBS) establishes
                                             global norms and standards that help
Biological medical products such as          define products of assured quality. The
vaccines, blood products, biotherapeutics    ECBS meets annually and their most
and associated diagnostics save lives,       recent meeting was held in Geneva from
reduce suffering and improve health, but     13 to 17 October 2008. During the meet-
only if these products and technologies      ing, 57 agenda items were considered.
are of good quality, are safe, effective,    This was accomplished, as in previous
available, affordable and properly used.     years, by running two parallel tracks, one
WHO is working with it’s Member States       dedicated to vaccines and selected other
to use only biological medicines of          biological medicines; one dedicated to
assured quality in national health sys-      blood products and related in vitro diag-
tems.                                        nostic devices.



12
WHO Drug Information Vol 23, No. 1, 2009                              Biomedicines Update



The most important outcomes of the 2008       Yellow fever vaccine
ECBS meeting were:                            An amendment to the written standard
                                              for yellow fever vaccine was also estab-
Snake antivenom immunoglobulins               lished. This requires that the expression
A new written standard for production,        of potency of such vaccines be in Interna-
control and regulation of snake antivenom     tional Units (IU) per dose. The dose
immunoglobulins was established. Snake        recommended for use in humans shall
antivenom immunoglobulins (antivenoms)        not be less than 3.0 log10 IU. This new
are the only therapeutic products for the     expression of potency should be ap-
treatment of envenomings due to snake-        proved by National Control Authorities,
bite. The lack of availability of effective   and will also be used as the standard for
snake antivenom immunoglobulins to            WHO prequalification of yellow fever
treat specific types of envenomings           vaccines.
encountered in various regions of the
world has become a critical health issue      Abbreviated licensing pathways for
at global level. The crisis has reached its   certain biological therapeutic products
greatest intensity in sub-Saharan Africa,     The Expert Committee also discussed a
but other regions, such as South-east         proposal to establish abbreviated licens-
Asia, are also suffering from a lack of       ing pathways for certain biological thera-
effective and affordable products.            peutic products. Control of chronic
                                              diseases is a major challenge for public
The complexity of the production of           health systems in WHO Member States.
efficient antivenoms, in particular the       Innovative biological medicines devel-
importance of preparing appropriate           oped by modern molecular biological
snake venom mixtures for the production       approaches have been successful in
of hyperimmune plasma (source of              treating many life-threatening diseases
antivenom immunoglobulins), the de-           and the market for these products is
creasing number of producers and the          rapidly growing.
fragility of the production systems in
developing countries further jeopardize       However, such innovative biological
the availability of efficient antivenoms in   medicines are expensive. This has limited
Africa, Asia, the Middle East, and South      their use, particularly in developing
America. Also, most of the remaining          countries. The expiration of patents on
producers are located in countries where      key biological drugs such as recombinant
the application of quality and safety         insulin, human growth hormone and
standards needs to be improved.               erythropoietin is opening the door for
                                              copies of these drugs to be made by
The new Guidelines cover all the steps        developing country manufacturers. This
involved in the production, control and       may contribute to a substantial increase
regulation of venoms and antivenoms. It       in their availability at an affordable price.
is hoped that this document, by covering
comprehensively current existing experi-      Generic versions of expired-patent
ence in manufacture, control, and pre-        chemical drugs are well known. However,
clinical and clinical assessment of these     copy biological medicines are far more
products will serve as a guide to national    complicated products for which the
control authorities and manufacturers to      current generic regulatory pathway is
support worldwide production of these         unsuitable. Nevertheless it is essential to
essential medicines.                          ensure that there is appropriate regula-
                                              tory oversight in place. Regulatory over-




                                                                                        13
Biomedicines Update                                   WHO Drug Information Vol 23, No. 1, 2009



Proposals to establish new or replacement International Standards or WHO
reference reagents: October 2008

 Name of preparation                                     Proposed status
 VACCINES AND RELATED SUBSTANCES

 Influenza H5N1 antibody (human)                         lst International Standard

 Human papillomavirus type 16 DNA                        lst International Standard

 Human papillomavirus type 18 DNA                        lst International Standard

 Rabies vaccine                                          6th International Standard

 Acellular Pertussis vaccine Modified Kendrick Test      lst International Standard

 Pertussis antiserum (human)                             lst International Standard

 Pertussis antiserum (human)                             WHO Reference Reagent


 BLOOD PRODUCTS AND RELATED SUBSTANCES

 Anti-hepatitis B immunoglobulin                         2nd International Standard

 Blood coagulation factor IX, concentrate                4th International Standard

 Factor VIIa concentrate                                 2nd International Standard

 Parvovirus B19 DNA                                      2nd International Standard

 Anti-A and anti-B antibodies, human                     WHO Reference Reagents

 Anti-hepatitis C core antigen (HBcAg),
   antibodies, human                                     lst International Standard

 Extended use for the International Standard
   for alpha-1-antitrypsin (05/162)                      1st International Standard


 DIAGNOSTIC REAGENTS AND RELATED SUBSTANCES

 Haemophilia A intron 22 inversion for molecular
   genetic diagnosis                                     lst reference panel

 Fragile X syndrome for molecular genetic
   diagnosis                                             lst reference panel


 CYTOKINES, GROWTH FACTORS AND ENDOCRINOLOGICAL SUBSTANCES

 Insulin-like growth factor (IGF-1)                      2nd International Standard

                                                                                      .../Continued



14
WHO Drug Information Vol 23, No. 1, 2009                                Biomedicines Update



Proposals to establish new or replacement International Standards or WHO
reference reagents: October 2008 (Continued)

 Name of preparation                                  Proposed status
 ANTIBIOTICS

 Gramicidin                                           2nd International Standard


 ITEMS PROPOSED IN MARCH 2008 BUT SUBSEQUENTLY WITHDRAWN

 Human papillomavirus type 16 antibody (human)        1st Reference Reagent to
                                                      1st International Standard

 Thromboplastin, human, plain                         International Standard

 Soluble serum transferrin receptor (STFR),
   recombinant                                        lst International Standard

 Vancomycin                                           2nd International Standard

 Parathyroid hormone 1-84, human recombinant          lst International Standard

 Poliovirus type 1 (Sabin) for MAPREC                 lst International Standard



sight should not be so lax that ineffective    Global reference preparations
or dangerous products are allowed into         A total of 18 new or replacement global
the market place or so restrictive that safe   reference preparations were established.
and effective products face regulations        These are the primary calibrant against
that are too stringent.                        which regional or national measurement
                                               standards are benchmarked. An updated
The ECBS affirmed that reduced data            list is available at http://www.who.int/
packages may be suitable to provide            biologicals/en/.
sufficient assurance about the quality,
safety and efficacy of certain products,       References
but it recommended that WHO and
                                               1. World Health Organization. Biologicals:
countries move forward cautiously. Based       http://www.who.int/biologicals/en/
on the outcome of discussions and
following consideration by the Committee,      2. World Health Organization. Blood products
the ECBS therefore recommended that            and related biologicals: http://www.who.int/
the current document be strengthened           bloodproducts/en/index.html
and some issues further clarified. A
revised version should be re-submitted to      3. World Health Organization. Immunization,
the Committee in 2009.                         Vaccines and Biologicals: http://www.who.int/
                                               immunization/en/




                                                                                            15
WHO Drug Information Vol 23, No. 1, 2009




Safety of Medicines
The mobile laboratory:                          crack down on the manufacturing and
                                                marketing of counterfeit pharmaceutical
a new concept in                                products, the Chinese Government has
medicines surveillance                          implemented a number of drug surveil-
                                                lance programs. In China, fake and
According to the World Health Organiza-         substandard drugs mainly appear at the
tion (WHO), about 6 to 10% of medicines         retail level in the supply chain, and
worldwide are counterfeit; a market worth       therefore these programmes generally
32 billion US dollars in annual sales. The      require samples to be collected from the
phenomenon has grown in recent years            market and analysed in quality control
due to methods of counterfeiting becom-         laboratories at the provincial or district
ing more sophisticated and to an increase       level.
in the quantity of counterfeit drugs cross-
ing borders. Trade in fake medicines            Common methods used on-site by local
mainly occurs in developing countries, but      authorities include basic tests, such as
counterfeiting is now also increasingly         appearance, colour and weight, identifica-
becoming a problem in developed coun-           tion by thin-layer chromatography (TLC),
tries.                                          and basic functional group tests using wet
                                                chemical analysis techniques. Samples
In response to the challenge presented          suspected of being counterfeit are then
by the public health crisis caused by a         sent to quality control laboratories at the
global increase in counterfeit drugs, WHO       district level for analysis using more
has launched a special taskforce, the           specific methods such as high perform-
International Medical Products Anti-            ance liquid chromatography (HPLC).
Counterfeiting Taskforce (IMPACT). The          Such programmes have their merits, but
main purpose of IMPACT is to build a            are not very effective in detecting the
coordinated network across and between          more sophisticated high technology
countries in order to halt the production,      counterfeit products.
trading and sale of fake medicines around
the world. IMPACT is a partnership              To reinforce surveillance, medicines are
comprising all the major anti-counterfeit-      also routinely sampled from the market
ing players, including international organi-    and sent to district laboratories for testing,
zations, nongovernmental organizations,         but this can be costly. Moreover, counter-
enforcement agencies, pharmaceutical            feit drugs are often deliberately made to
manufacturers associations and drug             pass tests defined in the Chinese Phar-
regulatory authorities.                         macopoeia to avoid being caught by the
                                                Chinese State Food and Drug Administra-
As elsewhere in the world, fake and             tion (SFDA) surveillance programme.
substandard drugs in China are driven by        There is therefore a demand to improve
huge profits, and have consequently             on-site analysis so that more sophisti-
become quite sophisticated. In order to         cated counterfeits can be reliably de-
                                                tected, and resources at the district level
Article prepared by Professor Shaohong Jin,     can be better utilized. Reliable on-site
National Institute for the Control of Pharma-   analysis will also allow resources to be
ceutical and Biological Products, China.        efficiently targeted at those cases where



16
WHO Drug Information Vol 23, No. 1, 2009                                 Safety of Medicines



Mobile laboratories in China




law enforcement already has evidence            • To provide a platform for the deployment
that counterfeit products are being               of modern high-technology analytical
distributed.                                      methods that would both aid in the
                                                  crackdown on the sale and distribution
Objectives and development of the                 of counterfeit drug products, and pro-
mobile laboratories                               vide reliable evidence for law enforce-
In January 2003, in response to a call            ment.
from the SFDA for drug monitoring in
predominantly rural areas, the Chinese          • To reduce the high cost and increase
National Institute for the Control of             the efficiency of routine drug quality
Pharmaceutical and Biological Products            post-marketing surveillance.
(NICPBP) proposed that mobile laborato-
ries be used for quality testing. The           On 30 November 2003, less than 10
laboratories are specially designed vans        months after the initial proposal from
equipped to perform various quick analy-        NICPBP, the first mobile laboratory for
ses. The primary objectives of the mobile       drug quality testing was unveiled. On
laboratories are:                               5 January 2004, the former Vice Premier
                                                of China inspected the mobile laboratory
• To utilize the mobility of the laboratories   and watched a live demonstration of a
  to extend drug surveillance into China’s      high technology screening method. The
  remote countryside.                           Vice Premier was very impressed with the
                                                new technology and the concept of such
• To increase consumer confidence in the        a mobile laboratory and requested that
  quality of pharmaceutical products            the Ministry of Finance, the State Com-
  available on the Chinese market.              mittee of Reform and Development and
                                                the National Bureau of Quality and
• To provide quick, easy-to-use, and            Standards provide the programme with
  effective screening methods for on-site       full support and assistance.
  drug testing.



                                                                                           17
Safety of Medicines                                 WHO Drug Information Vol 23, No. 1, 2009



Operating the mobile laboratory                  modern analytical instruments that can
Currently, the only internationally avail-       quickly and non-destructively analyse
able system for quick screening of coun-         drug products. The mobile laboratories
terfeits on-site is the Minilab test kit,        provide an effective screening tool for the
which is capable of testing less than 50         crackdown on counterfeit drugs.
common products, such as antibiotics or
antimalarials, but the Minilab test kit is not   Reliability of the NIR method
sufficient to address the problem of             for drug screening
counterfeits in China. The scientific            During 2006 and 2007, mobile laborato-
equipment in the mobile laboratory               ries tested a total of 10 340 batches of
includes a near-infrared spectrometer,           pharmaceutical products, of which 329
TLC, colorimetry, digital photography,           batches were known to be fake. Of the
visible microscopy, and test kits for            10 340 batches tested, 1087 (about
specific chemical reactions. The main            10.5%) failed the NIR screening, includ-
screening tool is based on a near-infrared       ing all 329 batches that were known to be
spectrometer and a pre-developed                 fake. In addition to the fake products,
standard analytical method that uses a           some non-counterfeit products failed to
library of near-infrared (NIR) spectra           pass the NIR screening because of
(developed by the NICPBP) of all the             changes in product formulations. All
registered pharmaceutical products in            products that failed the NIR screening
China. This near-infrared based system is        were sent to district laboratories for
quick, accurate, non-destructive, and            further testing using more specific meth-
versatile.                                       ods. These results show that NIR screen-
                                                 ing is a very reliable method for the
Apart from analytical instrumentation,           detection of counterfeit drugs, and also
another important tool in the mobile             dramatically decreases the number of
laboratory is the information system,            products that need to be tested in district
which includes manufacturer information          laboratories.
for officially registered products, including
the registration numbers, formulations,          Results of using mobile laboratories
dosages and labelling, etc. as well as a         for drug testing
list of known counterfeits. Dedicated            From April 2004 to November 2005, field
software for the mobile laboratory allows        tests of the mobile laboratories were
easy access to the information, even in          carried out in 5 provinces in China: Anhui,
remote areas. The software is also used          Hubei, Hunan, Sichuan and Yunnan.
to support the near-infrared instruments         Suitability, accuracy and efficiency of the
by providing automatic analysis of the           analytical equipment was evaluated
near-infrared spectrum using pre-loaded          under real conditions. The evaluation
analysis methods, and generation and             included the effect of vibration on the
logging of all test reports.                     equipment when the van was driven on
                                                 rough roads in the countryside. Field tests
In addition, the software includes a             were used to look for possible areas for
database of analytical methods, digital          improvement.
manuals, and predefined standard forms
to record and manage mobile laboratory           As an example of these trials, starting in
activities such as when and where the            August 2004, a mobile laboratory was
mobile laboratories have been dis-               dispatched 165 times in Zhumadian
patched. The mobile laboratory thus              Prefecture of Henan Province. The
combines modern information technology,          mobile laboratory visited 8 of 11 counties
scientific management systems, and               in the prefecture as well as 42 of 186




