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WHO Drug Information Vol 23, No. 2, 2009                               World Health Organization




WHO Drug Information
                                            Contents
Pharmacovigilance Focus                           Sodium valproate and fetal malformations 113
                                                  Abacavir: determining risk of heart attack 114
Biosimilar medicines and safety: new
                                                  Carbamazepine: serious adverse skin
challenges for pharmacovigilance             87
                                                     reactions                               114
                                                  Electronic adverse reaction reporting tool 115
Blood and Biomedicines                            Intensive monitoring of varenicline        116
Availability, quality and safety of blood
  and blood products                         95   Regulatory Action and News
                                                  Influenza virus vaccines: 2009–2010
New Regulatory Challenges                             season                                    117
Contribution of clinical pharmacologists          Sale of efalizumab suspended                  117
  to government: opportunities and                Efalizumab: voluntary withdrawal              118
  challenges                                 99   Oseltamivir: extension of shelf life          118
                                                  Antiviral medicines in an influenza
                                                      pandemic                                  119
Safety and Efficacy Issues                        European Union and Health Canada:
Etanercept: histoplasmosis and invasive               confidentiality arrangement               119
   fungal infections                      104     Ixabepilone: withdrawal of application
Zonisamide: metabolic acidosis            104         for marketing authorization               120
Progressive multifocal leuko-                     Peginterferon alfa–2b: withdrawal of
   encephalopathy                         105         application for marketing authorization   120
Severe adverse reactions with                     Levodopa/carbidopa/entacapone:
   intravenous immunoglobulin             105         withdrawal of application for
Exanatide: risk of severe pancreatitis                extension of indication                   120
   and renal failure                      106
Benefits of methylphenidate continue to           Medicines Strategy
   outweigh risks                         106
Chromic phosphate P32: acute                      and Policies
   lymphocytic leukaemia                  107     Good Governance for Medicines
Warning for metoclopramide-containing               Programme                                   122
   drugs                                  108
Metabolic effects of antipsychotics       108
Cefaclor and serum sickness-like                  Recent Publications,
   reactions in children                  108     Information and Events
Toremifene: prolongation of QTc interval 109      ASEAN: mutual recognition arrangement
Atomoxetine: risk of psychotic or manic              for GMP                               127
   symptoms                               109     Losing artemisinin?                      127
Lignocaine with chlorhexidrine gel:               International drug price indicator guide 128
   anaphylaxis                            110
Moxifloxacin safety update                110
Codeine toxicity in breastfed infants     110     Proposed International
Atypical antipsychotics: risk of stroke   111
Biphosphonates: atypical stress fractures 112
                                                  Nonproprietary Names:                         129
Effects of MRI on implantable drug pumps113        List 101



                                                                                                 85
World Health Organization            WHO Drug Information Vol 23, No. 2, 2009




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WHO Drug Information Vol 23, No. 2, 2009




Pharmacovigilance Focus
Biosimilar medicines and                          Biological medicinal products (biopharma-
                                                  ceuticals) have a successful record in
safety: new challenges for                        treating many life threatening and chronic
pharmacovigilance                                 diseases. However, their cost has often
                                                  been high, thereby limiting their access to
Regulatory experience of approving and            patients, notably in developing countries.
monitoring the safety of biosimilar medi-         More recently, the expiration of patents
cines varies across the world. Recently,          and/or data protection for the first major
the European Union (EU) took the lead in          group of innovative biotherapeutics is
establishing a transparent regulatory             stimulating development of products
process for approving biosimilars. To             “similar” to the original biological products
date, the EU has approved a number of             which rely for their licensing, in part, on
biosimilars such as formulations of               data from originator products licensed on
somatotropin, epoietin and, most recently,        a full registration dossier.
filgrastim. The prevailing view among
regulators is that proteins are much more         A variety of terms, such as ‘biosimilars’,
complex than small molecule medicines             ‘follow-on protein products’ and ‘subse-
and it may not be possible to demonstrate         quent-entry biologics’ have been used by
the identical nature of two biological            different jurisdictions to describe these
products originating from different manu-         products. The term ‘generic’ medicine is
facturing sources solely based on quality         used extensively for chemical, small
information.                                      molecule medicinal products that are
                                                  structurally and therapeutically equivalent
This has led to the view that follow-on           to an originator product whose patent
biological products manufactured by               and/or data protection period has expired.
generic manufacturers after expiry of
patent and other exclusivity rights cannot        Current situation
be approved using the same simplified             In many countries, a regulatory pathway
regulatory procedures as applied for              for the approval of generic medicines has
small molecule-based generic drugs.               been established. Since biological medici-
Generating additional nonclinical and             nal products consist of large and highly
clinical data to demonstrate that these           complex molecular entities that are
medicines have an equivalent, or similar,         difficult to characterize, the approach
safety and efficacy profile to the originator     established for small molecule generic
product is needed. However, several               medicines is not fully appropriate for
parties have raised concerns that such            development, evaluation and licensing of
regulatory procedures may not be enough           biosimilars — as they are called in the
to ensure the safety and efficacy of these        EU. The fine structure of a biotherapeutic
products. This article gives an overview of       medicine is very sensitive to various
regulatory experience as well as the main         production parameters and the full
principles and issues concerning quality,         understanding of all processes involved is
safety and efficacy of these products.            complicated. Thus, it is unlikely that one

* This article does not necessarily reflect the policies and views of the World Health Organiza-
tion.



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Pharmacovigilance Focus                          WHO Drug Information Vol 23, No. 2, 2009



manufacturer will be able to precisely        regulation was formally recognized by the
reproduce a biotherapeutic medicine           World Health Organization (WHO) in
manufactured by another company.              2007. Since then, WHO has been work-
Indeed, an increasingly wide range of         ing with regulators from many countries
biosimilars are under development or          on a draft document that provides guid-
already licensed in many countries.           ance for the development and evaluation
                                              of biological therapeutic products that
As stated, the EU has taken the lead in       may be subject to abbreviated licensing
establishing a regulatory process for         pathways [11]. The document is expected
approving biosimilars and EU legislation      to be finalized later in 2009.
now differentiates between “generic
medicinal products” and “similar biological   Generic medicines and biosimilars:
medicinal products”. It also defines the      similarities and differences
regulatory approach for EU marketing          Multisource (generic) medicines are
authorization of biosimilar medicinal         formulated when patent and other exclu-
products. Both general [1–3] and product-     sivity rights expire. These medicines have
specific guidelines dealing with recom-       an important role to play in public health
binant erythropoietin [4], granulocyte        as they are well known to the medical
colony stimulating factor (G-CSF) [5],        community and usually more affordable
human somatotropin [6] and human              due to competitive availability.
insulin [7] have been issued by the
Committee for Medicinal Products for          The key requirement for authorization of
Human Use (CHMP) of the European              generic medicines is therapeutic inter-
Medicines Agency (EMEA). Draft guide-         changeability with the originator product.
lines have also been issued for interferon    To ensure therapeutic interchangeability,
alfa [8] and low molecular weight             generic products must contain the same
heparins [9]. All these guidelines have       amount of active ingredient and have the
one common feature — identifying the          same dosage form and be bioequivalent
need for at least some clinical data to       to the originator product. Bioequivalence
support the approval of biosimilar medici-    is usually established using comparative
nal products.                                 in vivo pharmacokinetic studies with the
                                              originator product (or reference product).
In the USA, there is currently no set of      A detailed description of how this is
guidelines comparable to those of the EU      carried out is described in respective
for biosimilars. The Food and Drug            WHO and national regulatory guidelines
Administration (FDA) has approved             [12, 13]. Well-resourced regulatory
Omnitrope®, a growth hormone biosimilar,      authorities require that a multisource
but this was done using the abbreviated       (generic) medicine must meet certain
new drug application (ANDA) procedure         regulatory requirements. In a well estab-
which essentially defines biosimilars as      lished setting, a generic medicine in
“chemical” generic drugs rather than          general must:
biopharmaceuticals [10]. However, this
method of approval is rather exceptional      • contain the same active ingredients as
as specific US regulatory guidelines for        the innovator drug;
approval of biosimilars do not currently
exist. Also, in most other countries a        • be identical in strength, dosage form,
comparative set of guidelines to those of       and route of administration;
the EU is absent.                             • have the same use indications;
The need for additional global regulatory     • be bioequivalent (as a surrogate marker
guidelines for evaluation and overall           for therapeutic interchangeability).



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WHO Drug Information Vol 23, No. 2, 2009                            Pharmacovigilance Focus



• meet the same batch requirements for          necessarily implies different host cell
  identity, strength, purity and quality, and   impurities as a minimum but the regulator
                                                has accepted the product as biosimilar
• be manufactured under the same                [14]. Differences with other products have
  standards of good manufacturing               been justified as being within the range of
  practice (GMP) required for innovator         natural variants without major clinical
  products.                                     impact.
Traditional generic medicines are small,        Originator products can go through a
organic molecules with a well-character-        number of variations during product
ized structure which can be more easily         development and the post marketing
defined by their atomic structure than          period. However, it is difficult to ascertain
their manufacturing processes. In the           whether major process variations (e.g.
case of more complicated generic medi-          cloning, selection of a suitable cell line,
cines, processes of synthesis are used.         fermentation, purification and formulation)
For example, biotechnological methods           will affect the end product. Thus, a bio-
are applied to produce large molecule           similar may differ significantly from the
medicines such as antibiotics (for exam-        originator product. In principle, some of
ple, streptomycin). Sometimes, several          the variations applied by originators can
methods of synthesis are combined,              be more substantial than those applied by
including the use of genetically engi-          generic manufacturers. When assessing
neered microorganisms in fermentation.          and accepting variations applied to the
What makes a difference is how well the         manufacture of originator products,
resulting active pharmaceutical ingredient      regulators can acquire valuable informa-
(API) can be characterized without risking      tion for assessing biosimilars.
unidentified impurities and subtle struc-
tural changes resulting in different safety     At present, lack of consistency between
and efficacy profiles.                          originator epoietins and products manu-
                                                factured in countries outside well regu-
The current challenge facing international      lated markets (such as the EU and USA)
development of a programme for bio-             was demonstrated at the World Congress
similars is that there is no way of confirm-    of Nephrology in 2007 [15, 16]. Some
ing that the reference product on the           products were identified as containing
market in one region complies with              additional basic isoforms — more than
requirements in other regions. It is true       4% aggregates and bacterial endotoxin
that even identifying a global comparator       contamination. These findings may affect
for generic “chemical” medicines is             efficacy, immunogenicity and patient
sometimes very challenging. Above all,          safety, respectively [16, 17]. Finally, some
the essential characteristics of a bio-         of these biosimilar products were not
similar are not yet perfectly defined. For      approved under a specific well-defined
example, some consider that only fully          and transparent regulatory framework.
characterized proteins with no major            Biopharmaceutical safety and efficacy
differences in their structure or impurity      data are difficult to transcribe into a
profile can be considered biosimilar.           discernable format and it is a challenge
However, EU regulators have accepted a          demonstrating that a biosimilar product is
degree of difference provided it can be         as safe or effective as the originator. It is
justified. For example, Valtropin® (soma-       hoped that rapid advances in science and
totropin) is expressed from yeast whereas       knowledge obtained from regulatory
its reference product, Humotrope®, is           practice may make this task easier in the
expressed from Escherichia coli. This           future.