18
WHO Drug Information Vol 23, No. 1, 2009                                 Safety of Medicines



villages, and covered a total distance of       also result in significant cost-savings.
17 000 km, including highways between           Currently, the mobile laboratory pro-
cities and rough roads in the countryside.      gramme covers about 80% of essential
                                                medicine products commonly used in
The mobile laboratory examined a total of       rural areas.
260 pharmacies and clinics and screened
3965 batches of 408 different drug              The mobile laboratory programme has
products. Of these, 57 batches were             also shown its utility in response to
suspected to be fake and were further           emergencies caused by fake drugs. As an
tested by analytical methods in district        example, in the summer of 2006, instead
laboratories resulting in five batches that     of propylene glycol, the toxic ingredient
were confirmed as counterfeit. The              diethylene glycol was used by mistake in
mobile laboratories also visited AIDS           a few batches of Armillarisin A® for
prevention stations in Zhumadian Prefec-        injection, resulting in 11 deaths. Immedi-
ture, clinics in all 24 villages with a high    ately after the incidents were reported,
population of AIDS patients, and in all         the mobile laboratories were dispatched
nine villages with a moderate population        to screen all suspected products that
of AIDS patients. No fake or substandard        were still on the market. Gas chromatog-
drugs were found in the 1347 batches            raphy (GC) was later used to verify the
that were tested. The extensive surveil-        results for medicines screened positive
lance that is possible with mobile labora-      for diethylene glycol by the mobile labora-
tories thus ensures the quality and safety      tories. In this case, the NIR-based quick
of drug products used by at-risk groups         screening method demonstrated 100%
such as AIDS patients.                          accuracy.

To date, 379 mobile laboratories have           Future development of the mobile
been deployed across China. They have           laboratory programme
visited over 77 000 drug dispensaries,          A second generation of mobile laborato-
and have travelled over 2 000 000 km.           ries is currently under development which
They have screened more than 379 000            incorporate a patented green HPLC
batches of drugs, of which approximately        system that is suitable for mobile opera-
37 000 were suspected of being fake or          tion. The key to this new HPLC is that the
substandard. Of these, approximately            solvents are close-loop recycled inside
14 000 batches were later confirmed to          the van. The advantage of implementing
be counterfeit. The average analysis cost       the HPLC system in the mobile laboratory
per batch in the district laboratory is about   is that if a drug product tests positive
600 RMB. If the traditional test pro-           using the NIR-based prescreening
gramme were used for the 379 000                method, then an on-site verification can
batches, they would have cost almost            be performed immediately.
230 million RMB. The new, targeted
analysis of only those batches that were        Incorporating the HPLC technology
suspect based on pre-screening results          should further improve the accuracy and
reduced the cost of analysis in the district    efficiency of the mobile laboratory pro-
laboratories by about 90%, to approxi-          gramme, especially in remote areas
mately 22 million RMB.                          where the local Food and Drug Adminis-
                                                tration or other analytical laboratories are
These data show that the mobile labora-         far away. A combination of the NIR-based
tories not only increase the successful         quick and non-destructive screening
sampling rate and improve the efficiency        method and on-site verification capability
of the drug surveillance programme, but         using the new HPLC technology may also



                                                                                           19
Safety of Medicines                             WHO Drug Information Vol 23, No. 1, 2009



play an important role in counterfeit drug   surveillance programme and reduced
detection in many developing countries.      costs. They have also expanded the
                                             monitoring area of the programme and
Conclusions                                  have improved the ability of the authori-
The mobile laboratory is a new monitoring    ties to rapidly respond when there is
system that provides in-time information     evidence of adverse reactions to drug
gathering, quick screening, targeted         products on the market. In the future,
sampling based on drug law-enforcement       mobile laboratories will continue to play
efforts, and accurate analytical tests.      an important role in increasing the effi-
These mobile laboratories have demon-        ciency of government efforts to crack
strated considerable success in ensuring     down on the manufacture and marketing
medicines safety. The laboratories have      of counterfeit products in China.
increased the efficiency of the drug




20
WHO Drug Information Vol 23, No. 1, 2009




Pharmacovigilance Focus
Monitoring the safety of                        safety of medicines when used off-label.
off-label medicine use                          First and foremost, monitoring the safety
                                                of medicines in off-label settings is
Medicine labels contain important infor-        necessary to gain information on the
mation on the conditions of use. These          usage of medicines in these settings.
conditions typically include the indication,    While formal study of medication safety
dosage, frequency of administration, and        would be optimal in these settings, such
route of administration. Other important        studies are often not available. Thus,
conditions of use can include the age           safety monitoring plays a critical role.
range of patients, duration of treatment,       Data derived from monitoring safety in an
and contraindications to use of the             off-label setting can also potentially be
medicine. Deviations from the conditions        relevant to the safety of the medicine
of use set forth in the label constitute off-   when used according to the label. In
label use.                                      addition, data derived in the off-label
                                                setting may serve as a stimulus for more
In the USA, off-label use is legal. While       formal study.
the Food and Drug Administration (FDA)
regulates the marketing of medicines, it        There are many specific concerns that
does not regulate prescribing practices. In     need to be addressed when monitoring
one study (1), approximately 21 per cent        the safety of medicines in an off-label
of drug use in office-based practice was        setting. Many factors that could affect the
for off-label use. Off-label use may occur      safety of the medicine could be different
for a variety of reasons. For example,          in the off-label compared to the on-label
there are some diseases for which no            setting. These factors include the age of
adequate, labelled treatment exists. In         patients, range of co-morbidities, use of
these situations, prescribers use medi-         concomitant medication, drug-disease
cines for off-label indications. In the case    interactions and differences in pharma-
of medicines for children, many drugs           cokinetics and pharmacodynamics.
have never been studied in children, so
there has been extensive off-label use in       Despite the importance of monitoring the
children, although there are ongoing            safety of medicines in an off-label setting,
efforts to correct this situation. In some      there are many challenges that this
cases, there may be a reasonable body           situation presents. First, spontaneous
of published evidence to support off-label      reports do not always contain the indica-
use. In other cases, such use is specula-       tion for use or other details that would
tive. However, off-label use may become         allow one to determine that the medicine
part of accepted practice, and may be           was used in a manner not consistent with
part of professional society guidelines.        the product’s label. Second, the identifica-
                                                tion of an adverse drug reaction in the off-
Because off-label use is common, there is       label setting does not necessarily mean
a public health imperative to monitor the       that this reaction is limited to that setting.

Article prepared by Gerald J. Dal Pan, MD, MHS, Food and Drug Administration, USA. (Views
expressed are those of the author, and not necessarily those of the US Food and Drug Adminis-
tration.)



                                                                                           21
Pharmacovigilance Focus                              WHO Drug Information Vol 23, No. 1, 2009



Despite these limitations, spontaneous            used by persons without epilepsy, and
reports can be useful in determining              that these persons experienced seizures
adverse drug reactions when medicines             after tiagabine was started. The product’s
are used off-label.                               label was updated to include this informa-
                                                  tion.
Drug utilization databases may be helpful
in monitoring off-label use of medicines.         In summary, the off-label use of medi-
Though such databases do not typically            cines is common. Monitoring of adverse
contain information on indications for use,       events in this setting is important, though
they can be helpful in identifying other          there are many challenges in doing so.
aspects of off-label use. For example,
                                                  Reference: Radley et al. Arch Intern Med
drug utilization data may shed light on the
                                                  2006; 166:1021-1026.
age range of patients using a medicine,
the duration of therapy, concomitant
medication used, and dosages pre-                 Drotrecogin alfa: what
scribed. Review of such data may indi-            relation to thrombosis?
cate that there is substantial off-label use
and this may provide valuable information         Drotrecogin alfa (activated) is a recom-
for safety monitoring purposes.                   binant form of human activated protein C
                                                  that has antithrombotic, anti-inflammatory
Drug use databases typically do not have          and profibrinolytic activities. It is used
any information on medical diagnoses, so          mainly in intensive care as a treatment for
they are not suitable for identifying             severe sepsis (sepsis associated with
adverse events. Nonetheless, they can             acute organ dysfunction). It is adminis-
be useful for identifying trends that may         tered in multiple slow infusions, as a rule,
require further study. Administrative             at a dose of 24 µg/kg/hour for four days
healthcare databases that contain infor-          (1).
mation both on drug use data and medi-            Sepsis is a complex illness involving both
cal diagnoses can also be useful for              infection and inflammation when the
identifying trends in off-label use, though       body’s response is systemic, instead of
medical record review may be necessary            being localized to the site of infection.
to determine the indication for usage.            This “overreaction” to the infection may
Electronic medical records may be more            result in organ damage and is more
useful than administrative healthcare             dangerous than the initial infection itself
databases if indication for use is linked to      (2).
the drug prescribed. Finally, published
clinical trials studying off-label use may        Patients who die during episodes of
be a valuable source of information on            sepsis are more likely to have coagulation
adverse drug reactions. However, the              defects, including lower levels of circulat-
limitations of clinical trials for ascertaining   ing antithrombin III and protein C. The
adverse event information are well                latter is a vitamin K-dependent anticoagu-
known.                                            lant protease. In sepsis, protein C defi-
                                                  ciency appears before the onset of
One example of the importance of moni-            observable indicators of septic shock.
toring for adverse events in the off-label
setting is seen with the drug tiagabine,          The administration of an exogenous
whose labelled indication in the USA is for       analogue may modulate the patient’s
adjunctive therapy in adults and children
over 12 years of age in the treatment of          Article prepared by Tamás Paál, Hungary.
partial seizures. Post-marketing reports          (Signal Reviewer for the WHO Programme for
indicated that this medicine was being            International Drug Monitoring.)



22
WHO Drug Information Vol 23, No. 1, 2009                          Pharmacovigilance Focus



response during sepsis (1, 3). The only        day of drotrecogin treatment were deep
serious adverse reaction observed in           venous thrombophlebitis and thrombosis.
clinical trials to drotrecogin alfa was
bleeding (3, 4).                               5. A pharmacist described a 45-year-old
                                               female who was administered drotrecogin
Description of new ADR reports                 alfa for four days. Concomitant medica-
Thirteen non-duplicate reports of throm-       tion comprised dopamine and norepine-
botic events in septic patients treated with   phrine. Adverse effects described were
drotrecogin alfa were reported to              intestinal ischaemia, decreased pro-
VigiBase, the database of the WHO              thrombin level and thrombosis.
Collaborating Centre for International
Drug Monitoring, in the period 2002 to         6. A pharmacist described a 72-year-old
2007. There were 12 reports from the           male treated with drotrecogin alfa for four
USA and one from the United Kingdom.           days. Concomitant medication comprised
The reports are summarized below.              sodium bicarbonate, pantoprazole,
                                               norepinephrine, vasopressin, paraceta-
1. A General Practitioner (GP) described       mol, dopamine, amiodarone, vancomycin
a 66-year-old male who developed               and piperacillin-tazobactam combination.
thrombosis after administration of             Adverse reactions described were anae-
drotrecogin alfa. No details were re-          mia, discoloured faeces and thrombosis.
ported.
                                               7. A 68-year-old male was administered
2. A 72-year-old male was treated with         drotrecogin alfa for five days. Concomi-
drotrecogin alfa for three days. On the        tant medication comprised cefotaxime,
second day of treatment, pulmonary             clarithromycin, amiodarone for two days,
haemorrhage and thrombosis were                hydrocortisone for eight days and
observed.                                      lorazepam for two days. One day after
                                               termination of drotrecogin treatment the
3. A 34-year-old male was treated with         patient developed thrombosis.
drotrecogin alfa for six days in 2002.
Concomitant medication comprised               8. A pharmacist described an 86-year-old
antibiotics as well as paracetamol and         male who was treated with drotrecogin
hydrocodone bitartrate. The report, sent       alfa for two days. No concomitant medi-
by a GP, specified thrombosis, multiple        cation was reported. Life-threatening
organ failure and gangrene as adverse          adverse reactions comprised hypoten-
effects. Onset appeared eight days after       sion, gastrointestinal haemorrhage and
termination of treatment.                      thrombosis. Positive dechallenge was
                                               also observed.
4. A 66-year-old male was treated with
drotrecogin alfa for three days. Concomi-      9. A physician reported the case of a
tant medication comprised paracetamol,         female treated with drotrecogin alfa who
codeine, atenolol, lorazepam, triamci-         developed thrombosis. No details were
nolone, propofol, dopamine, levofloxacin,      disclosed.
morphine, famotidine, salbutamol, meto-        10. A pharmacist described a 63-year-old
clopramide, diazepam, midazolam,               female treated with drotrecogin alfa for
thiamine, piperacillin-tazobactam              three days. Concomitant medication
combination and heparin. The dosage            comprised ranitidine, azithromycin,
and other treatment data were missing.         ceftriaxone, dopamine and norepine-
Adverse reactions observed on the last         phrine. Adverse reactions reported were




                                                                                       23
Pharmacovigilance Focus                          WHO Drug Information Vol 23, No. 1, 2009



increased blood chloride and urea,            associated with bleeding, related to its
hypernatraemia, hypokalaemia,                 antithrombotic and profibrinolytic proper-
hyperglycaemia, peripheral oedema,            ties (1). In a Phase III placebo controlled
thrombocythaemia and thrombosis.              clinical trial, the incidence of thrombotic
Dechallenge appeared to be negative. No       events was similar in the drotrecogin and
further information was provided.             placebo arms (4). This was confirmed by
                                              analysis of results from combined clinical
11. A physician described a 70-year-old       trials. When compared with placebo,
female treated with drotrecogin alfa for      patients in the active treatment arms
two days. Reported adverse effects were       experienced numerically fewer thrombotic
rash, jaundice, rectal disorders, bacterial   events, although the difference was not
infection, peritonitis and thrombosis.        statistically significant (7).