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Pharmacovigilance Focus                           WHO Drug Information Vol 23, No. 2, 2009



Safety of biosimilars: specific                Another important factor is potential
points of concern                              contamination during manufacturing.
The two main issues of concern with            Impurities in biopharmaceuticals may
biosimilar agents involve variable po-         derive from chemicals or antibiotics used
tency/response and immunogenicity              during manufacture or may result from
thought to be due to one of three main         microbial or viral contamination. Impurities
mechanisms: glycosylation, contamina-          such as endotoxins or denatured pro-
tion or changes to three-dimensional           teins, for example, may give a danger
structure. Immunogenicity is generally the     signal to T cells which may then send
primary safety concern, but variation in       activating signals to B cells leading to an
potency can also raise safety issues in        immune response.
the case of substitution of the original
molecule with biosimilars, e.g. variability    An important lesson was learned in the
in haemoglobin values seen with original       case of an increasing incidence of anti-
epoietin [18] and its possible association     body-mediated pure red cell aplasia
with increased mortality in dialysis pa-       (PRCA) observed outside the USA
tients [19]. The issues of safety and          between 2000 and 2002 which revealed
efficacy cannot easily be separated as         that a small change in the formulation of a
binding of an agent by immune system           well-established innovator biopharma-
molecules will often decrease its clinical     ceutical product (epoietin alfa) with
effect and changes to the shape or             extensive patient years experience may
structure of a protein can alter binding to    have significant clinical consequences
immune system receptors as well as to its      [22]. The sharp increase in incidence
physiological target. Therefore, biosimi-      occurred primarily among those on
lars could induce immune responses             Eprex®/Erypo®, and coincided with
which may be either clinically irrelevant or   replacement of human serum albumin as
could have severe and potentially lethal       a stabilizer by glycine and polysorbate 80.
consequences.                                  Subsequent withdrawal of the SC formu-
                                               lation of epoietin alfa led to a consider-
The glycosylation of recombinant proteins      able decrease in the incidence of PRCA
can influence degradation, exposure of         cases. A number of possible mechanisms
antigenic sites and solubility, as well as     have been proposed to explain the
immunogenicity. Changes in degradation         observed upsurge of PRCA but it is likely
can produce novel antigenic epitopes not       the modification in formulation played a
found in the parent molecule with poten-       major role [23].
tially increased immunogenicity and
biological activity and metabolic half-life    Alterations to the three-dimensional
also affected. The degree of glycosylation     structure of a protein may also have
depends primarily on the host cell expres-     important effects on immunogenicity.
sion system. For example, recombinant          Major sources of such changes include
G-CSF expressed in Escherichia coli is         protein aggregation (which has been
non-glycosylated, whereas that ex-             suggested as one possible explanation of
pressed in Chinese hamster ovary cells is      the PRCP epidemic described above),
glycosylated. Similarly, proteins manufac-     oxidation and deamidation. Likely aggre-
tured in yeast cells contain high levels of    gation is of particular concern as it may
mannose sugar groups, rendering them           lead to the immune system recognizing
more prone to degradation and thereby          the protein as non-self and mounting a
decreasing their half-life. [See references    response [24]. This is probably because
20 and 21 for more details about effects       the repeating structure of protein aggre-
of immunogenicity.]                            gates more closely resembles the micro-




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WHO Drug Information Vol 23, No. 2, 2009                              Pharmacovigilance Focus



bial structures that the immune system is         even very small changes in manufactur-
primed to act against [25]. The process           ing can have major consequences for a
by which the body becomes reactive to             product’s adverse effects [27]. Pharma-
the protein can be very slow: antibodies          covigilance is thus likely to be a long-term
to products such as interferon and eryth-         project for any biosimilar medicine.
ropoietin may be detected for more than a         Overall, routine pharmacovigilance is
year after treatment cessation [26].              recommended for products where no
                                                  special concerns have arisen, whereas
Clinical safety data                              additional pharmacovigilance activities
and pharmacovigilance                             and action plans will be required for
The concerns raised above have been               medicinal products with important estab-
addressed, as far as possible and in line         lished risks, potential risks or missing
with present scientific knowledge, in EU          information.
regulatory guidance. For example,
erythropoietin is a more complex mole-            Spontaneous reporting still remains the
cule compared to either insulin or growth         cornerstone of pharmacovigilance but has
hormone. The respective guidelines                several weaknesses. Often, only the
reflect this complexity and, in order to          international nonproprietary name (INN)
identify potential immunogenicity, advo-          is used as the sole product identifier and
cate conducting at least two randomized           in the case of several products with the
controlled trials confirming safety data          same INN (originator, plus generics or
collected over a minimum of 12 months             biosimilars) it may be difficult to trace the
from at least 300 patients. Within the EU         exact manufacturer of the product. A
authorization procedure, the applicant            much better traceability of products is
should present a risk management                  needed [28], particularly in the case of
programme/pharmacovigilance plan in               biosimilars.
accordance with current EU legislation
and pharmacovigilance guidelines.                 Recent developments within the Interna-
                                                  tional Conference on Harmonization of
In order to further study the safety profile      Technical Requirements for Registration
of the biosimilar medicinal product, data         of Pharmaceuticals for Human Use (ICH)
for rare adverse events should be col-            raise hopes that a harmonized set of
lected from a cohort of patients represent-       product identifiers will become available
ing all approved therapeutic indications.         soon and could improve future traceabil-
Specific reference is made to include             ity. Recently, the ICH Steering Committee
assessment of the incidence of PRCA               recognized the benefits of continuing to
within the pharmacovigilance plan for             work with International Standard Develop-
epoietin biosimilars [4]. It is clear that with   ment Organizations in developing harmo-
300 patients PRCA may not be detected             nized electronic messages to transfer
due to the relatively small number of             regulatory information with a view to
patients involved as compared to the              developing harmonized formats for
rarity of this complication. Consequently,        Individual case safety reports (ICSR) and
EMEA guidelines for epoietins also                identification of medicinal products [29]
require immunogenicity testing and
pharmacovigilance programmes to                   Different versions of biopharmaceuticals
monitor the efficacy and safety of                have been available in both India and
biosimilar products during post-approval.         China for several years [30]. It is impor-
                                                  tant to note that both India and China are
Nonetheless, some adverse effects may             considered to have less stringent regula-
take more than a year to appear [26] and          tory standards than the EU and the USA.



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Pharmacovigilance Focus                           WHO Drug Information Vol 23, No. 2, 2009



Unfortunately, both countries have under-      but patients should not be expected to
developed pharmacovigilance systems            bear the burden of excessive trial-error
and provide only small number of adverse       incidents.
drug reaction reports to the WHO Interna-
tional Programme on Drug Monitoring            References
database managed by the Uppsala                1. European Medicines Agency. Guideline on
Monitoring Centre [31].                        Similar Biological Medicinal Products, CPMP/
                                               437/04, October 2005. www.emea.europa. eu/
Conclusions                                    pdfs/human/biosimilar/043704en.
The cost of providing effective therapies
in different disease areas increases           2. European Medicines Agency. Guideline on
progressively and biosimilar medicines         Similar Biological Medicinal Products Contain-
                                               ing Biotechnology-derived Proteins as Drug
may offer considerable advantages to           Substance – Non Clinical and Clinical Issues,
hard-pressed health-care budgets glo-          CHMP/42832/05, February 2006. www.emea.
bally. Regulatory decisions to permit          europa.eu/pdfs/human/biosimilar 4283205en.
clinical use should be based on rigorous
and highly competent case by case              3. European Medicines Agency. Similar
scientific assessments and presence of         Biological Medicinal Products Containing
appropriate systems for pharmacovigi-          Biotechnology-derived Proteins as Active
                                               Substance: Quality Issues, CHMP/49348/05,
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regulatory science would benefit from          human/biosimilar/4934805en.
better cooperation and information
exchange between different regulators          4. European Medicines Agency. Annex
internationally. Safety has to come first      Guideline on Similar Biological Medicinal
and effective pre- and post-marketing          Products Containing Biotechnology-derived
safety monitoring remains the key.             Proteins as Drug Substance – Non Clinical
                                               and Clinical Issues containing Recombinant
                                               Human Erythtropoietin, CHMP/94526/05,
Sufficient regulatory tools are currently      March 2006. www.emea.europa.eu/pdfs/
available to ensure safety of biosimilars      human/biosimilar/9452605en.
but the proper implementation of these
tools may prove challenging, particularly      5. European Medicines Agency. Annex
outside well established and resourced         Guideline on Similar Biological Medicinal
regulatory settings. Even in the EU,           Products Containing Biotechnology-derived
applying pharmacovigilance programmes          Proteins as Drug Substance –Non Clinical and
with uniform excellence across the region      Clinical Issues containing Recombinant
remains a challenge. Pharmacovigilance         Granylocyte Colony-Stimulating Factor,
                                               CHMP/313297/05, February 2006. www.
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actors in the pharmaceutical industry,         313297/05en.
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patients. Much better cooperation be-          Guideline on Similar Biological Medicinal
tween all stakeholders is needed to            Products Containing Biotechnology-derived
ensure that everyone involved fully            Proteins as Drug Substance – Non Clinical
understands the complex scientific             and Clinical Issues containing Recombinant
arguments and regulatory decisions             Human Growth Hormone, CHMP/94528/05,
applying to biosimilar products. This          February 2006. www.emea.europa.eu/pdfs/
                                               human/biosimilar/9452805en.
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Proteins as Drug Substance – Non Clinical          16. Singh AK. Gaps in the quality and potential
and Clinical Issues. Guidance on Similar           safety of Biosimilar epoetins in the developing
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human/biosimilar/3277505en.                        at: http://www.wcn2007.org
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27. Schellekens H. Erythropoietic proteins and   Brussels, Belgium, Novermber 8–13, 2008,
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Evolving Science in Drug Safety and Quality,