12. A health professional reported the        Thrombosis frequently occurs in patients
case of a 29-year-old female treated with     with severe sepsis (7). Disseminated
drotrecogin alfa for two days. Concomi-       intravascular coagulation (DIC) may
tant medication comprised norepine-           develop in 30-50% of patients with severe
phrine and dobutamine. Adverse reac-          sepsis and septic shock, especially when
tions were haemorrhage and thrombosis.        caused by Gram negative bacteria. The
                                              mortality of sepsis is correlated with the
13. A physician reported a 30-year-old        development and severity of DIC (8).
female who was administered drotrecogin       Protein C serves as an important antico-
alfa (no other information was available).    agulant compensatory mechanism. The
The adverse reaction was thrombosis.          cytokines produced in sepsis incapacitate
                                              the protein C pathway. One of the critical
Evaluation of reports                         mediators of DIC is the release of a
Six of the thirteen reports do not mention    transmembrane glycoprotein tissue factor.
concomitant medication. Because of the        This is released in response to exposure
clinical situation in which drotrecogin is    to cytokines or endotoxin and plays a
used, it is almost certain that other         major role in the development of DIC in
medicines were co-administered. Thus, it      septic conditions. For this reason,
is possible that some concomitantly used      drotrecogin alfa is recommended in the
but undisclosed medicine might have           therapy of DIC (8, 9). Additionally, a
contributed to the adverse effect.            retrospective subgroup analysis of a
                                              clinical trial demonstrated a lower mortal-
Seven reports (3, 4, 5, 6, 7, 10 and 12)      ity rate among patients treated with
describe a range of concomitant medica-       drotrecogin alfa who met the criteria for
tions. According to European Union            DIC (10).
Summaries of Product Characteristics
(SPCs) as well as an international data-      Hence, the conclusion is that in these
base (5) of these medicines, only propofol    spontaneous reports a manifestation of
(administered in a single case) has the       the underlying disease was reported as a
recognized, although very rare, adverse       possible adverse drug reaction. This
effect of thrombophlebitis (6).               hypothesis is further supported by the
                                              following.
Signal assessment
On the basis of pharmacological proper-       • Clinical manifestation of DIC is ex-
ties of drotrecogin alfa, administration is     tremely variable (9). The pathological
unlikely to lead to thrombosis. On the          processes involved deplete the body of
contrary, drotrecogin use is frequently         its platelets and coagulation factors and




24
WHO Drug Information Vol 23, No. 1, 2009                            Pharmacovigilance Focus



 so, paradoxically, may lead to both           2. Sepsis.com – understanding sepsis and
 thrombus formation and haemorrhage.           severe sepsis. www.sepsis.com/family_
                                               friends/ understanding.jsp?reqNavId=5.2,
• Septic patients are generally treated in     downloaded 03.01.2008.
  intensive care units but the adverse
                                               3. Cada DJ, Levien T. Drotrecogin Alfa.
  effect reporters (if disclosed) were         Hospital Pharmacy 2002;37(5):511–517.
  mostly GPs, pharmacists and other
  health professionals, possibly not           4. Bernard GR, Vincent Jl, Laterre PF. Efficacy
  possessing detailed information.             and safety of recombinant human activated
                                               protein C for severe sepsis. New England
• On consulting the WHO database, it can       Journal of Medicine 2001;344:699–709.
  be seen that other reports on drotre-
  cogin alfa between 2002 and 2007             5. 1974-–2207 Thomson MICROMEDEX
  specified various haemorrhages (the          Database.
  well-known adverse effects of dro-
                                               6. Propofol. Merck Manual. www.merck.com/
  trecogin alfa), as well as 43 reports of     mmpe/lexicomp/propofol,htm, downloaded 08.
  DIC itself.                                  08.2008.

Conclusion                                     7. GR Bernard et al. Extended evaluation of
In 13 reports of thrombosis associated         Recombinant Human Activated Protein C
with the use of drotrecogin alfa, retrieved    United States Trial (ENHANCE US). Chest
from VigiBase, it appears likely that the      2004;125:2206-2216.
reported thrombotic events represent a
manifestation of the underlying disease        8. Becker JU, Wira CR. Disseminated Intra-
                                               vascular Coagulation. www.emedicine.com/
process (severe sepsis), rather than an
                                               emerg/topic150.htm, downloaded 07.08.2008.
adverse reaction to any administered
medicine. This analysis underlines the         9. Aysola A , Lopez-Plaza I. Disseminated
importance of considered assessment of         Intravascular Coagulation. www.itxm.org/
all reported adverse drug reactions data.      TMU1998/tmu3-99.htm, downloaded
                                               07.08.2008.
References
                                               10. Dhainaut JF et al. Treatment effects of
1. Goshman L. Drotrecogin Alfa, Activated.     drotrecogin alfa (activated) in patients with
Journal of the Pharmacy Society of Wisconsin   severe sepsis with or without disseminated
Mar/Apr 2002;3335.                             intravascular coagulation. Journal of Thrombo-
                                               sis and Haemostasis 2004;2(11):1924–1933.




                                                                                           25
WHO Drug Information Vol 23, No. 1, 2009




Safety and Efficacy Issues
Genetic basis of                               Anaesthetic infusion with pain
adverse drug events                            pumps: articular chondrolysis
United States of America — The first           Canada — Postoperative pain pumps are
data offering health care professionals a      infusion devices designed to continuously
better look into the genetic basis of          deliver controlled amounts of medication
certain types of adverse drug events has       (1, 2). They can be used to infuse local
been released by the Food and Drug             anaesthetic solutions directly into opera-
Administration (FDA) and the Interna-          tive sites for pain management following
tional Serious Adverse Event Consortium        surgical procedures. The device consists
(SAEC). Data are focused on the genet-         of a reservoir containing the local anaes-
ics associated with drug-induced serious       thetic solution which is delivered by
skin rashes, such as Stevens-Johnson           gravity or by electric pump through a
syndrome and toxic epidermal necrolysis,       catheter implanted directly into the
and help better predict an individual’s risk   surgical wound. Bupivacaine is an anaes-
of developing these reactions.                 thetic commonly used with postoperative
                                               pain pumps (3). A combination of
Both skin conditions appear as allergic-       bupivacaine and epinephrine is also
like skin reactions associated with blister-   used, with the epinephrine inducing
ing and peeling, and are considered life-      vasoconstriction and slowing down the
threatening. Medications causing these         absorption of bupivacaine.
serious allergic reactions should be
                                               As of July 2008, Health Canada has
discontinued. If such signs and symptoms
                                               received 8 incident reports of articular
are not quickly recognized, these reac-
                                               chondrolysis following shoulder surgery
tions can be fatal.
                                               that were suspected of being associated
                                               with the use of postoperative pain pumps.
The SAEC is a non-profit partnership of
                                               The pain pumps were used for about 48
pharmaceutical companies, the Wellcome
                                               hours after surgery. All of the patients
Trust, and academic institutions focused
                                               received bupivacaine with epinephrine.
on research relating to the genetics of
                                               Chondrolysis was diagnosed between
drug-induced serious adverse events.
                                               one month and one year after surgery
                                               and use of the pain pumps.
Researchers who enter into a data use
agreement can obtain free access to the        Chondrolysis is a progressive degenera-
data to generate custom data inquiries         tion of the cartilage for which the cause is
and obtain immediate results on the            not fully understood (4, 5). Chondrolysis
genetic basis of adverse drug events.          of the shoulder results in narrowing of the
                                               joint space, leading to pain and loss of
References                                     motion; it is a debilitating condition that
                                               requires medical attention and possibly
1. FDA News, 10 February 2009. www.fda.gov     surgery (3, 4). Chondrolysis is listed
2. International Serious Adverse Event
                                               among the possible adverse incidents in
Consortium at http://www.saeconsortium.org     the device labelling of pain pumps (1, 2).
                                               The device labelling states that the



26
WHO Drug Information Vol 23, No. 1, 2009                             Safety and Efficacy Issues



continuous intra-articular infusion of           7. van Huyssteen AL, Bracey DJ. Chlorhexi-
anaesthetics, particularly when epine-           dine and chondrolysis in the knee. J Bone
phrine is also used, is not recommended.         Joint Surg Br 1999;81(6):995–6.

The association between postoperative            8. Leclair A, Gangi A, Lacaze F, et al. Rapid
pain pumps and the development of                chondrolysis after an intra-articular leak of
                                                 bone cement in treatment of a benign aceta-
chondrolysis is difficult to identify. Indeed,   bular subchondral cyst: an unusual complica-
chondrolysis may appear many months              tion of percutaneous injection of acrylic
after the use of a pain pump (3–5). In           cement. Skeletal Radiol 2000;29(5): 275–8.
addition, confounders such as the con-
comitant use of health products (e.g.,           9. Jerosch J, Aldawoudy AM. Chondrolysis of
gentian violet, chlorhexidine, bone ce-          the glenohumeral joint following arthroscopic
ment) and radiofrequency devices may             capsular release for adhesive capsulitis: a
be responsible for causing chondrolysis          case report. Knee Surg Sports Traumatol
after shoulder surgery (5–10).                   Arthrosc 2007;15(3):292–4.

                                                 10. Ciccone WJ II, Weinstein DM, Elias JJ.
Health care professionals are encouraged         Glenohumeral chondrolysis following thermal
to follow the instructions for use and           capsulorrhaphy. Orthopedics 2007;30(2):158–
refrain from using postoperative pain            60.
pumps for continuous intra-articular
infusion of local anaesthetics, particularly
with epinephrine, after shoulder surgery
                                                 Atomoxetine: serious
(1, 2).                                          liver injury
Extracted from the Canadian Adverse              United States of America — The Food
Reactions Newsletter, Volume 19 ,                and Drug Administration (FDA) continues
Number 1 (2009).                                 to receive reports of serious liver injury in
                                                 patients given atomoxetine. Atomoxetine
References                                       received FDA approval on 26 November
                                                 2002 as the first non-stimulant medication
1. On-Q PainBuster [Canadian instructions for    used for the treatment of attention deficit
use]. Lake Forest (CA): I-Flow Corporation;      hyperactivity disorder (ADHD) in children
2008.
                                                 (aged 6 years and above) and adults (1).
2. Donjoy Pain Control Device [Canadian
instructions for use]. Huntington Beach (CA):    Atomoxetine’s therapeutic action is
Curlin Medical Inc; 2007.                        believed to be due to its selective inhibi-
3. Hansen BP, Beck CL, Beck EP, et al.
                                                 tion of norepinephrine reuptake. From the
Postarthroscopic glenohumeral chondrolysis.      year 2002 to 2007, approximately 3.3
Am J Sports Med 2007;35(10):1628–34.             million patients received a prescription for
                                                 atomoxetine in the United States. Of
4. Yarbrough R, Gross R. Chondrolysis: an        those, approximately 2.1 million patients
update. J Pediatr Orthop 2005;25(5):702–4.       (64%) were children aged 17 years and
5. Petty DH, Jazrawi LM, Estrada LS, et al.      younger (2).
Glenohumeral chondrolysis after shoulder
arthroscopy: case reports and review of the      While a signal for serious liver injury was
literature. Am J Sports Med 2004;32(2):509–      not detected during premarket clinical
15.                                              trials of atomoxetine, two published post-
6. Shibata Y, Midorikawa K, Koga T, et al.
                                                 marketing reports did identify instances of
Chondrolysis of the glenohumeral joint           atomoxetine-induced hepatitis (3, 4). In
following a color test using gentian violet.     one of these reports, there was a positive
Int Orthop 2001;25(6):401–3.                     rechallenge with atomoxetine. Subse-



                                                                                            27
Safety and Efficacy Issues                           WHO Drug Information Vol 23, No. 1, 2009



quent to these reports, a bolded warning         2. Bangs ME, Ling J, Zhang S, et al. Hepatic
was added in 2004 to the atomoxetine             events associated with atomoxetine treatment
label indicating an increased risk for           for attention deficit hyperactivity disorder. Drug
severe liver injury.                             Safety. 2008;31(4): 345–54.
                                                 3. Stojanovski SD, Casavant MJ, Hayat MM,
Since the 2004 labelling change, FDA
                                                 et al. Atomoxetine-induced hepatitis in a child.
has received six additional reports of           Clin Toxicol (Phila). 2007;45 (1):51–5.
serious liver injury in patients taking
atomoxetine. Following an evaluation of          4. Lim JR, Faught PR, Chalasani NP. Severe
the information from the drug sponsor            liver injury after initiating therapy with atomox-
and additional literature articles submitted     etine in two children. J Pediatr. 2006;148(6):
to FDA, the atomoxetine product label            831–4.
was again revised in 2007. The warnings
and precautions section of the drug label        Drotrecogin alfa:
advises prescribers about the risk for           ongoing safety review
severe liver injury with this drug (1).
                                                 United States of America — The Food
Post-marketing reports indicate that             and Drug Administration (FDA) is aware
atomoxetine is associated with serious           of a retrospective study (1) which has
idiosyncratic liver injury. Some of the          reported an increased risk of serious
cases reported additional confounding            bleeding events and death in patients
factors, such as occasional acetami-             with sepsis (a severe illness related to a
nophen use. Some of the cases lacked             bloodstream infection) and baseline
sufficient clinical detail to convincingly       bleeding risk factors who received
detail the relationship between the use of       drotrecogin alfa. Drotrecogin alfa (acti-
atomoxetine and liver injury. The mecha-         vated) (Xigris®) is a recombinant human
nism of atomoxetine-induced liver injury         activated protein C indicated for the
remains unknown.                                 reduction of mortality in adult patients
                                                 with severe sepsis who have a high risk
FDA encourages physicians to:                    of death (2). The baseline bleeding risk
                                                 factors as defined by this study are the
• Inform patients to immediately contact
  their physician at the first sign or symp-     same as those described in the drotre-
  tom of fatigue, loss of appetite, nausea,      cogin alfa prescribing information.
  vomiting, pruritus, dark urine, jaundice
  of the sclerae or skin, right upper            An editorial (3) accompanying the article
  quadrant tenderness, or unexplained            stated that one approach to increasing
                                                 the safety of drotrecogin alfa would be to
  “flu–like” symptoms.
                                                 not administer it to any patients with
• Determine liver enzyme levels when a           sepsis and baseline bleeding risk factors,
  patient presents with signs or symptoms        effectively changing a warning in the
  of liver injury.                               product labelling to a contraindication.
                                                 Under FDA regulations, contraindications
• Discontinue and not resume atomoxet-           in the prescribing information describe
  ine treatment if patients present with         situations where the risks are known (that
  jaundice or laboratory evidence of liver       is, are not theoretical) and where the risks
  injury                                         of use clearly outweigh any possible
                                                 benefit.
References
1. Atomoxetine (Strattera®) product labelling.   The study was a retrospective medical
http://www.fda.gov/cder/foi/label/2008/          record review of 73 patients who received
021411s024s025s026lbl.pdf                        drotrecogin alfa. Serious bleeding events



28
WHO Drug Information Vol 23, No. 1, 2009                             Safety and Efficacy Issues



occurred in 7 of 20 patients (35%) who           Clopidogrel is an antiplatelet drug that is
had a bleeding risk factor vs only 2 of 53       used to prevent blood clots that could
(3.8%) patients without any bleeding risk        lead to heart attacks or strokes in patients
factors. More patients with baseline             at risk for these problems. The drug
bleeding risk factors died (13/20; 65%)          clopidogrel is a “pro-drug” which means
compared to patients without any bleed-          that it has to be metabolized by the body
ing risk factors (13/53; 24.5%). The             before it can be biologically active and
authors acknowledge that there are               have the effect of preventing blood clots.
limitations to this study, such as its           Understanding that there are differences
retrospective design and the small size of       in how the body metabolizes clopidogrel
the patient population, that limit the ability   and there are effects that other drugs
to draw definitive conclusions from the          may have on its metabolism is important
data.                                            because decreases in the effectiveness
                                                 of clopidogrel might be avoided, in part,
References                                       by using other drugs with clopidogrel that
                                                 do not interfere with its metabolism.
1. Gentry CA, Gross KB, Sud B, Drevets DA.
Adverse outcomes associated with the use of      One class of drugs commonly used with
drotrecogin alfa (activated) in patients with
                                                 clopidogrel is proton pump inhibitors
severe sepsis and baseline bleeding precau-
tions. Crit Care Med 2009;37(1):19-25.           (PPIs). Some reports suggest that use of
                                                 certain PPIs may make clopidogrel less
2. APACHE II score >25. The APACHE II            effective (3, 4) by inhibiting the enzyme
score (Acute Physiology and Chronic Health       that converts clopidogrel to the active
Evaluation II) is a commonly-used severity of    form of the drug. Other reports do not
disease classification system calculated for     suggest this effect (5, 6). Proton pump
critically ill patients after admission to an    inhibitors decrease stomach acid and are
intensive care unit.                             used to treat frequent heartburn and
                                                 stomach ulcers. Clopidogrel can irritate
3. Sweeney DA, Natanson C, Eichacker PQ.
                                                 the stomach so PPIs are commonly used
Recombinant human activated protein C,
package labeling, and hemorrhage risks. Crit     with clopidogrel to help reduce this
Care Med 2009; 37 (1):327-328.                   irritation. Currently, there is no evidence
                                                 that other drugs that reduce stomach
4. Early communication of ongoing safety         acid, such as H2 blockers or antacids
review. http://www.fda.gov/medwatch              interfere with the antiplatelet activity of
                                                 clopidogrel.
Clopidogrel bisulfate:
                                                 References
ongoing safety review
                                                 1 Frere C et al. Effect of cytochrome P450
United States of America — The Food
                                                 polymorphisms on platelet reactivity after
and Drug Administration (FDA) is aware           treatment with clopidogrel in acute coronary
of published reports that clopidogrel            syndrome. Am J Cardiol 2008; 101:1088–93.
(Plavix®) is less effective in some pa-
tients than it is in others. Differences in      2 Trenk et al. Cytochrome P450 2C19 681G A
effectiveness may be due to genetic              polymorphism and high on-clopidogrel platelet
differences in the way the body metabo-          reactivity associated with adverse 1-year
lizes clopidogrel (1, 2) or that using           clinical outcome of elective percutaneous
certain other drugs with clopidogrel can         coronary intervention with drug eluting or
interfere with how the body metabolizes          bare-metal stents. J Am Coll Cardiol 2008; 51:
                                                 1925–34.
clopidogrel (3).