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Blood and Biomedicines
Availability, quality and                      manufacture of medicinal products and in
                                               supply of other blood components such
safety of blood and blood                      as platelets and red cells.
products                                       Developed countries have implemented
Blood has been collected, stored, tested,      procedures, policies and methods to
and transfused as a therapeutic since the      ensure the safety, quality and availability
beginning of the Twentieth century. Until      of all products derived from blood. This
the 1950s, activities concentrated on          has facilitated wider access to a compre-
improving storage of cells and ensuring        hensive range of safe blood products for
blood group compatibility. Thereafter,         patients with bleeding, immunological or
methods were developed for preparing           other severe diseases. Additionally, good
therapeutic products from human blood          manufacturing practices (GMP) have
and plasma, for use in treating life-          been introduced into plasma fractionation
threatening diseases, and to support           centres and are now also applied in blood
complex surgical procedures and trans-         establishments. Improvements in health
plantation.                                    and transfusion safety have been docu-
                                               mented by haemovigilance and phar-
For the past 25 years, efforts have            macovigilance programmes. Conversely,
focused on improving the safety and            comparable levels of availability, quality
efficacy of components derived from            and safety do not yet exist in many
blood and plasma, developing and               developing countries (1).
validating new methods, and seeking new
therapeutic uses. Blood products such as       Equitable and universal access to blood
blood clotting factors and human               and blood products of assured quality
immunoglobulins (polyvalent and specific)      and efficacy will contribute to achieve-
are now included in the World Health           ment of the UN Millennium Development
Organization’s (WHO) Model List of             Goals relating to reduction of maternal
Essential Medicines. This reflects the         and child mortality, as well as to efforts to
importance of blood and blood products         prevent HIV, HBV and HCV transmission.
in treating congenital, immune-acquired
life-threatening diseases, and conditions      Specific issues requiring
such as bleeding or trauma. In vitro           action
diagnostic devices for sensitive detection
of infectious disease markers play a role      Wastage of blood plasma
in successfully screening donor blood and      Several reasons account for the lack of
testing plasma pools prior to fractionation,   blood products in developing countries.
as well as in clinical diagnosis.              Plasma collected in developed countries
                                               is restricted and the potential for generat-
Transmission of infectious diseases by         ing surplus products sufficient to meet the
blood (notably HIV, hepatitis B (HBV) and      needs of developing countries is small.
hepatitis C (HCV)) has underscored the         Moreover, such products would be too
importance of quality systems and effec-       expensive. Developing countries must
tive regulation in the preparation of          therefore create their own sustainable
plasma as a raw material for use in the        supplies of blood products using blood



                                                                                         95
Blood and Biomedicines                           WHO Drug Information Vol 23, No. 2, 2009



plasma collected by their own blood           material. Substantial improvement will
establishments from their own popula-         prevail through introduction and enforce-
tions. Currently, however, a large percent-   ment of appropriate independent and
age of the plasma collected in developing     transparent quality assurance regulations
countries is categorized as a waste           and inspection procedures.
material and destroyed. This is because
appropriate technology and enforcement        Cross-border threats
of GMP are not available. Fractionation       The risks of disease migration are esca-
capacity could, however, become avail-        lating due to changes in habitat, increas-
able if plasma production complied with       ing mobility of populations, wars and
internationally-agreed standards.             global climate change. Pandemic infec-
                                              tions may also affect the supply of blood
Risk of transfusion-transmitted               and blood products in different ways.
diseases                                      These factors underscore the need to
If rigorous standards for donor selection,    introduce and strengthen quality assur-
testing and donation are not applied,         ance regulations in developing countries.
blood products and blood transfusion          The trend towards global regulatory
remain potent vectors for transmission of     convergence favours sharing of best
infectious diseases. Unfortunately, current   practices and the creation of internation-
arrangements for blood plasma collection,     ally agreed regulations. International
processing and testing are inadequate in      coordination, notably in areas such as the
a vast number of developing countries. In     manufacture of blood products, is there-
addition, increasing international mobility   fore becoming increasingly important.
of populations and globalization of the
blood industry highlight the need to          WHO activities
introduce and strengthen quality assur-       For more than 50 years, WHO has been
ance regulations.                             closely involved in setting quality and
                                              safety standards and training regulators
The history of blood transfusion has          in the manufacture and quality control of
amply demonstrated the risks. Examples        biological and blood products. The overall
include transmission of HIV, HCV and          technical responsibility for these activities
HBV, bacteria, trypanosoma and malarial       lies with the WHO Expert Committee on
parasites, as well as emerging and re-        Biological Standardization (ECBS).
emerging diseases. Although worldwide         Guidelines on the manufacture and
expansion of human blood plasma               quality control of blood and blood prod-
collection and processing of blood prod-      ucts have been developed, updated and
ucts has the capacity to save lives,          promoted by WHO (2–4). They represent
without appropriate control and standardi-    global consensus on the part of manufac-
zation it can also amplify public health      turers, regulators, professional interna-
risks.                                        tional societies and national blood pro-
                                              grammes with respect to production and
Poor regulation of blood products in          quality assurance procedures for blood
developing countries                          and blood products.
Developing countries recognize the need
to regulate blood products and assure         International biological reference prepara-
blood safety. Blood establishments            tions (5) to assist in establishing the
should be subject to inspection and audit     quality and safety of blood products and
by national regulatory authorities and        related in vitro diagnostic devices have
fractionators should demonstrate effective    also been adopted following validation in
control and traceability of plasma raw        global coordinated studies. The value of




96
WHO Drug Information Vol 23, No. 2, 2009                           Blood and Biomedicines



reliable internationally agreed reference     As a first step, up-to-date mechanisms for
materials is that manufacturers, regula-      implementing and enforcing quality
tors and blood establishments can             standards relating to blood products and
compare results worldwide despite the         blood safety-related in vitro diagnostic
increasing diversity of products.             devices will need to be introduced in
                                              countries. Activities should be supported
Public health challenges demonstrate the      by WHO guidelines for the production of
need for international collaboration and      blood plasma for fractionation, comple-
cooperation and the need to create            mented with additional guidelines to
regulatory networks to support dissemina-     promote and support implementation of
tion of regulatory actions, knowledge         GMP. Work should also be undertaken to
transfer and organization of training         review existing national regulations for
programmes. The International Confer-         blood products and to support and further
ence on Drug Regulatory Authorities           develop technical upgrading of medicines
(ICDRA) provides regulatory authorities of    regulatory authorities. Furthermore,
WHO Member States with a forum to             strategies should be sought to share the
meet and discuss ways to strengthen           expertise and experience already gener-
collaboration. In 2005, the WHO Blood         ated in developed countries and to
Regulators Network was established in         develop regional regulatory networks.
response to the request by ICDRA
participants and the ECBS. The Network        The dimension and complexity of the
was set up to foster development of           situation requires a multifaceted strategy
international consensus on effective          incorporating input from partners at
regulatory approaches.                        national, regional and international levels.
Recognizing the importance of the             WHO is well placed to secure the support
provision of safe blood, blood compo-         of international and nongovernmental
nents and plasma derivatives, the Fifty-      organizations, international professional
eighth World Health Assembly in 2005          associations and other agencies devoted
(Resolution 58.13) expressed its support      to finding solutions for health problems.
for “full implementation of well organized,
nationally coordinated and sustainable        Creating sustainable blood and plasma
blood programmes with appropriate             programmes with appropriate regulatory
regulatory systems” and stressed the role     systems will ensure both specific and
of “voluntary, non-remunerated blood          wider public health benefits including:
donors from low-risk populations”.
                                              • optimal use of donated blood plasma;
Improving access to blood                     • safer blood components;
and blood products                            • sustainable and affordable supply of
In order to ensure the availability of safe     safe essential products for the treatment
blood products in developing countries,
                                                of congenital diseases, trauma and
Member States should be alerted to the          immunologically mediated conditions;
risks of inadequate regulation and guid-
ance should be provided on establishing       • reduction of infectious disease transmis-
regulatory oversight of blood systems.          sion via blood-borne pathogens, both
Efforts should be made to increase the          within countries and across national
transfer of validated technology and to         borders;
build capacity with the overall aim of
improving access to safe, effective and       • improved quality and safety of all
affordable blood products.                      products from blood establishments




                                                                                       97
Blood and Biomedicines                           WHO Drug Information Vol 23, No. 2, 2009



 through the enforcement of national          References
 (and international) quality assurance
 regulations;                                 1. Global Database on Blood Safety.
                                              http://www.who.int/bloodsafety/global_
• substantial contribution to national/       database/en/
  regional public health programmes
  through, for example, improved popula-      2. World Health Organization. Requirements
  tion epidemiology for infectious dis-       for the collection, processing and quality
                                              control of blood, blood components and
  eases such as HIV, HBV and HCV,
                                              plasma derivatives. Technical Report Series,
  prevention and control of disease           No. 840 (1994).
  transmission, and blood donor health
  monitoring;                                 3. World Health Organization. WHO Recom-
                                              mendations for the production, control and
• potential application of quality systems    regulation of human plasma for fractionation.
  and GMP principles to other medical         Technical Report Series, No. 941 (2007).
  laboratory disciplines, and
                                              4. World Health Organization. Guidelines on
• inclusion of developing countries in the    viral inactivation and removal procedures
  international transfusion community and     intended to assure the viral safety of human
  in activities of associated plasma          blood plasma products. Technical Report
  fractionation industries.                   Series, No. 924 (2004).

The strategic goal is to improve public       5. World Health Organization. WHO Interna-
health by providing safe and effective        tional Biological Standards: http://www.who.
medicine to the world’s population. A risk–   int/bloodproducts/catalogue/en/index.html
benefit analysis must ensure that suffi-
cient quantities of the required products
are available at a cost that does not limit
access.




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WHO Drug Information Vol 23, No. 2, 2009




New Regulatory Challenges
Contribution of clinical pharmacologists to government:
opportunities and challenges
  .
 Clinical pharmacology is a scientific discipline that focuses on evaluating the effect
 of medicines in humans. Within a wider context of promoting safety, maximizing
 efficacy and minimizing side-effects, the work of the clinical pharmacologist is par-
 ticularly valuable in clinical trials. Other branches of the discipline involve pharma-
 covigilance, pharmacokinetics, drug metabolism, pharmacoepidemiology and, more
 recently, pharmacoeconomics. The clinical pharmacologist collaborates closely with
 other clinicians, pharmacists, biologists, analytical chemists, statisticians, epidemi-
 ologists and health economists. The clinical pharmacologist receives training in the
 evaluation of drug therapy and drug products and this makes the profession valu-
 able in a number of public activities such as drug approval, post-marketing surveil-
 lance, drug therapy selection, reimbursement decisions and ethical review of re-
 search projects.

 Faced with the task of regulating increasingly complex medicines and biomedicines
 markets, many regulatory authorities and health departments in developing coun-
 tries rely for advice on pharmacists who may have a limited medical background and
 lack the resources to access and assess information on the latest clinical research.
 On the other hand, clinical pharmacologists have a rigorous medical and scientific
 training which enables them to evaluate evidence and produce new data through
 well designed studies and interaction with other healthcare professionals. A clinical
 pharmacologist can provide the link between government and health care outcomes,
 serving also as a powerful advocate of evidence-based medicine. They can be in-
 valuable in addressing current challenges such as assessing new medicines, pro-
 viding unbiased medicines-related information, contributing to treatment guideline
 development, identifying preventable adverse drug reactions through promoting ra-
 tional use of medicines and improving prescribing practices. Politicians are often
 unaware of the valuable role that clinical pharmacology can play in improving per-
 formance of regulatory and health systems through closing the gap between current
 medical practices and latest clinical science.