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Who drug information vol1

  • 1.
  • 2. WHO Drug Information Vol 23, No. 1, 2009 World Health Organization WHO Drug Information Contents Quality of Medicines Erlotinib: Use in hepatic impairment and advanced solid tumours 32 WHO medicines prequalification: Generic piperacillin and tazobactam: progress in 2008 3 medication errors 33 Safety of artemisinin combination therapy: Herbal and Traditional pregnant women 33 Medicines WHO Congress on Traditional Medicine Regulatory Action and News and the Beijing Declaration 8 Efalizumab: suspension of marketing authorization 35 Contusugene ladenovec: withdrawal of Biomedicines Update marketing application 36 Global norms and standards for biological Paliperidone: withdrawal of application quality, safety and efficacy 12 for extension of indication 36 First EMEA meeting of Committee for Advanced Therapies 36 Safety of Medicines The mobile laboratory: a new concept in medicines surveillance 16 Consultation document International Pharmacopoeia Pharmacovigilance Focus Oxytocin 38 Oxytocin injection 43 Monitoring the safety of off-label medicine use 21 Drotrecogin alfa: what relation to Recent Publications, thrombosis? 22 Information and Events Low availability, high prices keep Safety and Efficacy Issues essential medicines out of reach 46 Genetic basis of adverse drug events 26 Sources and prices of selected Anaesthetic infusion with pain pumps: medicines for children 46 articular chondrolysis 26 Two international summer courses Atomoxetine: serious liver injury 27 in the Netherlands 47 Drotrecogin alfa: ongoing safety review 28 Global politics of pharmaceutical Clopidogrel bisulfate: ongoing safety monopoly 48 review 29 Modafinil: adverse skin and psychiatric reactions 30 Recommended International Levothyroxine update 30 Nonproprietary Names: Temsirolimus: hypersensitivity reactions 31 Continued vaccination with Gardasil® 32 List 61 49 1
  • 3. World Health Organization WHO Drug Information Vol 23, No. 1, 2009 WHO Drug Information is also available online at http://www.who.int/druginformation NEW ! WHO Drug Information DIGITAL LIBRARY with search facility at http://www.who.int/druginformation Subscribe to our e-mail service and receive the table of contents of the latest WHO Drug Information (To subscribe: send a message to LISTSER@WHO.INT containing the text: subscribe druginformation) 2
  • 4. WHO Drug Information Vol 23, No. 1, 2009 Quality of Medicines WHO medicines prequalification: progress in 2008 The WHO Prequalification Programme for considerable breakthrough in making Medicines (PQP) was initiated in 2001 as user-friendly formulations available that a service provided by the World Health will also improve efficacy of treatment. Organization (WHO) to facilitate access to medicines that meet unified interna- The number of products prequalified in tional standards of quality, safety and 2008 was the highest in six years. The efficacy for HIV/AIDS, malaria, tuberculo- main reasons for this were: sis and reproductive health. • Increasing number of well prepared new The work is carried out through: submissions in 2007–2008. • Stringent assessment of pharmaceutical • Improved quality of evidence to demon- product dossiers. strate quality, safety and efficacy of products. • Inspection of pharmaceutical manufac- turing sites (both for finished dosage • Expanded staffing component in 2007. forms and active pharmaceutical ingre- • Implementation of management effi- dients) and contract research organiza- ciency tools which improve the evalua- tions (CROs). tion process. • Prequalification of pharmaceutical quality control laboratories (QCLs). List of prequalified medicines Inclusion in the list does not mean that • Advocacy for medicines of assured the prequalification status of a product is quality. assured indefinitely. All approved medi- cines have to be checked regularly to The Bill & Melinda Gates Foundation as ensure that any changes undertaken by well as UNITAID are the main financial manufacturers do not undermine the supporters of PQP. quality, safety and efficacy of the product. Newly prequalified medicines In order to achieve this objective, WHO Forty products were added to the list of carries out re-inspections of manufactur- prequalified medicines in 2008, an ing sites as well as random quality control increase from 21 products in 2007. The tests of prequalified medicines. Since the total number of prequalified medicines prequalified products list is constantly currently stands at 196. being added to, information maintenance and updating becomes crucial to the A major achievement in 2008 was the preservation of established international prequalification of new products specially standards. designed to treat HIV/AIDS in children, as well as the first fixed-dose combination New submissions to PQP tablets of artesunate and amodiaquine to Certain product groups are urgently in treat malaria. These products represent a need of expansion to increase available 3
  • 5. Quality of Medicines WHO Drug Information Vol 23, No. 1, 2009 In 2008, the WHO Medicines Prequalification Programme: • Prequalified a total of 40 medicinal products. The list of prequalified medicines now contains nearly 200 products. • Prequalified the first ever fixed-dose combination tablets of antiretroviral medi- cines designed for use in children to treat HIV/AIDS, and the first fixed-dose combination tablets of artesunate and amodiaquine to treat malaria. • Organized 11 training workshops for capacity building in resource-limited coun- tries for staff of regulatory authorities and pharmaceutical manufacturers. • Provided manufacturers with scientific advice and technical assistance to sup- port improvements in the quality of their products. • Implemented the biowaiver concept to facilitate evaluation of product dossiers. • Prequalified six quality control laboratories. • Planned and implemented three comprehensive medicines sampling and testing programmes in countries that were recipients of drug donations. • Revised and updated the procedure for prequalification to increase transparency and accountability of prequalification performance. • Contributed to the development of guidelines and standards to facilitate global quality assurance activities, including pharmacopoeial monographs and chemi- cal reference standards. • Opened prequalification to include zinc and influenza products and considerably expanded the invitation list of reproductive health products. treatment options (e.g., second-line required. Insufficient quality specifications antituberculosis and paediatric antiretrovi- presented for reproductive health and ral combination products). However, it antimalarial products and manufacturing was again noted that the number of conditions are of particular concern. products submitted for evaluation within this category was insufficient to meet In recent years, documented quality current demand. This is mainly due to a assurance of medicines has become an lack of commercial incentives available to essential requirement of international manufacturers to develop products funding agencies for successful bidding in intended for small or non-profitable procuring essential medicines for devel- markets. oping countries. Manufacturers should therefore be increasingly motivated to In the past year, the number and quality invest in enhancing their own manufactur- of product dossiers submitted for assess- ing and control processes to improve the ment continued to present many chal- quality of submissions to the PQP. lenges. Newcomer manufacturers having limited or no experience in production Technical assistance to manufacturers according to international standards have Time and resources are needed from great difficulty in submitting the evidence applicants to obtain product prequalifica- 4
  • 6. WHO Drug Information Vol 23, No. 1, 2009 Quality of Medicines tion and this includes dedication to Capacity building of implementation of corrective action to regulatory authorities meet international quality standards. It In 2008, the PQP continued to offer follows that an increase in the number of national regulatory personnel from available prequalified medicines can only resource-limited countries a three-month be achieved based on increased capacity full-time post at WHO. These rotational building and technical assistance activi- positions for quality assessors are aimed ties. at creating links and form a network between WHO and the countries in- Consequently, since 2006, the PQP has volved, as well as enhance information provided coordinated technical assistance exchange between both parties. aimed at resolving specific practical problems encountered by manufacturers In addition, assessors from less re- or quality control laboratories. Assistance sourced regulatory authorities continue to is provided by qualified professionals in participate in PQP assessment sessions the form of an audit and training in where they account for one-third of the technical or regulatory areas. total external assessor contribution. Since 2008, inspectors from these Such action in resource-limited countries authorities are invited to take part in has become one of the core activities of WHO inspections as observers. Regula- PQP since 2007 and will remain so for tors from the WHO Africa Region have the following years. In 2008, PQP pro- been especially active in this process. vided eight technical assistance missions to pharmaceutical manufacturers in five Dossier assessments different countries. and expert advice In 2008, seven assessment sessions Training were organized at the UNICEF Supply WHO recognizes the crucial role of Division in Copenhagen where product capacity building through training and dossiers are received and stored. The hands-on practice. In 2008, PQP organ- number of assessment reports for 2008 ized 11 training courses and co-organized increased to 732 compared to 463 in four training activities together with other 2007. In addition to regular assessment partners in 10 different countries (see activities, provision of expert scientific table on page 7). advice to applicants remained high on the This tuition on general or specific techni- agenda. In 2008, a total of 13 bioequiva- cal issues is also offered to larger groups lence study protocols were reviewed, formed by manufacturers, national more than 60 bioequivalence queries medicines regulatory agency staff and answered, and close to 80 separate professionals from quality control labora- quality issues handled by the respective tories. Training courses include group expert panels. sessions as well as focused communica- tion between the involved parties, such as Inspections manufacturers and lecturers who are part A total of 38 inspections of pharmaceuti- of the assessment or inspection teams cal manufacturers and 14 inspections of working with PQP. In 2008, these courses CROs were carried out in seven different involved more than 600 participants and countries in 2008. As in all previous 46 lecturers and trainers provided by years, the national inspectorates from PQP. well established regulatory authorities continued to provide staff inspectors for 5
  • 7. Quality of Medicines WHO Drug Information Vol 23, No. 1, 2009 Prequalification assessment and inspection statistics 2007 2008 Dossier Assessment Assessment sessions in Copenhagen 6 7 Total number of assessment days 42 46 Total number of assessment reports 463 732 Assessment reports on HIV/AIDS products 298 494 Assessment reports on TB products 100 100 Assessment reports on malaria products 54 115 Assessment reports on reproductive health products 11 19 Assessment reports on influenza products - 4 Inspections 46 62 Manufacturing sites of finished product manufacturers 26 27 Manufacturing sites of active pharmaceutical ingredients 6 11 Contract research organizations 13 14 Pharmaceutical quality control laboratories 1 10 prequalification purposes. France was the of delivery to the recipient country. How- leading country in terms of providing ever, quality can deteriorate during inspection support. transportation and storage. To verify that the quality of essential medicines is Prequalification of quality maintained throughout the supply chain control laboratories until the medicines reach the end user, The prequalification of quality control several sampling and testing programmes laboratories was restarted in 2007 when have been designed and implemented. 12 laboratories expressed interest in prequalification. In 2008, PQP carried out Programme strengthening 10 inspections of quality control laborato- and development of standards ries with six gaining prequalification Major procedural improvements to PQP status. in 2008 include: Testing of medicines • Revision and update of the procedure The prequalification status of a medicinal for prequalification to increase transpar- product guarantees its quality at the time ency and accountability of PQP. Major medicines testing programmes organized by WHO PQP in 2008 Aim of sampling Countries involved Total number and testing of samples Quality survey of anti- Cameroon, Ethiopia, Ghana, malarial medicines Kenya, Nigeria, Tanzania 936 Quality monitoring of products Kenya, Tanzania, Uganda, funded by UNITAID Zambia 378 Quality survey of anti-TB Armenia, Azerbaijan, Belarus, medicines in Eastern Europe Kazakhstan, Ukraine, Uzbekistan 360 6
  • 8. WHO Drug Information Vol 23, No. 1, 2009 Quality of Medicines Training workshops organized by WHO PQP in 2008 Date Location Content of training 25–29 February Brasilia, Brazil New approaches to quality risk manage- ment in manufacture of medicines. 21–25 April Lahore, Pakistan Development of PQP submission dossiers. 28 April–1 May Mumbai, India Pharmaceutical development with a focus on paediatric formulations. 2–6 June Dar-es-Salaam, United Evaluation of generic products focusing Republic of Tanzania on bioequivalence and biowaiver data. 16–20 June Amman, Jordan Introduction to PQP and technical requirements. 16–20 June Teheran, The Islamic Introduction to PQP and technical Republic of Iran requirements. 23–27 June Beijing, China GMP for reproductive health products and dossier requirements. 8–11 July Rabat, Morocco GMP – air and water treatment systems 20–24 October Jakarta, Indonesia GMP for reproductive health products and dossier requirements. 3–7 November Accra, Ghana Regulatory requirements and data assessment of artemisinin-based fixed dose combination medicines. 1–5 December Nanchang, China GMP training for SFDA inspectors • Opening of new tracks for the prequalifi- development and updating of new and cation of zinc and influenza products. existing WHO guidelines and standards continued to facilitate global quality • Implementation of the biowaiver concept assurance activities. Such guidance to facilitate evaluation of product dossi- includes pharmacopoeial monographs ers. and chemical reference standards. The procedure for prequalification of active • Publication of the first “notices of con- pharmaceutical ingredients was approved cern” highlighting good manufacturing by the WHO Expert Committee on Phar- practice (GMP) violations observed maceutical Specifications for implementa- during inspections. tion in 2009. PQP activities are based on scientifically Reference: The Medicines Prequalification sound and updated internationally ac- Programme (PQP). http://www. who.int/ cepted quality standards. In 2008, prequal 7
  • 9. WHO Drug Information Vol 23, No. 1, 2009 Herbal and Traditional Medicines WHO Congress on Traditional Medicine and the Beijing Declaration Representatives of over 70 Member States attended the first WHO Congress on Traditional Medicine held on 7–9 November 2008 in Beijing, China. Satellite sympo- sia were held to discuss related technical topics. Presentations were given by repre- sentatives of organizations such as the World Self-Medication Industry (WSMI), the World Federation of Acupuncture-Moxibustion Societies (WFAS), the International Pharmaceutical Federation (FIP), and the World Federation of Chiropractic (WFC). Almost 1500 people were present at the events. Highlights of the Congress included adoption of the Beijing Declaration promoting the safe and effective use of traditional medicine and calling on WHO Member States and other stakeholders to take steps to integrate traditional medicine, complemen- tary and alternative medicines (TM/CAM) into national health systems. Sharing of national experience and information by Member States in five areas aimed at leveraging future action. • National policy on TM/CAM. • National regulation of traditional and herbal medicines. • TM use in Primary Health Care. • National regulation of TM/CAM practice. • Research on TM/CAM. Participants visited community health centres, clinics and hospitals for traditional medicine. These models showed how traditional and Western medicine can work together and be successfully integrated into China’s health system. In 2008, WHO marked its 60th anniver- health care by WHO and its Member sary and the 30th anniversary of the Alma States. Ata Declaration, adopted by UNICEF and WHO in 1978. Although traditional Use of traditional medicine has changed medicine has been used for thousands dramatically over the past thirty years. of years and has made a fundamental Due to its affordability, availability and contribution to human health, the Alma accessibility, traditional medicine has Ata Declaration was the first formal played an important role in meeting the recognition of the role of traditional demands of primary health care in many medicine and its practitioners in primary developing countries. 8
  • 10. WHO Drug Information Vol 23, No. 1, 2009 Herbal and Traditional Medicines Since the 1990s, the use of traditional and western medicine can blend together medicine has surged. It not only main- in beneficial harmony, using the best tains its function in primary health care in features of each system. developing countries (70–80% of the population in Ethiopia and India still Delegates were welcomed by the Minister depend on traditional medicine and of Health, People’s Republic of China. In practitioners for primary health care), its their presentations, the Minister of Health use has expanded widely in many devel- of the Union of Myanmar and the Deputy oped countries where it is referred to as Minister of Health of South Africa ex- complementary or alternative medicine plored the role of integration of traditional (CAM). For instance, 70% of the popula- medicine into primary health care and tion in Canada and 80% in Germany have actions that their respective countries used CAM. National health authorities have taken. The need for appropriate were asked to consider how to integrate regulatory oversight of complementary TM/CAM into their national health sys- medicine products was expressed by the tems and significant progress has been National Manager of the Therapeutic made since initiation of the WHO Tradi- Goods Administration of Australia. tional Medicine Strategy in 2002. During the International Forum on Inte- WHO Congress on gration of Traditional Medicine/CAM into Traditional Medicine Health Systems, 26 delegates presented To further assess the role of traditional short national reports outlining the regula- medicine/CAM, review the progress of the tory framework for traditional medicine, countries and help Member States products and practice in their respective integrate traditional medicine/CAM into countries. To facilitate discussion, the their national health systems, the first presentations were separated into five WHO Congress on Traditional Medicine topic areas: on 7–9 November 2008, was organized in Beijing, China. The Congress was hosted • National Policy on TM/CAM and integra- by the Ministry of Health and the State tion into national health systems. Administration of Traditional Chinese Medicine of the Government of China, in • National regulation of traditional and cooperation with four nongovernmental herbal medicines. organizations (NGOs) in official relations with WHO — the World Self-Medication • Traditional medicine in primary health Industry (WSMI), the World Federation of care. Acupuncture-Moxibustion Societies • National regulation of traditional medi- (WFAS), the International Pharmaceutical cine/CAM practice. Federation (FIP), and the World Federa- tion of Chiropractic (WFC). • Research and development of tradi- tional medicine. During the opening ceremony, the Direc- tor-General of WHO identified the impor- While presentations showed that it is tance of traditional medicine in primary often necessary to tailor legislation and health care, the role of research, the need delivery to reflect the needs and traditions for appropriate licensing or registration of of individual countries, a number of practitioners and the importance of common themes and issues did emerge. patient-practitioner interaction. It was Most notable of these were the impor- noted that within the context of primary tance of practitioner training, issues health care, the two systems of traditional related to safety, need to enhance re- 9
  • 11. Herbal and Traditional Medicines WHO Drug Information Vol 23, No. 1, 2009 search into both products and practices, created to discuss and harmonize the importance of labelling and information as comments submitted to WHO prior to the it relates to supporting informed choice, Congress and to enable the Declaration and the need for appropriate integration to be presented to the Congress. into primary health care. Congress delegates adopted the Beijing Delegates also heard from two WHO Declaration during the WHO Congress on partners (The Nippon Foundation and the Traditional Medicine. In addition to a Regional Government of Lombardy) who preamble text noting a number of related described their work in this area. The four initiatives and reflecting the importance of nongovernmental organizations hosting national contexts with regard to capacity, satellite conferences were also given the priorities and relevant legislation, the opportunity to make presentations and Beijing Declaration is set out below. observe the Congress. The Beijing Declaration will serve to A key outcome of the Congress was the promote the safe and effective use of Beijing Declaration, which identified traditional medicine, and calls on WHO common aims and principles reached by Member States and other stakeholders to participants at the Congress. Preparation take steps to integrate traditional medi- of the declaration was structured, starting cine/CAM into national health systems. some months prior to the Congress with During the closing of the International circulation of the first draft. Comments Forum the WHO Assistant Director- were collected and modifications made General for Health Systems and Services with a subsequent draft sent to partici- said, “This is a landmark declaration, after pants before the Congress. During the a landmark Congress.” Congress, an ad hoc drafting team was Beijing Declaration Adopted by the WHO Congress on Traditional Medicine, Beijing, China, 8 November 2008 Participants at the World Health Organization Congress on Traditional Medicine, meeting in Beijing this eighth day of November in the year two thousand and eight: Recalling the International Conference on Primary Health Care at Alma Ata thirty years ago and noting that people have the right and duty to participate individually and collectively in the planning and implementation of their health care, which may include access to traditional medicine. Recalling World Health Assembly resolutions promoting traditional medicine, includ- ing WHA56.31 on Traditional Medicine of May 2003. Noting that the term “traditional medicine” covers a wide variety of therapies and practices which may vary greatly from country to country and from region to region, and that traditional medicine may also be referred to as alternative or complementary medicine. .../ .../ Continued 10
  • 12. WHO Drug Information Vol 23, No. 1, 2009 Herbal and Traditional Medicines Beijing Declaration (continued) Recognizing traditional medicine as one of the resources of primary health care services to increase availability and affordability and to contribute to improve health outcomes including those mentioned in the Millennium Development Goals. Recognizing that Member States have different domestic legislation, approaches, regulatory responsibilities and delivery models. Noting that progress in the field of traditional medicine has been obtained in a number of Member States through implementation of the WHO Traditional Medicine Strategy 2002-2005. Expressing the need for action and cooperation by the international community, governments, and health professionals and workers, to ensure proper use of traditional medicine as an important component contributing to the health of all people, in accordance with national capacity, priorities and relevant legislation. In accordance with national capacities, priorities, relevant legislation and circum- stances, hereby make the following Declaration: I. The knowledge of traditional medicine, treatments and practices should be respected, preserved, promoted and communicated widely and appropriately based on the circumstances in each country. II. Governments have a responsibility for the health of their people and should formulate national policies, regulations and standards, as part of comprehensive national health systems to ensure appropriate, safe and effective use of tradi- tional medicine. III. Recognizing the progress of many governments to date in integrating tradi- tional medicine into their national health systems, we call on those who have not yet done so to take action. IV. Traditional medicine should be further developed based on research and innovation in line with the “Global strategy and plan of action on public health, innovation and intellectual property” adopted at the Sixty-first World Health Assembly in resolution WHA61.21 in 2008. Governments, international organiza- tions and other stakeholders should collaborate in implementing the global strategy and plan of action. V. Governments should establish systems for the qualification, accreditation or licensing of traditional medicine practitioners. Traditional medicine practitioners should upgrade their knowledge and skills based on national requirements. VI. The communication between conventional and traditional medicine providers should be strengthened and appropriate training programmes be established for health professionals, medical students and relevant researchers. 11
  • 13. WHO Drug Information Vol 23, No. 1, 2009 Biomedicines Update Global norms and standards for biological quality, safety and efficacy WHO Expert Committee on Biological Standardization Established in 1947, the Expert Committee on Biological Standardization (ECBS) is one of the longest standing World Health Organization (WHO) committees and has overall responsibility for setting written standards and establishing reference prepa- ration materials. Standards developed through the ECBS relate to the production and quality control of safe and effective biological products. They provide guidance for national regulatory authorities and manufacturers and serve as the standard for prequalification of vaccines for supply to countries through international agencies. Reference preparation materials are available from designated WHO laboratories and provide the basis for comparison of materials used in biologicals worldwide. Members of the ECBS are scientists from national control agencies, academia, re- search institutes and public health bodies. These scientists act as individual experts and not as representatives of their respective organizations or employers. The deci- sions and recommendations of the ECBS are based entirely on scientific principles and public health considerations. The ECBS reports directly to the WHO Executive Board, which is the executive arm of the World Health Assembly. The outcome of each ECBS meeting is subsequently published in a technical report. This report provides updated information on stand- ards for assuring the quality, safety and efficacy of biological products as well as on the establishment of new or updated WHO international standards for designating the activity of biological substances. ECBS technical reports are available at: http://www.who.int/biologicals/publications/trs/en/index.html Highlights of the The WHO Expert Committee on Biologi- 2008 ECBS meeting cal Standardization (ECBS) establishes global norms and standards that help Biological medical products such as define products of assured quality. The vaccines, blood products, biotherapeutics ECBS meets annually and their most and associated diagnostics save lives, recent meeting was held in Geneva from reduce suffering and improve health, but 13 to 17 October 2008. During the meet- only if these products and technologies ing, 57 agenda items were considered. are of good quality, are safe, effective, This was accomplished, as in previous available, affordable and properly used. years, by running two parallel tracks, one WHO is working with it’s Member States dedicated to vaccines and selected other to use only biological medicines of biological medicines; one dedicated to assured quality in national health sys- blood products and related in vitro diag- tems. nostic devices. 12
  • 14. WHO Drug Information Vol 23, No. 1, 2009 Biomedicines Update The most important outcomes of the 2008 Yellow fever vaccine ECBS meeting were: An amendment to the written standard for yellow fever vaccine was also estab- Snake antivenom immunoglobulins lished. This requires that the expression A new written standard for production, of potency of such vaccines be in Interna- control and regulation of snake antivenom tional Units (IU) per dose. The dose immunoglobulins was established. Snake recommended for use in humans shall antivenom immunoglobulins (antivenoms) not be less than 3.0 log10 IU. This new are the only therapeutic products for the expression of potency should be ap- treatment of envenomings due to snake- proved by National Control Authorities, bite. The lack of availability of effective and will also be used as the standard for snake antivenom immunoglobulins to WHO prequalification of yellow fever treat specific types of envenomings vaccines. encountered in various regions of the world has become a critical health issue Abbreviated licensing pathways for at global level. The crisis has reached its certain biological therapeutic products greatest intensity in sub-Saharan Africa, The Expert Committee also discussed a but other regions, such as South-east proposal to establish abbreviated licens- Asia, are also suffering from a lack of ing pathways for certain biological thera- effective and affordable products. peutic products. Control of chronic diseases is a major challenge for public The complexity of the production of health systems in WHO Member States. efficient antivenoms, in particular the Innovative biological medicines devel- importance of preparing appropriate oped by modern molecular biological snake venom mixtures for the production approaches have been successful in of hyperimmune plasma (source of treating many life-threatening diseases antivenom immunoglobulins), the de- and the market for these products is creasing number of producers and the rapidly growing. fragility of the production systems in developing countries further jeopardize However, such innovative biological the availability of efficient antivenoms in medicines are expensive. This has limited Africa, Asia, the Middle East, and South their use, particularly in developing America. Also, most of the remaining countries. The expiration of patents on producers are located in countries where key biological drugs such as recombinant the application of quality and safety insulin, human growth hormone and standards needs to be improved. erythropoietin is opening the door for copies of these drugs to be made by The new Guidelines cover all the steps developing country manufacturers. This involved in the production, control and may contribute to a substantial increase regulation of venoms and antivenoms. It in their availability at an affordable price. is hoped that this document, by covering comprehensively current existing experi- Generic versions of expired-patent ence in manufacture, control, and pre- chemical drugs are well known. However, clinical and clinical assessment of these copy biological medicines are far more products will serve as a guide to national complicated products for which the control authorities and manufacturers to current generic regulatory pathway is support worldwide production of these unsuitable. Nevertheless it is essential to essential medicines. ensure that there is appropriate regula- tory oversight in place. Regulatory over- 13
  • 15. Biomedicines Update WHO Drug Information Vol 23, No. 1, 2009 Proposals to establish new or replacement International Standards or WHO reference reagents: October 2008 Name of preparation Proposed status VACCINES AND RELATED SUBSTANCES Influenza H5N1 antibody (human) lst International Standard Human papillomavirus type 16 DNA lst International Standard Human papillomavirus type 18 DNA lst International Standard Rabies vaccine 6th International Standard Acellular Pertussis vaccine Modified Kendrick Test lst International Standard Pertussis antiserum (human) lst International Standard Pertussis antiserum (human) WHO Reference Reagent BLOOD PRODUCTS AND RELATED SUBSTANCES Anti-hepatitis B immunoglobulin 2nd International Standard Blood coagulation factor IX, concentrate 4th International Standard Factor VIIa concentrate 2nd International Standard Parvovirus B19 DNA 2nd International Standard Anti-A and anti-B antibodies, human WHO Reference Reagents Anti-hepatitis C core antigen (HBcAg), antibodies, human lst International Standard Extended use for the International Standard for alpha-1-antitrypsin (05/162) 1st International Standard DIAGNOSTIC REAGENTS AND RELATED SUBSTANCES Haemophilia A intron 22 inversion for molecular genetic diagnosis lst reference panel Fragile X syndrome for molecular genetic diagnosis lst reference panel CYTOKINES, GROWTH FACTORS AND ENDOCRINOLOGICAL SUBSTANCES Insulin-like growth factor (IGF-1) 2nd International Standard .../Continued 14
  • 16. WHO Drug Information Vol 23, No. 1, 2009 Biomedicines Update Proposals to establish new or replacement International Standards or WHO reference reagents: October 2008 (Continued) Name of preparation Proposed status ANTIBIOTICS Gramicidin 2nd International Standard ITEMS PROPOSED IN MARCH 2008 BUT SUBSEQUENTLY WITHDRAWN Human papillomavirus type 16 antibody (human) 1st Reference Reagent to 1st International Standard Thromboplastin, human, plain International Standard Soluble serum transferrin receptor (STFR), recombinant lst International Standard Vancomycin 2nd International Standard Parathyroid hormone 1-84, human recombinant lst International Standard Poliovirus type 1 (Sabin) for MAPREC lst International Standard sight should not be so lax that ineffective Global reference preparations or dangerous products are allowed into A total of 18 new or replacement global the market place or so restrictive that safe reference preparations were established. and effective products face regulations These are the primary calibrant against that are too stringent. which regional or national measurement standards are benchmarked. An updated The ECBS affirmed that reduced data list is available at http://www.who.int/ packages may be suitable to provide biologicals/en/. sufficient assurance about the quality, safety and efficacy of certain products, References but it recommended that WHO and 1. World Health Organization. Biologicals: countries move forward cautiously. Based http://www.who.int/biologicals/en/ on the outcome of discussions and following consideration by the Committee, 2. World Health Organization. Blood products the ECBS therefore recommended that and related biologicals: http://www.who.int/ the current document be strengthened bloodproducts/en/index.html and some issues further clarified. A revised version should be re-submitted to 3. World Health Organization. Immunization, the Committee in 2009. Vaccines and Biologicals: http://www.who.int/ immunization/en/ 15
  • 17. WHO Drug Information Vol 23, No. 1, 2009 Safety of Medicines The mobile laboratory: crack down on the manufacturing and marketing of counterfeit pharmaceutical a new concept in products, the Chinese Government has medicines surveillance implemented a number of drug surveil- lance programs. In China, fake and According to the World Health Organiza- substandard drugs mainly appear at the tion (WHO), about 6 to 10% of medicines retail level in the supply chain, and worldwide are counterfeit; a market worth therefore these programmes generally 32 billion US dollars in annual sales. The require samples to be collected from the phenomenon has grown in recent years market and analysed in quality control due to methods of counterfeiting becom- laboratories at the provincial or district ing more sophisticated and to an increase level. in the quantity of counterfeit drugs cross- ing borders. Trade in fake medicines Common methods used on-site by local mainly occurs in developing countries, but authorities include basic tests, such as counterfeiting is now also increasingly appearance, colour and weight, identifica- becoming a problem in developed coun- tion by thin-layer chromatography (TLC), tries. and basic functional group tests using wet chemical analysis techniques. Samples In response to the challenge presented suspected of being counterfeit are then by the public health crisis caused by a sent to quality control laboratories at the global increase in counterfeit drugs, WHO district level for analysis using more has launched a special taskforce, the specific methods such as high perform- International Medical Products Anti- ance liquid chromatography (HPLC). Counterfeiting Taskforce (IMPACT). The Such programmes have their merits, but main purpose of IMPACT is to build a are not very effective in detecting the coordinated network across and between more sophisticated high technology countries in order to halt the production, counterfeit products. trading and sale of fake medicines around the world. IMPACT is a partnership To reinforce surveillance, medicines are comprising all the major anti-counterfeit- also routinely sampled from the market ing players, including international organi- and sent to district laboratories for testing, zations, nongovernmental organizations, but this can be costly. Moreover, counter- enforcement agencies, pharmaceutical feit drugs are often deliberately made to manufacturers associations and drug pass tests defined in the Chinese Phar- regulatory authorities. macopoeia to avoid being caught by the Chinese State Food and Drug Administra- As elsewhere in the world, fake and tion (SFDA) surveillance programme. substandard drugs in China are driven by There is therefore a demand to improve huge profits, and have consequently on-site analysis so that more sophisti- become quite sophisticated. In order to cated counterfeits can be reliably de- tected, and resources at the district level Article prepared by Professor Shaohong Jin, can be better utilized. Reliable on-site National Institute for the Control of Pharma- analysis will also allow resources to be ceutical and Biological Products, China. efficiently targeted at those cases where 16