Regulation and clinical                       tary and provide the means of attaining
pharmacology: emerging                        the health and wellbeing of citizens.
alliances                                     In a broad sense, the role of regulatory
As a function of protecting and promoting     agencies is multidimensional. The World
public health, a government must con-         Health Organization (WHO) proposes that
sider the ethical, scientific and develop-    regulatory goals are achieved through
mental aspects of medicines. Activities in    ensuring the safety, efficacy and quality of
these three dimensions are complimen-         medicines, rational use, and providing



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New Regulatory Challenges                         WHO Drug Information Vol 23, No. 2, 2009



appropriate medicines information to the       many essential and interrelated activities
public and health professionals (1).           which underpin the most important role of
Similarly, the European Medicines              the government in the broader sense: i.e.,
Agency (EMEA) coordinates the work of          to protect the health and wellbeing of its
national experts and has inter alia the        citizens through ensuring and promoting
following far reaching responsibilities (2):   effective public health.

“In the context of continuing globaliza-       Governments and their respective institu-
tion, to protect and promote public and        tions are responsible for ensuring basic
animal health by:                              human rights of citizens. In the event of
                                               research conducted within a country, they
• developing efficient and transparent         are expected to protect patients and trial
  procedures to allow rapid access by          participants by maintaining effective
  users to safe and effective innovative       systems for granting clinical research
  medicines and to generic and nonpre-         authorization and oversight of trials. This
  scription medicines through a single         challenging task involves assessment of
  European marketing authorization;            whether the clinical research planned is
                                               based on scientific principles and consid-
• controlling the safety of medicines for      erations of safety and whether it will offer
  humans and animals, in particular            the desired benefits to patients while
  through a pharmacovigilance network          identifying and minimizing any possible
  and the establishment of safe limits for     risks. This task forms the ethical dimen-
  residues in food-producing animals;          sion of the government’s role.

• facilitating innovation and stimulating      Milestones in the current
  research, hence contributing to the          ethical research environment
  competitiveness of the EU-based              The International Covenant on Civil and
  pharmaceutical industry, and                 Political Rights (1966) states that ... “no
                                               one shall be subjected without his free
• mobilizing and coordinating scientific       consent to medical or scientific experi-
  resources throughout the EU to provide       mentation”. These principles were devel-
  high-quality evaluation of medicinal         oped with a particular focus on risk/
  products, to advise on research and          benefit in the World Medical Association’s
  development programmes, to perform           Declaration of Helsinki and have been
  inspections for ensuring fundamental         incorporated into national and interna-
  GXP (good clinical practice, good            tional laws and regulations.
  manufacturing practice and good              In 1949, the Council for International
  laboratory practice collectively) provi-     Organizations of Medical Sciences
  sions are consistently achieved, and to      (CIOMS) was founded under the aus-
  provide useful and clear information to      pices of WHO and the United Nations
  users and healthcare professionals.          Educational, Scientific and Cultural
                                               Organization (UNESCO). The most
The ethical dimension                          important of CIOMS publications is its
In addition to their role in ensuring the      International Ethical Guidelines for
safety, efficacy and quality of medicines,     Biomedical Research Involving Human
governments are also tasked with the           Subjects. The latest version was pub-
responsibility of exerting an ethical          lished in 2002 (3) and, based on the
influence on processes in the develop-         Declaration of Helsinki, is designed to be
ment and marketing of medicines. The           of use in defining the ethics of biomedical
regulatory authority is responsible for        research, applying ethical standards in



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WHO Drug Information Vol 23, No. 2, 2009                        New Regulatory Challenges



local circumstances, and establishing or       Above all, governments have to ensure
redefining adequate mechanisms for             that only effective and safe good quality
ethical review of research involving           medicines are used to treat their citizens.
human subjects. The Guidelines are             Nowadays, all medicines are subject to
targeted to ethics committees, and review      marketing authorization prior to being
boards, sponsors and investigators. The        prescribed. Approval is based on assess-
CIOMS guidelines — to which several            ment of quality, safety and efficacy of the
clinical pharmacologists have contributed      product. The safety monitoring of medi-
— also provide the basis for government        cines during their whole life-cycle (from
thinking about clinical research, espe-        marketing authorization to potential
cially in resource poor settings.              withdrawal from the market) is also a task
                                               for governments. Usually, these and other
Good clinical practice (GCP) is a “stand-      medicines-related regulatory functions
ard for the design, conduct, performance,      are carried out by specialized govern-
monitoring, auditing, recording, analysis      mental agencies, such as the Food and
and reporting of clinical trials that pro-     Drug Administration (FDA) in the USA or
vides assurance that the data and re-          the European Medicines Agency (EMEA).
ported results are credible and accurate,
and that rights, integrity and confidential-   Scientific dimension
ity of trial subjects are protected.” Many     It is important for regulators involved in
national and regional GCP guidelines are       the evaluation of medicines prior to
based on, or refer to, the Declaration of      marketing to have the best possible
Helsinki, including WHO GCP Guidelines         scientific education and background or to
published in 1995 (4) and the Interna-         be able to call on expertise which is
tional Conference of Harmonization (ICH)       relevant to the work in hand. A critical
GCP (E6) from 1996 (5).                        scientific review of the clinical data will
                                               address the known and unknown aspects
A priority requirement for the ethical         of an assessment and provide relevant
review of a scientific study, research or      conclusions. The larger regulatory agen-
clinical trial involving human subjects is     cies possess their own clinical pharma-
submission of a research proposal for          cology units. For example, the US FDA
independent evaluation by scientific,          has in its Center for Drug Evaluation and
regulatory and ethical review committees.      Research (CDER) Office of Clinical
Nowadays, many governments define              Pharmacology. Safety surveillance and
procedural aspects of the work of the          pharmacovigilance is also entrusted to
ethics committees in detail.                   regulatory agencies, and here, also,
                                               expertise in clinical pharmacology is
For example, the European Commission           essential.
has laid down strict timelines for process-
ing research applications that affect the      Governments, either directly or through
work of ethical review committees in all       their specialized agencies, are also
27 European Union countries. This can          involved in taking decisions about medi-
be perceived as the European Commis-           cines selection for public procurement,
sion’s attempt to facilitate and promote       developing national treatment guidelines
clinical research. Clinical pharmacologists    and proposing inclusion of medicines in
can be particularly valuable as members        reimbursement lists. This work may also
of the ethical review committee because        involve composing and updating national
of their extensive knowledge of the            essential medicines lists as promoted by
effects of medicines and the related area      WHO. The real life performance of drugs
of clinical research.                          following regulatory approval requires a



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New Regulatory Challenges                         WHO Drug Information Vol 23, No. 2, 2009



cost-effectiveness assessment by highly        hand evidence that electronic health
qualified specialists using different mod-     records can offer added value for phar-
els and again calls on the expertise of the    macogenetic research and pharmacovigi-
clinical pharmacologist.                       lance (7). Clinical pharmacologists should
                                               be actively involved in designing elec-
These various activities support the           tronic patient health records due to their
rational use of medicines, sometimes also      potential for future clinical research use,
called “quality use” (6). Governmental         including monitoring of rational use and
institutions involved in such activities       safety.
include the National Institute for Health
and Clinical Excellence (NICE) in the          Government efforts to create a research
United Kingdom. Activities are based on        friendly environment should include legal
the best possible scientific methodologies     and other systems with effective function-
and knowledge and are part of the              ing and well-informed scientific govern-
scientific dimension of the Government’s       ment backup. Due to the relative lack of
obligation to its citizens. Clinical pharma-   new therapies and pressure from patient
cologists are well prepared to meet the        groups and industry, governments have
challenges needed in the complex as-           been exorted to grant “early market
sessment of medicines.                         approvals” under certain preconditions.
                                               However, effective methodologies for
Developmental dimension                        pharmacovigilance and safety studies in
Lastly, governments carry the responsibil-     the context of early market access have
ity of improving the health of their citi-     yet to be created and tested and clinical
zens. Stimulating the necessary research       pharmacologists have an important role
and developing research capacities is          to play here (8, 9). Clinical pharmacology
therefore a regulatory function. Action        also contributes to the discipline of
should be directed to facilitating research    pharmacoepidemiology, which is some-
in areas where lack of effective or safer      times the only available method to evalu-
health care interventions impedes im-          ate the benefits and risks of long term
provement to public health. Recent             pharmacotherapy. Similarly, pharmaco-
examples provide evidence that private         economics attempts to give a financial
sector initiatives and funding are insuffi-    cost and value to everyday medicines use
cient in developing and promoting public       and contributes to rational reimbursement
health through medicines research. Thus,       systems.
governments may also be involved in
providing financial support to stimulate       In the implementation of these various
clinical research in medicines. Clinical       dimensions, governments create various
pharmacologists are well positioned to         tools, including laws and regulations,
help make appropriate judgements on the        infrastructure and institutions, with sup-
scientific value of government funding of      porting resource allocations. A key
research proposals.                            resource is properly trained specialists
                                               who are capable of taking decisions
An important emerging issue is the             based on the best possible scientific
adoption of electronic patient health          methodology and evidence. These
records implemented or planned to be           dimensions are interrelated and interde-
implemented in many countries. Although        pendent. Good ethics cannot do without
these may be perceived as mostly admin-        good science and developmental goals
istrative tools, they hold scientific poten-   cannot be achieved without following
tial for monitoring of safety and quality      ethical principles and a sound science
medicines therapy. There is already first-     base.




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The clinical pharmacologist is thus a           3. The Council for International Organizations
unique specialist and ally who can serve        of Medical Sciences (CIOMS). International
the public best by ensuring that only safe      Ethical Guidelines for Biomedical Research
and effective medicines are authorized for      Involving Human Subjects, Geneva, 2002.
                                                http://www.cioms.ch/
use, as well as facilitating cost effective
prescribing and improving rational use of       4. World Health Organization. Guidelines for
drugs. In order to meet the needs of            good clinical practice (GCP) for trials on
various governmental services and               pharmaceutical products. Technical Report
ensure that the best scientific knowledge       Series, No. 850, 1995. http://www.who.int/
is used to make decisions, clinical phar-       medicines/library/par/ggcp/GGCP.shtml
macology as a discipline should be
harmonized with the objectives and              5. International Conference of Harmonization
policies of governments to ensure a             (ICH) E6: Good Clinical Practice: Consoli-
benefit to public health                        dated Guideline. http://www.ich.org/cache/
                                                compo/276–254–1.html
Equally, governments of emerging econo-         6. Smith AJ, McGettigan P. Quality use of
mies and developing countries may               medicines in the community: the Australian
benefit hugely from the expertise of            experience. Br J Clin Pharmacol (2000) 50(6):
clinical pharmacologists and experience         515–519.
has shown that a qualified clinical phar-
macologist can make a great difference at       7. Wang X, Hripcsak G, Markatou M, et al.
country level.                                  Active computerized pharmacovigilance using
                                                natural language processing, statistics and
References                                      electronic health records: a feasibility study. J
                                                Am Med Inform Assoc (2009).
1. World Health Organization. WHO Policy
Perspective on Medicines No 7, “Effective       8. Lesko LJ. Paving the Critical Path: How can
Medicines Regulation: Ensuring Safety,          Clinical Pharmacology Help Achieve the
Efficacy and Quality”, November 2003. http://   Vision? Clinical Pharmacology & Therapeutics
www.who.int/medicines/organization/mgt/         (2007) 81:170–177.
PolicyPerspectives.shtml
                                                9. Massol J, Puech A, Boissel JP. How to
2. EMEA Mission Statement. http://              anticipate the assessment of the public health
www.emea.eu.int/mission.htm                     benefit of new medicines? Therapie. (2007)
                                                62(5):427–35.