  • 18. WHO Drug Information Vol 23, No. 1, 2009 Safety of Medicines Mobile laboratories in China law enforcement already has evidence • To provide a platform for the deployment that counterfeit products are being of modern high-technology analytical distributed. methods that would both aid in the crackdown on the sale and distribution Objectives and development of the of counterfeit drug products, and pro- mobile laboratories vide reliable evidence for law enforce- In January 2003, in response to a call ment. from the SFDA for drug monitoring in predominantly rural areas, the Chinese • To reduce the high cost and increase National Institute for the Control of the efficiency of routine drug quality Pharmaceutical and Biological Products post-marketing surveillance. (NICPBP) proposed that mobile laborato- ries be used for quality testing. The On 30 November 2003, less than 10 laboratories are specially designed vans months after the initial proposal from equipped to perform various quick analy- NICPBP, the first mobile laboratory for ses. The primary objectives of the mobile drug quality testing was unveiled. On laboratories are: 5 January 2004, the former Vice Premier of China inspected the mobile laboratory • To utilize the mobility of the laboratories and watched a live demonstration of a to extend drug surveillance into China’s high technology screening method. The remote countryside. Vice Premier was very impressed with the new technology and the concept of such • To increase consumer confidence in the a mobile laboratory and requested that quality of pharmaceutical products the Ministry of Finance, the State Com- available on the Chinese market. mittee of Reform and Development and the National Bureau of Quality and • To provide quick, easy-to-use, and Standards provide the programme with effective screening methods for on-site full support and assistance. drug testing. 17
  • 19. Safety of Medicines WHO Drug Information Vol 23, No. 1, 2009 Operating the mobile laboratory modern analytical instruments that can Currently, the only internationally avail- quickly and non-destructively analyse able system for quick screening of coun- drug products. The mobile laboratories terfeits on-site is the Minilab test kit, provide an effective screening tool for the which is capable of testing less than 50 crackdown on counterfeit drugs. common products, such as antibiotics or antimalarials, but the Minilab test kit is not Reliability of the NIR method sufficient to address the problem of for drug screening counterfeits in China. The scientific During 2006 and 2007, mobile laborato- equipment in the mobile laboratory ries tested a total of 10 340 batches of includes a near-infrared spectrometer, pharmaceutical products, of which 329 TLC, colorimetry, digital photography, batches were known to be fake. Of the visible microscopy, and test kits for 10 340 batches tested, 1087 (about specific chemical reactions. The main 10.5%) failed the NIR screening, includ- screening tool is based on a near-infrared ing all 329 batches that were known to be spectrometer and a pre-developed fake. In addition to the fake products, standard analytical method that uses a some non-counterfeit products failed to library of near-infrared (NIR) spectra pass the NIR screening because of (developed by the NICPBP) of all the changes in product formulations. All registered pharmaceutical products in products that failed the NIR screening China. This near-infrared based system is were sent to district laboratories for quick, accurate, non-destructive, and further testing using more specific meth- versatile. ods. These results show that NIR screen- ing is a very reliable method for the Apart from analytical instrumentation, detection of counterfeit drugs, and also another important tool in the mobile dramatically decreases the number of laboratory is the information system, products that need to be tested in district which includes manufacturer information laboratories. for officially registered products, including the registration numbers, formulations, Results of using mobile laboratories dosages and labelling, etc. as well as a for drug testing list of known counterfeits. Dedicated From April 2004 to November 2005, field software for the mobile laboratory allows tests of the mobile laboratories were easy access to the information, even in carried out in 5 provinces in China: Anhui, remote areas. The software is also used Hubei, Hunan, Sichuan and Yunnan. to support the near-infrared instruments Suitability, accuracy and efficiency of the by providing automatic analysis of the analytical equipment was evaluated near-infrared spectrum using pre-loaded under real conditions. The evaluation analysis methods, and generation and included the effect of vibration on the logging of all test reports. equipment when the van was driven on rough roads in the countryside. Field tests In addition, the software includes a were used to look for possible areas for database of analytical methods, digital improvement. manuals, and predefined standard forms to record and manage mobile laboratory As an example of these trials, starting in activities such as when and where the August 2004, a mobile laboratory was mobile laboratories have been dis- dispatched 165 times in Zhumadian patched. The mobile laboratory thus Prefecture of Henan Province. The combines modern information technology, mobile laboratory visited 8 of 11 counties scientific management systems, and in the prefecture as well as 42 of 186 18
  • 20. WHO Drug Information Vol 23, No. 1, 2009 Safety of Medicines villages, and covered a total distance of also result in significant cost-savings. 17 000 km, including highways between Currently, the mobile laboratory pro- cities and rough roads in the countryside. gramme covers about 80% of essential medicine products commonly used in The mobile laboratory examined a total of rural areas. 260 pharmacies and clinics and screened 3965 batches of 408 different drug The mobile laboratory programme has products. Of these, 57 batches were also shown its utility in response to suspected to be fake and were further emergencies caused by fake drugs. As an tested by analytical methods in district example, in the summer of 2006, instead laboratories resulting in five batches that of propylene glycol, the toxic ingredient were confirmed as counterfeit. The diethylene glycol was used by mistake in mobile laboratories also visited AIDS a few batches of Armillarisin A® for prevention stations in Zhumadian Prefec- injection, resulting in 11 deaths. Immedi- ture, clinics in all 24 villages with a high ately after the incidents were reported, population of AIDS patients, and in all the mobile laboratories were dispatched nine villages with a moderate population to screen all suspected products that of AIDS patients. No fake or substandard were still on the market. Gas chromatog- drugs were found in the 1347 batches raphy (GC) was later used to verify the that were tested. The extensive surveil- results for medicines screened positive lance that is possible with mobile labora- for diethylene glycol by the mobile labora- tories thus ensures the quality and safety tories. In this case, the NIR-based quick of drug products used by at-risk groups screening method demonstrated 100% such as AIDS patients. accuracy. To date, 379 mobile laboratories have Future development of the mobile been deployed across China. They have laboratory programme visited over 77 000 drug dispensaries, A second generation of mobile laborato- and have travelled over 2 000 000 km. ries is currently under development which They have screened more than 379 000 incorporate a patented green HPLC batches of drugs, of which approximately system that is suitable for mobile opera- 37 000 were suspected of being fake or tion. The key to this new HPLC is that the substandard. Of these, approximately solvents are close-loop recycled inside 14 000 batches were later confirmed to the van. The advantage of implementing be counterfeit. The average analysis cost the HPLC system in the mobile laboratory per batch in the district laboratory is about is that if a drug product tests positive 600 RMB. If the traditional test pro- using the NIR-based prescreening gramme were used for the 379 000 method, then an on-site verification can batches, they would have cost almost be performed immediately. 230 million RMB. The new, targeted analysis of only those batches that were Incorporating the HPLC technology suspect based on pre-screening results should further improve the accuracy and reduced the cost of analysis in the district efficiency of the mobile laboratory pro- laboratories by about 90%, to approxi- gramme, especially in remote areas mately 22 million RMB. where the local Food and Drug Adminis- tration or other analytical laboratories are These data show that the mobile labora- far away. A combination of the NIR-based tories not only increase the successful quick and non-destructive screening sampling rate and improve the efficiency method and on-site verification capability of the drug surveillance programme, but using the new HPLC technology may also 19
  • 21. Safety of Medicines WHO Drug Information Vol 23, No. 1, 2009 play an important role in counterfeit drug surveillance programme and reduced detection in many developing countries. costs. They have also expanded the monitoring area of the programme and Conclusions have improved the ability of the authori- The mobile laboratory is a new monitoring ties to rapidly respond when there is system that provides in-time information evidence of adverse reactions to drug gathering, quick screening, targeted products on the market. In the future, sampling based on drug law-enforcement mobile laboratories will continue to play efforts, and accurate analytical tests. an important role in increasing the effi- These mobile laboratories have demon- ciency of government efforts to crack strated considerable success in ensuring down on the manufacture and marketing medicines safety. The laboratories have of counterfeit products in China. increased the efficiency of the drug 20
  • 22. WHO Drug Information Vol 23, No. 1, 2009 Pharmacovigilance Focus Monitoring the safety of safety of medicines when used off-label. off-label medicine use First and foremost, monitoring the safety of medicines in off-label settings is Medicine labels contain important infor- necessary to gain information on the mation on the conditions of use. These usage of medicines in these settings. conditions typically include the indication, While formal study of medication safety dosage, frequency of administration, and would be optimal in these settings, such route of administration. Other important studies are often not available. Thus, conditions of use can include the age safety monitoring plays a critical role. range of patients, duration of treatment, Data derived from monitoring safety in an and contraindications to use of the off-label setting can also potentially be medicine. Deviations from the conditions relevant to the safety of the medicine of use set forth in the label constitute off- when used according to the label. In label use. addition, data derived in the off-label setting may serve as a stimulus for more In the USA, off-label use is legal. While formal study. the Food and Drug Administration (FDA) regulates the marketing of medicines, it There are many specific concerns that does not regulate prescribing practices. In need to be addressed when monitoring one study (1), approximately 21 per cent the safety of medicines in an off-label of drug use in office-based practice was setting. Many factors that could affect the for off-label use. Off-label use may occur safety of the medicine could be different for a variety of reasons. For example, in the off-label compared to the on-label there are some diseases for which no setting. These factors include the age of adequate, labelled treatment exists. In patients, range of co-morbidities, use of these situations, prescribers use medi- concomitant medication, drug-disease cines for off-label indications. In the case interactions and differences in pharma- of medicines for children, many drugs cokinetics and pharmacodynamics. have never been studied in children, so there has been extensive off-label use in Despite the importance of monitoring the children, although there are ongoing safety of medicines in an off-label setting, efforts to correct this situation. In some there are many challenges that this cases, there may be a reasonable body situation presents. First, spontaneous of published evidence to support off-label reports do not always contain the indica- use. In other cases, such use is specula- tion for use or other details that would tive. However, off-label use may become allow one to determine that the medicine part of accepted practice, and may be was used in a manner not consistent with part of professional society guidelines. the product’s label. Second, the identifica- tion of an adverse drug reaction in the off- Because off-label use is common, there is label setting does not necessarily mean a public health imperative to monitor the that this reaction is limited to that setting. Article prepared by Gerald J. Dal Pan, MD, MHS, Food and Drug Administration, USA. (Views expressed are those of the author, and not necessarily those of the US Food and Drug Adminis- tration.) 21
  • 23. Pharmacovigilance Focus WHO Drug Information Vol 23, No. 1, 2009 Despite these limitations, spontaneous used by persons without epilepsy, and reports can be useful in determining that these persons experienced seizures adverse drug reactions when medicines after tiagabine was started. The product’s are used off-label. label was updated to include this informa- tion. Drug utilization databases may be helpful in monitoring off-label use of medicines. In summary, the off-label use of medi- Though such databases do not typically cines is common. Monitoring of adverse contain information on indications for use, events in this setting is important, though they can be helpful in identifying other there are many challenges in doing so. aspects of off-label use. For example, Reference: Radley et al. Arch Intern Med drug utilization data may shed light on the 2006; 166:1021-1026. age range of patients using a medicine, the duration of therapy, concomitant medication used, and dosages pre- Drotrecogin alfa: what scribed. Review of such data may indi- relation to thrombosis? cate that there is substantial off-label use and this may provide valuable information Drotrecogin alfa (activated) is a recom- for safety monitoring purposes. binant form of human activated protein C that has antithrombotic, anti-inflammatory Drug use databases typically do not have and profibrinolytic activities. It is used any information on medical diagnoses, so mainly in intensive care as a treatment for they are not suitable for identifying severe sepsis (sepsis associated with adverse events. Nonetheless, they can acute organ dysfunction). It is adminis- be useful for identifying trends that may tered in multiple slow infusions, as a rule, require further study. Administrative at a dose of 24 µg/kg/hour for four days healthcare databases that contain infor- (1). mation both on drug use data and medi- Sepsis is a complex illness involving both cal diagnoses can also be useful for infection and inflammation when the identifying trends in off-label use, though body’s response is systemic, instead of medical record review may be necessary being localized to the site of infection. to determine the indication for usage. This “overreaction” to the infection may Electronic medical records may be more result in organ damage and is more useful than administrative healthcare dangerous than the initial infection itself databases if indication for use is linked to (2). the drug prescribed. Finally, published clinical trials studying off-label use may Patients who die during episodes of be a valuable source of information on sepsis are more likely to have coagulation adverse drug reactions. However, the defects, including lower levels of circulat- limitations of clinical trials for ascertaining ing antithrombin III and protein C. The adverse event information are well latter is a vitamin K-dependent anticoagu- known. lant protease. In sepsis, protein C defi- ciency appears before the onset of One example of the importance of moni- observable indicators of septic shock. toring for adverse events in the off-label setting is seen with the drug tiagabine, The administration of an exogenous whose labelled indication in the USA is for analogue may modulate the patient’s adjunctive therapy in adults and children over 12 years of age in the treatment of Article prepared by Tamás Paál, Hungary. partial seizures. Post-marketing reports (Signal Reviewer for the WHO Programme for indicated that this medicine was being International Drug Monitoring.) 22
  • 24. WHO Drug Information Vol 23, No. 1, 2009 Pharmacovigilance Focus response during sepsis (1, 3). The only day of drotrecogin treatment were deep serious adverse reaction observed in venous thrombophlebitis and thrombosis. clinical trials to drotrecogin alfa was bleeding (3, 4). 5. A pharmacist described a 45-year-old female who was administered drotrecogin Description of new ADR reports alfa for four days. Concomitant medica- Thirteen non-duplicate reports of throm- tion comprised dopamine and norepine- botic events in septic patients treated with phrine. Adverse effects described were drotrecogin alfa were reported to intestinal ischaemia, decreased pro- VigiBase, the database of the WHO thrombin level and thrombosis. Collaborating Centre for International Drug Monitoring, in the period 2002 to 6. A pharmacist described a 72-year-old 2007. There were 12 reports from the male treated with drotrecogin alfa for four USA and one from the United Kingdom. days. Concomitant medication comprised The reports are summarized below. sodium bicarbonate, pantoprazole, norepinephrine, vasopressin, paraceta- 1. A General Practitioner (GP) described mol, dopamine, amiodarone, vancomycin a 66-year-old male who developed and piperacillin-tazobactam combination. thrombosis after administration of Adverse reactions described were anae- drotrecogin alfa. No details were re- mia, discoloured faeces and thrombosis. ported. 7. A 68-year-old male was administered 2. A 72-year-old male was treated with drotrecogin alfa for five days. Concomi- drotrecogin alfa for three days. On the tant medication comprised cefotaxime, second day of treatment, pulmonary clarithromycin, amiodarone for two days, haemorrhage and thrombosis were hydrocortisone for eight days and observed. lorazepam for two days. One day after termination of drotrecogin treatment the 3. A 34-year-old male was treated with patient developed thrombosis. drotrecogin alfa for six days in 2002. Concomitant medication comprised 8. A pharmacist described an 86-year-old antibiotics as well as paracetamol and male who was treated with drotrecogin hydrocodone bitartrate. The report, sent alfa for two days. No concomitant medi- by a GP, specified thrombosis, multiple cation was reported. Life-threatening organ failure and gangrene as adverse adverse reactions comprised hypoten- effects. Onset appeared eight days after sion, gastrointestinal haemorrhage and termination of treatment. thrombosis. Positive dechallenge was also observed. 4. A 66-year-old male was treated with drotrecogin alfa for three days. Concomi- 9. A physician reported the case of a tant medication comprised paracetamol, female treated with drotrecogin alfa who codeine, atenolol, lorazepam, triamci- developed thrombosis. No details were nolone, propofol, dopamine, levofloxacin, disclosed. morphine, famotidine, salbutamol, meto- 10. A pharmacist described a 63-year-old clopramide, diazepam, midazolam, female treated with drotrecogin alfa for thiamine, piperacillin-tazobactam three days. Concomitant medication combination and heparin. The dosage comprised ranitidine, azithromycin, and other treatment data were missing. ceftriaxone, dopamine and norepine- Adverse reactions observed on the last phrine. Adverse reactions reported were 23
  • 25. Pharmacovigilance Focus WHO Drug Information Vol 23, No. 1, 2009 increased blood chloride and urea, associated with bleeding, related to its hypernatraemia, hypokalaemia, antithrombotic and profibrinolytic proper- hyperglycaemia, peripheral oedema, ties (1). In a Phase III placebo controlled thrombocythaemia and thrombosis. clinical trial, the incidence of thrombotic Dechallenge appeared to be negative. No events was similar in the drotrecogin and further information was provided. placebo arms (4). This was confirmed by analysis of results from combined clinical 11. A physician described a 70-year-old trials. When compared with placebo, female treated with drotrecogin alfa for patients in the active treatment arms two days. Reported adverse effects were experienced numerically fewer thrombotic rash, jaundice, rectal disorders, bacterial events, although the difference was not infection, peritonitis and thrombosis. statistically significant (7). 12. A health professional reported the Thrombosis frequently occurs in patients case of a 29-year-old female treated with with severe sepsis (7). Disseminated drotrecogin alfa for two days. Concomi- intravascular coagulation (DIC) may tant medication comprised norepine- develop in 30-50% of patients with severe phrine and dobutamine. Adverse reac- sepsis and septic shock, especially when tions were haemorrhage and thrombosis. caused by Gram negative bacteria. The mortality of sepsis is correlated with the 13. A physician reported a 30-year-old development and severity of DIC (8). female who was administered drotrecogin Protein C serves as an important antico- alfa (no other information was available). agulant compensatory mechanism. The The adverse reaction was thrombosis. cytokines produced in sepsis incapacitate the protein C pathway. One of the critical Evaluation of reports mediators of DIC is the release of a Six of the thirteen reports do not mention transmembrane glycoprotein tissue factor. concomitant medication. Because of the This is released in response to exposure clinical situation in which drotrecogin is to cytokines or endotoxin and plays a used, it is almost certain that other major role in the development of DIC in medicines were co-administered. Thus, it septic conditions. For this reason, is possible that some concomitantly used drotrecogin alfa is recommended in the but undisclosed medicine might have therapy of DIC (8, 9). Additionally, a contributed to the adverse effect. retrospective subgroup analysis of a clinical trial demonstrated a lower mortal- Seven reports (3, 4, 5, 6, 7, 10 and 12) ity rate among patients treated with describe a range of concomitant medica- drotrecogin alfa who met the criteria for tions. According to European Union DIC (10). Summaries of Product Characteristics (SPCs) as well as an international data- Hence, the conclusion is that in these base (5) of these medicines, only propofol spontaneous reports a manifestation of (administered in a single case) has the the underlying disease was reported as a recognized, although very rare, adverse possible adverse drug reaction. This effect of thrombophlebitis (6). hypothesis is further supported by the following. Signal assessment On the basis of pharmacological proper- • Clinical manifestation of DIC is ex- ties of drotrecogin alfa, administration is tremely variable (9). The pathological unlikely to lead to thrombosis. On the processes involved deplete the body of contrary, drotrecogin use is frequently its platelets and coagulation factors and 24
  • 26. WHO Drug Information Vol 23, No. 1, 2009 Pharmacovigilance Focus so, paradoxically, may lead to both 2. Sepsis.com – understanding sepsis and thrombus formation and haemorrhage. severe sepsis. www.sepsis.com/family_ friends/ understanding.jsp?reqNavId=5.2, • Septic patients are generally treated in downloaded 03.01.2008. intensive care units but the adverse 3. Cada DJ, Levien T. Drotrecogin Alfa. effect reporters (if disclosed) were Hospital Pharmacy 2002;37(5):511–517. mostly GPs, pharmacists and other health professionals, possibly not 4. Bernard GR, Vincent Jl, Laterre PF. Efficacy possessing detailed information. and safety of recombinant human activated protein C for severe sepsis. New England • On consulting the WHO database, it can Journal of Medicine 2001;344:699–709. be seen that other reports on drotre- cogin alfa between 2002 and 2007 5. 1974-–2207 Thomson MICROMEDEX specified various haemorrhages (the Database. well-known adverse effects of dro- 6. Propofol. Merck Manual. www.merck.com/ trecogin alfa), as well as 43 reports of mmpe/lexicomp/propofol,htm, downloaded 08. DIC itself. 08.2008. Conclusion 7. GR Bernard et al. Extended evaluation of In 13 reports of thrombosis associated Recombinant Human Activated Protein C with the use of drotrecogin alfa, retrieved United States Trial (ENHANCE US). Chest from VigiBase, it appears likely that the 2004;125:2206-2216. reported thrombotic events represent a manifestation of the underlying disease 8. Becker JU, Wira CR. Disseminated Intra- vascular Coagulation. www.emedicine.com/ process (severe sepsis), rather than an emerg/topic150.htm, downloaded 07.08.2008. adverse reaction to any administered medicine. This analysis underlines the 9. Aysola A , Lopez-Plaza I. Disseminated importance of considered assessment of Intravascular Coagulation. www.itxm.org/ all reported adverse drug reactions data. TMU1998/tmu3-99.htm, downloaded 07.08.2008. References 10. Dhainaut JF et al. Treatment effects of 1. Goshman L. Drotrecogin Alfa, Activated. drotrecogin alfa (activated) in patients with Journal of the Pharmacy Society of Wisconsin severe sepsis with or without disseminated Mar/Apr 2002;3335. intravascular coagulation. Journal of Thrombo- sis and Haemostasis 2004;2(11):1924–1933. 25
  • 27. WHO Drug Information Vol 23, No. 1, 2009 Safety and Efficacy Issues Genetic basis of Anaesthetic infusion with pain adverse drug events pumps: articular chondrolysis United States of America — The first Canada — Postoperative pain pumps are data offering health care professionals a infusion devices designed to continuously better look into the genetic basis of deliver controlled amounts of medication certain types of adverse drug events has (1, 2). They can be used to infuse local been released by the Food and Drug anaesthetic solutions directly into opera- Administration (FDA) and the Interna- tive sites for pain management following tional Serious Adverse Event Consortium surgical procedures. The device consists (SAEC). Data are focused on the genet- of a reservoir containing the local anaes- ics associated with drug-induced serious thetic solution which is delivered by skin rashes, such as Stevens-Johnson gravity or by electric pump through a syndrome and toxic epidermal necrolysis, catheter implanted directly into the and help better predict an individual’s risk surgical wound. Bupivacaine is an anaes- of developing these reactions. thetic commonly used with postoperative pain pumps (3). A combination of Both skin conditions appear as allergic- bupivacaine and epinephrine is also like skin reactions associated with blister- used, with the epinephrine inducing ing and peeling, and are considered life- vasoconstriction and slowing down the threatening. Medications causing these absorption of bupivacaine. serious allergic reactions should be As of July 2008, Health Canada has discontinued. If such signs and symptoms received 8 incident reports of articular are not quickly recognized, these reac- chondrolysis following shoulder surgery tions can be fatal. that were suspected of being associated with the use of postoperative pain pumps. The SAEC is a non-profit partnership of The pain pumps were used for about 48 pharmaceutical companies, the Wellcome hours after surgery. All of the patients Trust, and academic institutions focused received bupivacaine with epinephrine. on research relating to the genetics of Chondrolysis was diagnosed between drug-induced serious adverse events. one month and one year after surgery and use of the pain pumps. Researchers who enter into a data use agreement can obtain free access to the Chondrolysis is a progressive degenera- data to generate custom data inquiries tion of the cartilage for which the cause is and obtain immediate results on the not fully understood (4, 5). Chondrolysis genetic basis of adverse drug events. of the shoulder results in narrowing of the joint space, leading to pain and loss of References motion; it is a debilitating condition that requires medical attention and possibly 1. FDA News, 10 February 2009. www.fda.gov surgery (3, 4). Chondrolysis is listed 2. International Serious Adverse Event among the possible adverse incidents in Consortium at http://www.saeconsortium.org the device labelling of pain pumps (1, 2). The device labelling states that the 26
  • 28. WHO Drug Information Vol 23, No. 1, 2009 Safety and Efficacy Issues continuous intra-articular infusion of 7. van Huyssteen AL, Bracey DJ. Chlorhexi- anaesthetics, particularly when epine- dine and chondrolysis in the knee. J Bone phrine is also used, is not recommended. Joint Surg Br 1999;81(6):995–6. The association between postoperative 8. Leclair A, Gangi A, Lacaze F, et al. Rapid pain pumps and the development of chondrolysis after an intra-articular leak of bone cement in treatment of a benign aceta- chondrolysis is difficult to identify. Indeed, bular subchondral cyst: an unusual complica- chondrolysis may appear many months tion of percutaneous injection of acrylic after the use of a pain pump (3–5). In cement. Skeletal Radiol 2000;29(5): 275–8. addition, confounders such as the con- comitant use of health products (e.g., 9. Jerosch J, Aldawoudy AM. Chondrolysis of gentian violet, chlorhexidine, bone ce- the glenohumeral joint following arthroscopic ment) and radiofrequency devices may capsular release for adhesive capsulitis: a be responsible for causing chondrolysis case report. Knee Surg Sports Traumatol after shoulder surgery (5–10). Arthrosc 2007;15(3):292–4. 10. Ciccone WJ II, Weinstein DM, Elias JJ. Health care professionals are encouraged Glenohumeral chondrolysis following thermal to follow the instructions for use and capsulorrhaphy. Orthopedics 2007;30(2):158– refrain from using postoperative pain 60. pumps for continuous intra-articular infusion of local anaesthetics, particularly with epinephrine, after shoulder surgery Atomoxetine: serious (1, 2). liver injury Extracted from the Canadian Adverse United States of America — The Food Reactions Newsletter, Volume 19 , and Drug Administration (FDA) continues Number 1 (2009). to receive reports of serious liver injury in patients given atomoxetine. Atomoxetine References received FDA approval on 26 November 2002 as the first non-stimulant medication 1. On-Q PainBuster [Canadian instructions for used for the treatment of attention deficit use]. Lake Forest (CA): I-Flow Corporation; hyperactivity disorder (ADHD) in children 2008. (aged 6 years and above) and adults (1). 2. Donjoy Pain Control Device [Canadian instructions for use]. Huntington Beach (CA): Atomoxetine’s therapeutic action is Curlin Medical Inc; 2007. believed to be due to its selective inhibi- 3. Hansen BP, Beck CL, Beck EP, et al. tion of norepinephrine reuptake. From the Postarthroscopic glenohumeral chondrolysis. year 2002 to 2007, approximately 3.3 Am J Sports Med 2007;35(10):1628–34. million patients received a prescription for atomoxetine in the United States. Of 4. Yarbrough R, Gross R. Chondrolysis: an those, approximately 2.1 million patients update. J Pediatr Orthop 2005;25(5):702–4. (64%) were children aged 17 years and 5. Petty DH, Jazrawi LM, Estrada LS, et al. younger (2). Glenohumeral chondrolysis after shoulder arthroscopy: case reports and review of the While a signal for serious liver injury was literature. Am J Sports Med 2004;32(2):509– not detected during premarket clinical 15. trials of atomoxetine, two published post- 6. Shibata Y, Midorikawa K, Koga T, et al. marketing reports did identify instances of Chondrolysis of the glenohumeral joint atomoxetine-induced hepatitis (3, 4). In following a color test using gentian violet. one of these reports, there was a positive Int Orthop 2001;25(6):401–3. rechallenge with atomoxetine. Subse- 27
  • 29. Safety and Efficacy Issues WHO Drug Information Vol 23, No. 1, 2009 quent to these reports, a bolded warning 2. Bangs ME, Ling J, Zhang S, et al. Hepatic was added in 2004 to the atomoxetine events associated with atomoxetine treatment label indicating an increased risk for for attention deficit hyperactivity disorder. Drug severe liver injury. Safety. 2008;31(4): 345–54. 3. Stojanovski SD, Casavant MJ, Hayat MM, Since the 2004 labelling change, FDA et al. Atomoxetine-induced hepatitis in a child. has received six additional reports of Clin Toxicol (Phila). 2007;45 (1):51–5. serious liver injury in patients taking atomoxetine. Following an evaluation of 4. Lim JR, Faught PR, Chalasani NP. Severe the information from the drug sponsor liver injury after initiating therapy with atomox- and additional literature articles submitted etine in two children. J Pediatr. 2006;148(6): to FDA, the atomoxetine product label 831–4. was again revised in 2007. The warnings and precautions section of the drug label Drotrecogin alfa: advises prescribers about the risk for ongoing safety review severe liver injury with this drug (1). United States of America — The Food Post-marketing reports indicate that and Drug Administration (FDA) is aware atomoxetine is associated with serious of a retrospective study (1) which has idiosyncratic liver injury. Some of the reported an increased risk of serious cases reported additional confounding bleeding events and death in patients factors, such as occasional acetami- with sepsis (a severe illness related to a nophen use. Some of the cases lacked bloodstream infection) and baseline sufficient clinical detail to convincingly bleeding risk factors who received detail the relationship between the use of drotrecogin alfa. Drotrecogin alfa (acti- atomoxetine and liver injury. The mecha- vated) (Xigris®) is a recombinant human nism of atomoxetine-induced liver injury activated protein C indicated for the remains unknown. reduction of mortality in adult patients with severe sepsis who have a high risk FDA encourages physicians to: of death (2). The baseline bleeding risk factors as defined by this study are the • Inform patients to immediately contact their physician at the first sign or symp- same as those described in the drotre- tom of fatigue, loss of appetite, nausea, cogin alfa prescribing information. vomiting, pruritus, dark urine, jaundice of the sclerae or skin, right upper An editorial (3) accompanying the article quadrant tenderness, or unexplained stated that one approach to increasing the safety of drotrecogin alfa would be to “flu–like” symptoms. not administer it to any patients with • Determine liver enzyme levels when a sepsis and baseline bleeding risk factors, patient presents with signs or symptoms effectively changing a warning in the of liver injury. product labelling to a contraindication. Under FDA regulations, contraindications • Discontinue and not resume atomoxet- in the prescribing information describe ine treatment if patients present with situations where the risks are known (that jaundice or laboratory evidence of liver is, are not theoretical) and where the risks injury of use clearly outweigh any possible benefit. References 1. Atomoxetine (Strattera®) product labelling. The study was a retrospective medical http://www.fda.gov/cder/foi/label/2008/ record review of 73 patients who received 021411s024s025s026lbl.pdf drotrecogin alfa. Serious bleeding events 28
  • 30. WHO Drug Information Vol 23, No. 1, 2009 Safety and Efficacy Issues occurred in 7 of 20 patients (35%) who Clopidogrel is an antiplatelet drug that is had a bleeding risk factor vs only 2 of 53 used to prevent blood clots that could (3.8%) patients without any bleeding risk lead to heart attacks or strokes in patients factors. More patients with baseline at risk for these problems. The drug bleeding risk factors died (13/20; 65%) clopidogrel is a “pro-drug” which means compared to patients without any bleed- that it has to be metabolized by the body ing risk factors (13/53; 24.5%). The before it can be biologically active and authors acknowledge that there are have the effect of preventing blood clots. limitations to this study, such as its Understanding that there are differences retrospective design and the small size of in how the body metabolizes clopidogrel the patient population, that limit the ability and there are effects that other drugs to draw definitive conclusions from the may have on its metabolism is important data. because decreases in the effectiveness of clopidogrel might be avoided, in part, References by using other drugs with clopidogrel that do not interfere with its metabolism. 1. Gentry CA, Gross KB, Sud B, Drevets DA. Adverse outcomes associated with the use of One class of drugs commonly used with drotrecogin alfa (activated) in patients with clopidogrel is proton pump inhibitors severe sepsis and baseline bleeding precau- tions. Crit Care Med 2009;37(1):19-25. (PPIs). Some reports suggest that use of certain PPIs may make clopidogrel less 2. APACHE II score >25. The APACHE II effective (3, 4) by inhibiting the enzyme score (Acute Physiology and Chronic Health that converts clopidogrel to the active Evaluation II) is a commonly-used severity of form of the drug. Other reports do not disease classification system calculated for suggest this effect (5, 6). Proton pump critically ill patients after admission to an inhibitors decrease stomach acid and are intensive care unit. used to treat frequent heartburn and stomach ulcers. Clopidogrel can irritate 3. Sweeney DA, Natanson C, Eichacker PQ. the stomach so PPIs are commonly used Recombinant human activated protein C, package labeling, and hemorrhage risks. Crit with clopidogrel to help reduce this Care Med 2009; 37 (1):327-328. irritation. Currently, there is no evidence that other drugs that reduce stomach 4. Early communication of ongoing safety acid, such as H2 blockers or antacids review. http://www.fda.gov/medwatch interfere with the antiplatelet activity of clopidogrel. Clopidogrel bisulfate: References ongoing safety review 1 Frere C et al. Effect of cytochrome P450 United States of America — The Food polymorphisms on platelet reactivity after and Drug Administration (FDA) is aware treatment with clopidogrel in acute coronary of published reports that clopidogrel syndrome. Am J Cardiol 2008; 101:1088–93. (Plavix®) is less effective in some pa- tients than it is in others. Differences in 2 Trenk et al. Cytochrome P450 2C19 681G A effectiveness may be due to genetic polymorphism and high on-clopidogrel platelet differences in the way the body metabo- reactivity associated with adverse 1-year lizes clopidogrel (1, 2) or that using clinical outcome of elective percutaneous certain other drugs with clopidogrel can coronary intervention with drug eluting or interfere with how the body metabolizes bare-metal stents. J Am Coll Cardiol 2008; 51: 1925–34. clopidogrel (3). 29