                                                                                              103
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Safety and Efficacy Issues
Etanercept: histoplasmosis                     Reference: Communication from Amgen. 21
                                               April 2009 at Health Canada. http://www. hc-
and invasive fungal infections                 sc.gc.ca/dhp-mps/medeff/advisories-avis/prof/
                                               _2009/index-eng.php
Canada — The manufacturer of
etanercept (Enbrel®) has informed
healthcare professionals of the risk of        Zonisamide: metabolic
invasive fungal infections, including          acidosis
histoplasmosis. Etanercept is indicated
for the treatment of rheumatoid arthritis,     United States of America — Following
psoriatic arthritis, juvenile idiopathic       a review of updated clinical data, the
arthritis, ankylosing spondylitis and          Food and Drug Administration (FDA) has
plaque psoriasis.                              determined that treatment with zonis-
                                               amide can cause metabolic acidosis in
There have been reports of serious             some patients. Zonisamide (Zonegran®
pulmonary and disseminated histoplas-          and generics) is indicated as adjunctive
mosis, coccidioidomycosis, blastomycosis       therapy in the treatment of partial sei-
infections, sometimes with fatal out-          zures in adults with epilepsy.
comes, in patients taking TNF blockers,
including etanercept. Histoplasmosis and       Chronic metabolic acidosis can have
other invasive fungal infections have not      adverse effects on the kidneys and on
been recognized consistently in patients       bones, and can retard growth in children.
taking TNF blockers. This has led to           Patients with predisposing conditions or
delays in instituting appropriate treatment,   therapies, including renal disease, severe
sometimes resulting in death.                  respiratory disorders, diarrhoea, surgery,
                                               ketogenic diet, or certain other drugs may
For a patient taking a TNF blocker who         be at greater risk for developing meta-
presents with signs and symptoms of            bolic acidosis following treatment with
systemic illness, such as fever, malaise,      zonisamide. The risk of zonisamide-
weight loss, sweats, cough, dyspnoea,          induced metabolic acidosis appears to be
and/or pulmonary infiltrates, the health-      more frequent and severe in younger
care professional should ascertain if the      patients. Although not approved by the
patient has lived or worked in or travelled    FDA, zonisamide is sometimes used in
to areas of endemic mycoses, and               children. Metabolic acidosis increases the
appropriate empiric antifungal treatment       risk for slowed growth in children and
may be initiated while a diagnostic            could reduce the overall height that they
workup is being performed. As with any         achieve.
serious infection, the TNF blocker should
be stopped until the infection has been        The FDA recommends that healthcare
diagnosed and adequately treated.              professionals measure serum bicarbo-
                                               nate before starting treatment and peri-
Prescribers should discuss with patients       odically during treatment, even in the
and their caregivers the risk for infections   absence of symptoms. If metabolic
while receiving TNF blockers, including        acidosis develops and persists, consid-
infections caused by viruses, fungi, or        eration should be given to reducing the
bacteria including tuberculosis (TB).          dose or discontinuing zonisamide (using



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WHO Drug Information Vol 23, No. 2, 2009                          Safety and Efficacy Issues



dose tapering), and modifying the pa-          ously identified an association between
tient’s antiepileptic treatment as appropri-   PML and use of some monoclonal anti-
ate. If the decision is made to continue,      bodies such as natalizumab (Tysabri®,
then alkali treatment should be consid-        used to treat multiple sclerosis) and
ered.                                          rituximab (MabThera®, indicated for non-
                                               Hodgkin lymphoma and severe active
Reference: FDA Alert, 23 February 2009 at
                                               rheumatoid arthritis). An association has
http://www.fda.gov/medwatch
                                               also now been identified between PML
                                               and efalizumab (Raptiva®).
Progressive multifocal
leukoencephalopathy                            Up to 6 January 2009, the MHRA has
                                               received 19 suspected reports of PML, in
United Kingdom — Progressive                   three of which PML was listed as the fatal
multifocal leukoencephalopathy (PML) is        suspected reaction.
a rare and usually fatal re-infection of the
CNS characterized by progressive               Reference: Medicines and Healthcare
damage and inflammation of the white           Products Regulatory Agency, Drug Safety
matter in the brain, in multiple locations.    Update, Volume 2, Issue 8 March 2009 at
PML is caused by a type of human               http://www.mhra.gov.uk/Safetyinformation/
polyoma virus known as the JC, or John
Cunningham virus. The JC virus is              Severe adverse reactions with
widespread, with about 70–90% of adults        intravenous immunoglobulin
presenting antibodies.
                                               Australia — Intravenous immunoglobu-
The virus usually remains latent in            lin, normal (human) (IVIG) is used to treat
healthy individuals, only causing disease      a variety of deficiencies and disorders
when the immune system is severely             with an immune (or presumed immune)
compromised. PML has been studied in           aetiology. IVIG preparations, including
patients with HIV infection, where inci-       Intragam P®, Sandoglobulin®, and
dence is approximately 5% of the disease       Octagam®, have been available since the
population. PML also occurs in patients        1980s. Use worldwide and in Australia
with cancer and those who have                 has more than doubled over the past
received kidney or bone-marrow trans-          decade (1) partly due to increasing use in
plants. In PML, gradual destruction of the     off-label indications.
myelin sheath covering nerve axons             Nausea and vomiting are most commonly
leads to impaired transmission of nerve
                                               observed with IVIG, as are hypersensitiv-
impulses. PML causes rapidly progres-          ity reactions which may include anaphy-
sive focal neurological deficits including:    laxis. Those with IgA deficiency have a
                                               higher risk of hypersensitivity to IVIG due
• cognitive and behavioural changes;           to the presence of IgA antibodies. Less
• paraesthesia;                                common but also serious reactions are
                                               aseptic meningitis, haemolysis and
• visual problems;                             transfusion-related acute lung injury —
                                               one case has been reported in Australia
• gait abnormalities and loss of limb
  coordination, and                            and one in Canada (2). Recently, Health
                                               Canada highlighted an association
• hemiparesis.                                 between IVIG and thromboembolic
                                               events (3).
The Medicines and Healthcare Products
Regulatory Agency (MHRA) has previ-            To date, the Therapeutic Goods Adminis-
                                               tration (TGA) has received 356 reports of



                                                                                           105
Safety and Efficacy Issues                           WHO Drug Information Vol 23, No. 2, 2009



adverse reactions associated with IVIG:           Exenatide: risk of severe
IVIG was the sole suspected agent in              pancreatitis and renal failure
90% of reports. Thirty-five per cent
describe serious reactions, including             United Kingdom — Exenatide (Byetta®),
where the outcome was fatal due to:               an incretin mimetic, is a glucagon-like-
stroke/myocardial infarction, myocardial          peptide-1 analogue that stimulates insulin
infarction, convulsions, hepatic and renal        release from pancreatic cells in a glucose
failure, and respiratory failure respec-          dependent manner. Exenatide is indi-
tively. In fatal cases, patients generally        cated for treatment of type 2 diabetes
had thrombogenic risk factors such as             mellitus in combination with metformin,
hypertension, obesity, increasing age, or         with or without sulphonylureas in patients
past history of stroke.                           who have not achieved adequate glycae-
                                                  mic control on maximally tolerated doses
The TGA has also received substantial             of these oral therapies.
numbers of reports describing pyrexia
(58), chills (41), haemolysis or anaemia          Exenatide should not be used in patients
(32), meningitis (20), neutropenia (12),          with type 1 diabetes or for the treatment
hepatic disorders (11), and renal failure/        of diabetic ketoacidosis. It should not be
impairment (8). In some of the cases, the         used in patients with type 2 diabetes
reactions — particularly those suggesting         who require insulin therapy due to cell
hypersensitivity — occurred during the            failure.
IVIG infusion and improved with slowing
or stopping the infusion.                         Suspected adverse reaction reports of
                                                  necrotizing and haemorrhagic pancreatitis
Before and during the use of IVIG, any            have been received in association with
pre-existing thrombogenic risk factors            exenatide. Some of these reports had a
should be assessed and all patients               fatal outcome. If pancreatitis is diag-
should be monitored closely during                nosed, exenatide should be permanently
infusion. A slow infusion rate of IVIG            discontinued. Reports of renal impair-
should be considered for all patients with        ment, including acute renal failure and
risk factors (as recommended in the PI).          worsened chronic renal failure have also
Extracted from the Australian Adverse             been received. Exenatide is not
Drug Reactions Bulletin, Volume 28,               recommended for use in patients with
Number 2, April 2009 at http://                   end-stage renal disease or severe renal
www.tga.gov.au/adr/aadrb/aadr0904.htm             impairment

References                                        Reference: Medicines and Healthcare
                                                  Products Regulatory Agency, Drug Safety
1. National Blood Authority. Criteria for the     Update, Volume 2, Issue 8 March 2009 at
clinical use of intravenous immunoglobulin in     http://www.mhra.gov.uk/Safetyinformation/
Australia. Australian Health Ministers’ Confer-
ence. December 2007.                              Benefits of methylphenidate
2. Case Presentation: Intravenous immune
                                                  continue to outweigh risks
globulin – suspected association with transfu-    United Kingdom — The EMEA’s Com-
sion-related acute lung injury. Canadian          mittee for Medicinal Products for Human
Adverse Reactions Newsletter Oct 2008; 18/4.
                                                  Use (CHMP) concluded that on the basis
3. Intravenous immune globulin: myocardial        of currently available data, the benefits of
infarction and cerebrovascular and thrombotic     methylphenidate continue to outweigh the
adverse reactions. Canadian Adverse Reac-         risks when used in its licensed indication.
tions Newsletter Jan 2008; 18/1.                  Methylphenidate is indicated as part of a



106
WHO Drug Information Vol 23, No. 2, 2009                          Safety and Efficacy Issues



comprehensive treatment programme for         2. Further information on brands of
attention deficit/hyperactivity disorder      methylphenidate available in the UK, see
(ADHD) in children aged 6 years or older      BNF, p 216 (edn 56; www.bnf.org).
and adolescents who are diagnosed
                                              3. Information on DSM-IV criteria is at
according to DSM-IV criteria or guidelines
                                              http://www.psychiatryonline.com/;
in ICD-10 and when remedial measures          information on ICD-10 is at
alone are insufficient.                       http://www.cdc.gov/nchs/about/otheract/i
                                              cd9/abticd10.htm
Treatment must be under the supervision
of a specialist in childhood behavioural      4. Medicines and Healthcare Products
disorders. Patients should be monitored       Regulatory Agency, Drug Safety Update,
during treatment, which should be inter-      Volume 2, Issue 8 March 2009 at http://
rupted at least once a year to determine      www.mhra.gov.uk/Safetyinforma tion/
whether continuation is needed.
                                              Chromic phosphate P32:
Contraindications—methylphenidate             acute lymphocytic leukaemia
should not be used in patients with:
                                              Canada — Information has been pro-
• Diagnosis or history of severe depres-      vided on important new safety information
  sion, anorexia nervosa or anorexic          concerning Chromic phosphate P32
  disorders, suicidal tendencies, psychotic   suspension (Phosphocol® P32) which is
  symptoms, mania, schizophrenia,             authorized for intracavitary instillation for
  severe mood disorders, or psychopathic      the treatment of peritoneal or pleural
  or borderline personality disorder.         effusions caused by metastatic disease.
• Diagnosis or history of severe and          Physicians should be vigilant for signs
  episodic (type I) bipolar (affective)       and symptoms of leukaemia in patients
  disorder that is not well-controlled.       who have received Phosphocol® P32.
• Pre-existing cerebrovascular disorders      The Canadian product monograph will be
  — e.g., cerebral aneurysm and vascular      updated to include the following warning.
  abnormalities, including vasculitis or
  stroke.                                     Leukaemia: Phosphocol® P32 may
                                              increase the risk of leukaemia in certain
• Unless specialist cardiac advice has        situations. Two children (ages 9 and 14)
  been obtained, in pre-existing cardio-      with haemophilia developed acute lym-
  vascular disorders, including severe        phocytic leukaemia approximately 10
  hypertension, heart failure, arterial       months after intra-articular injections.
  occlusive disease, angina, haemody-         Phosphocol® P32 is not indicated in the
  namically significant congenital heart      treatment of haemarthroses.
  disease, cardiomyopathies, myocardial
  infarction, potentially life-threatening    In addition, the product monograph will be
  arrhythmias, and dysfunction of cardiac     updated to include post-marketing reports
  ion channels                                of radiation injury (necrosis and fibrosis)
                                              to the small bowel, caecum, and bladder
References:                                   following peritoneal administration of
                                              Phosphocol® P32.
1. EMEA press release at http://www.
emea.europa.eu/pdfs/human/                    Reference: Health Canada, Alert dated 25
referral/methylphenidate/2231509en.pdf;       March 2009. at http://www.hc-sc.gc.ca/dhp-
question-and-answer document at               mps/medeff/advisories-avis/prof/_2009/index-
http://www.emea.europa.eu/pdfs/human/         eng.php



                                                                                         107
Safety and Efficacy Issues                        WHO Drug Information Vol 23, No. 2, 2009



Warning for metoclopramide-                    frequently than other agents. Prescribers
containing drugs                               are advised to monitor all patients taking
                                               antipsychotics for adverse metabolic
United States of America — The Food            effects.
and Drug Administration (FDA) has
announced that manufacturers of meto-          References
clopramide, a drug used to treat gastroin-
testinal disorders, must add a boxed           1. http://www.bpac.org.nz/magazine/2007/
                                               february/antipsychotics.asp
warning to labelling about the risk of long-
term or high-dose use. Chronic use of          3. Prescriber Update 2009;30(2):12 at http://
metoclopramide has been linked to              www.medsafe.govt.nz/profs/PUarticles.asp
tardive dyskinesia even after the drugs
are no longer taken.
                                               Cefaclor and serum sickness-
Metoclopramide works by speeding up            like reactions in children
the movement of the stomach muscles,           Australia — The association between
thus increasing the rate at which the          cefaclor and serum sickness-like reac-
stomach empties into the intestines. It is
                                               tions (SSLR), particularly in children, has
used as a short-term treatment of gastro-      long been recognized (1). These reac-
oesophageal reflux disease in patients         tions are characterized by a variety of
who have not responded to other thera-
                                               rashes, which include urticaria or ery-
pies, and to treat diabetic gastro-paresis.    thema multiforme, with or without
It is recommended that treatment not           angioedema, accompanied by arthritis/
exceed three months.
                                               arthralgia, with or without fever.
Reference: FDA News, 26 February 2009 at
http://www.fda.gov                             The reactions are rare but occur more
                                               often after a second or subsequent
Metabolic effects of                           course of treatment. Onset time is often a
                                               few days after cefaclor is commenced
antipsychotics                                 and signs and symptoms typically sub-
New Zealand — Although schizophrenia           side a few days after the drug is ceased.
itself is associated with several adverse      However, onset may also be delayed and
metabolic effects it is now clear that all     occur 7–21 days after stopping cefaclor.
antipsychotics, and in particular some         Children are more susceptible than
atypical antipsychotics, are associated        adults.
with adverse effects on weight, blood
glucose, and lipid concentrations. All of      The TGA continues to receive about 10
these adverse effects have long-term           reports per year of cefaclor-related SSLR
consequences in terms of life expectancy.      in children. If cefaclor must be prescribed
                                               to a child, the parents/caregivers should
While the effects of antipsychotics on         be advised to remain alert for the devel-
weight gain may be responsible for the         opment of new or worsening symptoms
increased risk of diabetes and hyperlipi-      that might indicate a hypersensitivity
daemia, a direct effect on glucose me-         reaction to the drug and to contact their
tabolism may also occur.                       doctor immediately if there are concerns.

Not all atypical antipsychotics are associ-    Extracted from the Australian Adverse
ated with the same level of risk. Clozap-      Drug Reactions Bulletin, Volume 28,
ine and olanzapine are considered to           Number 2, April 2009 at http://
cause adverse metabolic effects more           www.tga.gov.au/adr/aadrb/aadr0904.htm



108
WHO Drug Information Vol 23, No. 2, 2009                          Safety and Efficacy Issues



Reference: ADRAC. Cefaclor in the young        • If signs or symptoms that may be
patient: arthritis and arthralgia <http://       associated with cardiac arrhythmia
www.tga.gov.au/adr/aadrb/aadr9508.htm#           occur during treatment with toremifene,
cefaclor>. Aust Adv Drug React Bull 1995; 14     treatment should be stopped and an
(3).
                                                 ECG should be performed.

Toremifene: prolongation                       Currently, toremifene 20 mg/day and 80
of QTc interval                                mg/day are being studied in prostate
                                               cancer indications.
United Kingdom/European Union —
The manufacturer of toremifene                 Reference: Communication from Orion
(Fareston®) has informed healthcare            Pharma UK at http://www.mhra.gov.uk/
professionals of new information on            Safetyinformation/
prolongation of the QTc interval related to
toremifene. The approved therapeutic           Atomoxetine: risk of psychotic
indication for toremifene 60 mg/day is the     or manic symptoms
first line treatment of hormone dependent
metastatic breast cancer in postmeno-          United Kingdom — Atomoxetine
pausal patients.                               (Strattera®) is a selective noradrenaline
                                               reuptake inhibitor, authorized since 2004
Both in preclinical investigations and in      for use in the treatment of attention-
humans, changes in cardiac electro-            deficit/hyperactivity disorder (ADHD) as
physiology have been observed following        part of a comprehensive treatment
exposure to toremifene, in the form of QT      regimen. Continued case reports of
prolongation. Consequently:                    possible nervous-system and psychiatric
                                               adverse effects prompted a review of
• Toremifene is therefore contraindicated      data from all sources resulting in updated
  in patients with:                            information on the risk of new-onset or
                                               worsening of serious psychiatric disor-
 Congenital or documented acquired QT          ders, including psychotic reactions,
 prolongation; electrolyte disturbances,       hallucinations, mania, and agitation.
 particularly in uncorrected hypokalae-
 mia; clinically relevant bradycardia;         Product information for prescribers has
 clinically relevant heart failure with        been updated to reflect more fully the
 reduced left-ventricular ejection fraction;   emerging safety information. Atomoxetine
 previous history of symptomatic arrhyth-      is associated with treatment-emergent
 mias.                                         psychotic or manic symptoms in children
                                               and adolescents without a history of such
• Toremifene should not be used concur-        disorders. If such symptoms occur,
  rently with other drugs that prolong the     consideration should be given to a
  QT interval.                                 possible causal role of atomoxetine and
                                               discontinuation of treatment.
• Toremifene should be used with caution
  in patients with ongoing proarrhythmic       Advice for healthcare professionals:
  conditions (especially elderly patients)
  such as acute myocardial ischaemia or        • At normal doses, atomoxetine can be
  QT prolongation as this may lead to an         associated with emergent psychotic or
  increased risk for ventricular arrhyth-        manic symptoms (e.g., hallucinations,
  mias (including Torsade de Pointes) and        delusional thinking, mania, or agitation)
  cardiac arrest.                                in children and adolescents without a
                                                 history of psychotic illness or mania.



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Safety and Efficacy Issues                      WHO Drug Information Vol 23, No. 2, 2009



• If such symptoms occur, consideration      In February 2008, the manufacturer
  should be given to a possible causal       informed healthcare professionals of very
  role of atomoxetine and discontinuation    rare liver injuries and serious skin reac-
  of treatment.                              tions associated with moxifloxacin. This
                                             was in response to a worldwide review of
• It remains possible that atomoxetine       serious, including fatal cases of hepato-
  might exacerbate pre-existing psychotic    toxicity and bullous skin reactions such as
  or manic symptoms                          Stevens-Johnson syndrome (SJS) and
                                             toxic epidermal necrolysis (TEN) reported
Reference: Medicines and Healthcare          for moxifloxacin.
Products Regulatory Agency, Drug Safety
Update, Volume 2, Issue 8 March 2009 at      To date, HSA has received 22 local
http://www.mhra.gov.uk/Safetyinformation/    spontaneous adverse drug reaction
                                             reports associated with oral moxifloxacin.
Lignocaine with chlorhexidine                Patient exposure to moxifloxacin to date
                                             is estimated to be 230 577, according to
gel: anaphylaxis                             local figures provided by the manufac-
United Kingdom — Lignocaine 2% gel           turer. In the interpretation of the above
with chlorhexidine 0.05% is an anaes-        figures, there is a need to consider the
thetic/antiseptic/disinfectant combination   significant degree of under-reporting of
used as a lubricant for urology proce-       adverse reactions as is the case with all
dures and examination, and as sympto-        spontaneous adverse drug reaction
matic treatment of painful urethritis.       reporting programmes.
                                             References
Since 1990, the TGA has received 19
reports of suspected adverse reactions to    1. EMEA Press Release. European Medicines
lignocaine with chlorhexidine gel. Eleven    Agency recommends restricting the use of oral
of these were of anaphylaxis. Some were      moxifloxacin-containing medicines. http://
life threatening, but there have been no     www.emea. europa.eu/pdfs/human/press/
fatalities.
                                             2. Direct Healthcare Professional Communica-
The MHRA warns of the potential for          tion regarding moxifloxacin (Avelox®) and
                                             serious hepatic and bullous skin reactions.
anaphylaxis or other hypersensitivity
                                             http://www.mhra.gov.uk/
reactions with both lignocaine and chlor-
hexidine. Users of local anaesthetic         3. HSA Safety News, 19 Mar 2009 at http://
preparations should check which prod-        www.hsa.gov.sg
ucts contain chlorhexidine and are
reminded of the risk of severe allergic
reactions to medicines, even when
                                             Codeine toxicity
applied topically.                           in breastfed infants
                                             Singapore — Codeine is found in many
Reference: Medicines and Healthcare
                                             prescription and non-prescription pain
Products Regulatory Agency, http://
www.mhra.gov.uk/Safetyinforma tion/          relievers and cough syrups. Once in-
                                             gested, codeine is metabolised by cyto-
                                             chrome P450 2D6 (CYP2D6) to its active
Moxifloxacin safety update                   metabolite, morphine, which relieves pain
Singapore — Moxifloxacin (Avelox® and        or cough. Limited evidence suggests that
Vigamox®) is a broad-spectrum antibac-       individuals with a specific CYP2D6
terial that is available locally.            genotype (otherwise known as ultra-rapid
                                             metabolisers) may convert codeine to



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Who drug information vol2

  • 1.
  • 2. WHO Drug Information Vol 23, No. 2, 2009 World Health Organization WHO Drug Information Contents Pharmacovigilance Focus Sodium valproate and fetal malformations 113 Abacavir: determining risk of heart attack 114 Biosimilar medicines and safety: new Carbamazepine: serious adverse skin challenges for pharmacovigilance 87 reactions 114 Electronic adverse reaction reporting tool 115 Blood and Biomedicines Intensive monitoring of varenicline 116 Availability, quality and safety of blood and blood products 95 Regulatory Action and News Influenza virus vaccines: 2009–2010 New Regulatory Challenges season 117 Contribution of clinical pharmacologists Sale of efalizumab suspended 117 to government: opportunities and Efalizumab: voluntary withdrawal 118 challenges 99 Oseltamivir: extension of shelf life 118 Antiviral medicines in an influenza pandemic 119 Safety and Efficacy Issues European Union and Health Canada: Etanercept: histoplasmosis and invasive confidentiality arrangement 119 fungal infections 104 Ixabepilone: withdrawal of application Zonisamide: metabolic acidosis 104 for marketing authorization 120 Progressive multifocal leuko- Peginterferon alfa–2b: withdrawal of encephalopathy 105 application for marketing authorization 120 Severe adverse reactions with Levodopa/carbidopa/entacapone: intravenous immunoglobulin 105 withdrawal of application for Exanatide: risk of severe pancreatitis extension of indication 120 and renal failure 106 Benefits of methylphenidate continue to Medicines Strategy outweigh risks 106 Chromic phosphate P32: acute and Policies lymphocytic leukaemia 107 Good Governance for Medicines Warning for metoclopramide-containing Programme 122 drugs 108 Metabolic effects of antipsychotics 108 Cefaclor and serum sickness-like Recent Publications, reactions in children 108 Information and Events Toremifene: prolongation of QTc interval 109 ASEAN: mutual recognition arrangement Atomoxetine: risk of psychotic or manic for GMP 127 symptoms 109 Losing artemisinin? 127 Lignocaine with chlorhexidrine gel: International drug price indicator guide 128 anaphylaxis 110 Moxifloxacin safety update 110 Codeine toxicity in breastfed infants 110 Proposed International Atypical antipsychotics: risk of stroke 111 Biphosphonates: atypical stress fractures 112 Nonproprietary Names: 129 Effects of MRI on implantable drug pumps113 List 101 85
  • 3. World Health Organization WHO Drug Information Vol 23, No. 2, 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) 86
  • 4. WHO Drug Information Vol 23, No. 2, 2009 Pharmacovigilance Focus Biosimilar medicines and Biological medicinal products (biopharma- ceuticals) have a successful record in safety: new challenges for treating many life threatening and chronic pharmacovigilance diseases. However, their cost has often been high, thereby limiting their access to Regulatory experience of approving and patients, notably in developing countries. monitoring the safety of biosimilar medi- More recently, the expiration of patents cines varies across the world. Recently, and/or data protection for the first major the European Union (EU) took the lead in group of innovative biotherapeutics is establishing a transparent regulatory stimulating development of products process for approving biosimilars. To “similar” to the original biological products date, the EU has approved a number of which rely for their licensing, in part, on biosimilars such as formulations of data from originator products licensed on somatotropin, epoietin and, most recently, a full registration dossier. filgrastim. The prevailing view among regulators is that proteins are much more A variety of terms, such as ‘biosimilars’, complex than small molecule medicines ‘follow-on protein products’ and ‘subse- and it may not be possible to demonstrate quent-entry biologics’ have been used by the identical nature of two biological different jurisdictions to describe these products originating from different manu- products. The term ‘generic’ medicine is facturing sources solely based on quality used extensively for chemical, small information. molecule medicinal products that are structurally and therapeutically equivalent This has led to the view that follow-on to an originator product whose patent biological products manufactured by and/or data protection period has expired. generic manufacturers after expiry of patent and other exclusivity rights cannot Current situation be approved using the same simplified In many countries, a regulatory pathway regulatory procedures as applied for for the approval of generic medicines has small molecule-based generic drugs. been established. Since biological medici- Generating additional nonclinical and nal products consist of large and highly clinical data to demonstrate that these complex molecular entities that are medicines have an equivalent, or similar, difficult to characterize, the approach safety and efficacy profile to the originator established for small molecule generic product is needed. However, several medicines is not fully appropriate for parties have raised concerns that such development, evaluation and licensing of regulatory procedures may not be enough biosimilars — as they are called in the to ensure the safety and efficacy of these EU. The fine structure of a biotherapeutic products. This article gives an overview of medicine is very sensitive to various regulatory experience as well as the main production parameters and the full principles and issues concerning quality, understanding of all processes involved is safety and efficacy of these products. complicated. Thus, it is unlikely that one * This article does not necessarily reflect the policies and views of the World Health Organiza- tion. 87
  • 5. Pharmacovigilance Focus WHO Drug Information Vol 23, No. 2, 2009 manufacturer will be able to precisely regulation was formally recognized by the reproduce a biotherapeutic medicine World Health Organization (WHO) in manufactured by another company. 2007. Since then, WHO has been work- Indeed, an increasingly wide range of ing with regulators from many countries biosimilars are under development or on a draft document that provides guid- already licensed in many countries. ance for the development and evaluation of biological therapeutic products that As stated, the EU has taken the lead in may be subject to abbreviated licensing establishing a regulatory process for pathways [11]. The document is expected approving biosimilars and EU legislation to be finalized later in 2009. now differentiates between “generic medicinal products” and “similar biological Generic medicines and biosimilars: medicinal products”. It also defines the similarities and differences regulatory approach for EU marketing Multisource (generic) medicines are authorization of biosimilar medicinal formulated when patent and other exclu- products. Both general [1–3] and product- sivity rights expire. These medicines have specific guidelines dealing with recom- an important role to play in public health binant erythropoietin [4], granulocyte as they are well known to the medical colony stimulating factor (G-CSF) [5], community and usually more affordable human somatotropin [6] and human due to competitive availability. insulin [7] have been issued by the Committee for Medicinal Products for The key requirement for authorization of Human Use (CHMP) of the European generic medicines is therapeutic inter- Medicines Agency (EMEA). Draft guide- changeability with the originator product. lines have also been issued for interferon To ensure therapeutic interchangeability, alfa [8] and low molecular weight generic products must contain the same heparins [9]. All these guidelines have amount of active ingredient and have the one common feature — identifying the same dosage form and be bioequivalent need for at least some clinical data to to the originator product. Bioequivalence support the approval of biosimilar medici- is usually established using comparative nal products. in vivo pharmacokinetic studies with the originator product (or reference product). In the USA, there is currently no set of A detailed description of how this is guidelines comparable to those of the EU carried out is described in respective for biosimilars. The Food and Drug WHO and national regulatory guidelines Administration (FDA) has approved [12, 13]. Well-resourced regulatory Omnitrope®, a growth hormone biosimilar, authorities require that a multisource but this was done using the abbreviated (generic) medicine must meet certain new drug application (ANDA) procedure regulatory requirements. In a well estab- which essentially defines biosimilars as lished setting, a generic medicine in “chemical” generic drugs rather than general must: biopharmaceuticals [10]. However, this method of approval is rather exceptional • contain the same active ingredients as as specific US regulatory guidelines for the innovator drug; approval of biosimilars do not currently exist. Also, in most other countries a • be identical in strength, dosage form, comparative set of guidelines to those of and route of administration; the EU is absent. • have the same use indications; The need for additional global regulatory • be bioequivalent (as a surrogate marker guidelines for evaluation and overall for therapeutic interchangeability). 88
  • 6. WHO Drug Information Vol 23, No. 2, 2009 Pharmacovigilance Focus • meet the same batch requirements for necessarily implies different host cell identity, strength, purity and quality, and impurities as a minimum but the regulator has accepted the product as biosimilar • be manufactured under the same [14]. Differences with other products have standards of good manufacturing been justified as being within the range of practice (GMP) required for innovator natural variants without major clinical products. impact. Traditional generic medicines are small, Originator products can go through a organic molecules with a well-character- number of variations during product ized structure which can be more easily development and the post marketing defined by their atomic structure than period. However, it is difficult to ascertain their manufacturing processes. In the whether major process variations (e.g. case of more complicated generic medi- cloning, selection of a suitable cell line, cines, processes of synthesis are used. fermentation, purification and formulation) For example, biotechnological methods will affect the end product. Thus, a bio- are applied to produce large molecule similar may differ significantly from the medicines such as antibiotics (for exam- originator product. In principle, some of ple, streptomycin). Sometimes, several the variations applied by originators can methods of synthesis are combined, be more substantial than those applied by including the use of genetically engi- generic manufacturers. When assessing neered microorganisms in fermentation. and accepting variations applied to the What makes a difference is how well the manufacture of originator products, resulting active pharmaceutical ingredient regulators can acquire valuable informa- (API) can be characterized without risking tion for assessing biosimilars. unidentified impurities and subtle struc- tural changes resulting in different safety At present, lack of consistency between and efficacy profiles. originator epoietins and products manu- factured in countries outside well regu- The current challenge facing international lated markets (such as the EU and USA) development of a programme for bio- was demonstrated at the World Congress similars is that there is no way of confirm- of Nephrology in 2007 [15, 16]. Some ing that the reference product on the products were identified as containing market in one region complies with additional basic isoforms — more than requirements in other regions. It is true 4% aggregates and bacterial endotoxin that even identifying a global comparator contamination. These findings may affect for generic “chemical” medicines is efficacy, immunogenicity and patient sometimes very challenging. Above all, safety, respectively [16, 17]. Finally, some the essential characteristics of a bio- of these biosimilar products were not similar are not yet perfectly defined. For approved under a specific well-defined example, some consider that only fully and transparent regulatory framework. characterized proteins with no major Biopharmaceutical safety and efficacy differences in their structure or impurity data are difficult to transcribe into a profile can be considered biosimilar. discernable format and it is a challenge However, EU regulators have accepted a demonstrating that a biosimilar product is degree of difference provided it can be as safe or effective as the originator. It is justified. For example, Valtropin® (soma- hoped that rapid advances in science and totropin) is expressed from yeast whereas knowledge obtained from regulatory its reference product, Humotrope®, is practice may make this task easier in the expressed from Escherichia coli. This future. 89
  • 7. Pharmacovigilance Focus WHO Drug Information Vol 23, No. 2, 2009 Safety of biosimilars: specific Another important factor is potential points of concern contamination during manufacturing. The two main issues of concern with Impurities in biopharmaceuticals may biosimilar agents involve variable po- derive from chemicals or antibiotics used tency/response and immunogenicity during manufacture or may result from thought to be due to one of three main microbial or viral contamination. Impurities mechanisms: glycosylation, contamina- such as endotoxins or denatured pro- tion or changes to three-dimensional teins, for example, may give a danger structure. Immunogenicity is generally the signal to T cells which may then send primary safety concern, but variation in activating signals to B cells leading to an potency can also raise safety issues in immune response. the case of substitution of the original molecule with biosimilars, e.g. variability An important lesson was learned in the in haemoglobin values seen with original case of an increasing incidence of anti- epoietin [18] and its possible association body-mediated pure red cell aplasia with increased mortality in dialysis pa- (PRCA) observed outside the USA tients [19]. The issues of safety and between 2000 and 2002 which revealed efficacy cannot easily be separated as that a small change in the formulation of a binding of an agent by immune system well-established innovator biopharma- molecules will often decrease its clinical ceutical product (epoietin alfa) with effect and changes to the shape or extensive patient years experience may structure of a protein can alter binding to have significant clinical consequences immune system receptors as well as to its [22]. The sharp increase in incidence physiological target. Therefore, biosimi- occurred primarily among those on lars could induce immune responses Eprex®/Erypo®, and coincided with which may be either clinically irrelevant or replacement of human serum albumin as could have severe and potentially lethal a stabilizer by glycine and polysorbate 80. consequences. Subsequent withdrawal of the SC formu- lation of epoietin alfa led to a consider- The glycosylation of recombinant proteins able decrease in the incidence of PRCA can influence degradation, exposure of cases. A number of possible mechanisms antigenic sites and solubility, as well as have been proposed to explain the immunogenicity. Changes in degradation observed upsurge of PRCA but it is likely can produce novel antigenic epitopes not the modification in formulation played a found in the parent molecule with poten- major role [23]. tially increased immunogenicity and biological activity and metabolic half-life Alterations to the three-dimensional also affected. The degree of glycosylation structure of a protein may also have depends primarily on the host cell expres- important effects on immunogenicity. sion system. For example, recombinant Major sources of such changes include G-CSF expressed in Escherichia coli is protein aggregation (which has been non-glycosylated, whereas that ex- suggested as one possible explanation of pressed in Chinese hamster ovary cells is the PRCP epidemic described above), glycosylated. Similarly, proteins manufac- oxidation and deamidation. Likely aggre- tured in yeast cells contain high levels of gation is of particular concern as it may mannose sugar groups, rendering them lead to the immune system recognizing more prone to degradation and thereby the protein as non-self and mounting a decreasing their half-life. [See references response [24]. This is probably because 20 and 21 for more details about effects the repeating structure of protein aggre- of immunogenicity.] gates more closely resembles the micro- 90
  • 8. WHO Drug Information Vol 23, No. 2, 2009 Pharmacovigilance Focus bial structures that the immune system is even very small changes in manufactur- primed to act against [25]. The process ing can have major consequences for a by which the body becomes reactive to product’s adverse effects [27]. Pharma- the protein can be very slow: antibodies covigilance is thus likely to be a long-term to products such as interferon and eryth- project for any biosimilar medicine. ropoietin may be detected for more than a Overall, routine pharmacovigilance is year after treatment cessation [26]. recommended for products where no special concerns have arisen, whereas Clinical safety data additional pharmacovigilance activities and pharmacovigilance and action plans will be required for The concerns raised above have been medicinal products with important estab- addressed, as far as possible and in line lished risks, potential risks or missing with present scientific knowledge, in EU information. regulatory guidance. For example, erythropoietin is a more complex mole- Spontaneous reporting still remains the cule compared to either insulin or growth cornerstone of pharmacovigilance but has hormone. The respective guidelines several weaknesses. Often, only the reflect this complexity and, in order to international nonproprietary name (INN) identify potential immunogenicity, advo- is used as the sole product identifier and cate conducting at least two randomized in the case of several products with the controlled trials confirming safety data same INN (originator, plus generics or collected over a minimum of 12 months biosimilars) it may be difficult to trace the from at least 300 patients. Within the EU exact manufacturer of the product. A authorization procedure, the applicant much better traceability of products is should present a risk management needed [28], particularly in the case of programme/pharmacovigilance plan in biosimilars. accordance with current EU legislation and pharmacovigilance guidelines. Recent developments within the Interna- tional Conference on Harmonization of In order to further study the safety profile Technical Requirements for Registration of the biosimilar medicinal product, data of Pharmaceuticals for Human Use (ICH) for rare adverse events should be col- raise hopes that a harmonized set of lected from a cohort of patients represent- product identifiers will become available ing all approved therapeutic indications. soon and could improve future traceabil- Specific reference is made to include ity. Recently, the ICH Steering Committee assessment of the incidence of PRCA recognized the benefits of continuing to within the pharmacovigilance plan for work with International Standard Develop- epoietin biosimilars [4]. It is clear that with ment Organizations in developing harmo- 300 patients PRCA may not be detected nized electronic messages to transfer due to the relatively small number of regulatory information with a view to patients involved as compared to the developing harmonized formats for rarity of this complication. Consequently, Individual case safety reports (ICSR) and EMEA guidelines for epoietins also identification of medicinal products [29] require immunogenicity testing and pharmacovigilance programmes to Different versions of biopharmaceuticals monitor the efficacy and safety of have been available in both India and biosimilar products during post-approval. China for several years [30]. It is impor- tant to note that both India and China are Nonetheless, some adverse effects may considered to have less stringent regula- take more than a year to appear [26] and tory standards than the EU and the USA. 91
  • 9. Pharmacovigilance Focus WHO Drug Information Vol 23, No. 2, 2009 Unfortunately, both countries have under- but patients should not be expected to developed pharmacovigilance systems bear the burden of excessive trial-error and provide only small number of adverse incidents. drug reaction reports to the WHO Interna- tional Programme on Drug Monitoring References database managed by the Uppsala 1. European Medicines Agency. Guideline on Monitoring Centre [31]. Similar Biological Medicinal Products, CPMP/ 437/04, October 2005. www.emea.europa. eu/ Conclusions pdfs/human/biosimilar/043704en. The cost of providing effective therapies in different disease areas increases 2. European Medicines Agency. Guideline on progressively and biosimilar medicines Similar Biological Medicinal Products Contain- ing Biotechnology-derived Proteins as Drug may offer considerable advantages to Substance – Non Clinical and Clinical Issues, hard-pressed health-care budgets glo- CHMP/42832/05, February 2006. www.emea. bally. Regulatory decisions to permit europa.eu/pdfs/human/biosimilar 4283205en. clinical use should be based on rigorous and highly competent case by case 3. European Medicines Agency. Similar scientific assessments and presence of Biological Medicinal Products Containing appropriate systems for pharmacovigi- Biotechnology-derived Proteins as Active Substance: Quality Issues, CHMP/49348/05, lance. Clearly this area of rapidly evolving February 2006. www.emea.europa.eu/pdfs/ regulatory science would benefit from human/biosimilar/4934805en. better cooperation and information exchange between different regulators 4. European Medicines Agency. Annex internationally. Safety has to come first Guideline on Similar Biological Medicinal and effective pre- and post-marketing Products Containing Biotechnology-derived safety monitoring remains the key. Proteins as Drug Substance – Non Clinical and Clinical Issues containing Recombinant Human Erythtropoietin, CHMP/94526/05, Sufficient regulatory tools are currently March 2006. www.emea.europa.eu/pdfs/ available to ensure safety of biosimilars human/biosimilar/9452605en. but the proper implementation of these tools may prove challenging, particularly 5. European Medicines Agency. Annex outside well established and resourced Guideline on Similar Biological Medicinal regulatory settings. Even in the EU, Products Containing Biotechnology-derived applying pharmacovigilance programmes Proteins as Drug Substance –Non Clinical and with uniform excellence across the region Clinical Issues containing Recombinant remains a challenge. Pharmacovigilance Granylocyte Colony-Stimulating Factor, CHMP/313297/05, February 2006. www. is a responsibility that is shared among emea.europa.eu/pdfs/human/biosimilar/ actors in the pharmaceutical industry, 313297/05en. physicians and pharmacists, with input from appropriately educated and informed 6. European Medicines Agency. Annex patients. Much better cooperation be- Guideline on Similar Biological Medicinal tween all stakeholders is needed to Products Containing Biotechnology-derived ensure that everyone involved fully Proteins as Drug Substance – Non Clinical understands the complex scientific and Clinical Issues containing Recombinant arguments and regulatory decisions Human Growth Hormone, CHMP/94528/05, applying to biosimilar products. This February 2006. www.emea.europa.eu/pdfs/ human/biosimilar/9452805en. would hopefully lead to safer use and better qualitative and quantitative report- 7. European Medicines Agency. Annex ing of suspected adverse reactions. Guideline on Similar Biological Medicinal Biosimilar medicines clearly have a future Products Containing Biotechnology-derived 92
  • 10. WHO Drug Information Vol 23, No. 2, 2009 Pharmacovigilance Focus Proteins as Drug Substance – Non Clinical 16. Singh AK. Gaps in the quality and potential and Clinical Issues. Guidance on Similar safety of Biosimilar epoetins in the developing Medicinal Products Containing Recombinant world: an international survey. Abstract S-PO- Human Insulin CHMP/BMWP/32775/05, 0412. World Congress of Nephrology, April February 2006. www.emea.europa.eu/pdfs/ 21–25, 2007, Brazil, Rio de Janeiro. Available human/biosimilar/3277505en. at: http://www.wcn2007.org 8. European Medicines Agency. Guideline on 17. Hermeling S, Schellekens SH, Crommelin Similar Biological Medicinal Products Contain- DJ et al. Micelle-associated protein in epoetin ing Low-molecular Weight Heparins EMEA/ formulations: a risk factor for immunogenicity? CHMP/BMWP/118264/07. Draft released for Pharm Res 2003, 20:1903–1907. consultation in April 2008. www.emea.europa. eu/pdfs/human/biosimilar/11826407en. 18. Berns JS, Elzein H, Lynn RI et al. Hemoglobin variability in epoetin-treated 9. European Medicines Agency. Guideline on hemodialysis patients. Kidney Int 2003 Similar Biological Medicinal Products Contain- 64:1514–1521. ing Recombinant Interferone Alpha EMEA/ CHMP/BMWP/102046/06. Draft released for 19. Yang W, Israni RK, Brunelli SM, et al. consultation in October 2007. www.emea. Hemoglobin variability and mortality in ESRD. europa.eu/pdfs/human/biosimilar/ J Am Soc Nephrol 2007 18:3164–3170. 10204606en. 10. Belsey MJ, Harris LM, Das RR et al. 20. Kessler M, Goldsmith D, Schellekens H. Biosimilars: initial excitement gives way to Immunogenicity of biopharmaceuticals. reality. Nat Rev Drug Discov 2006, 5:535–536 Nephrology Dialysis Transplantation 2006 21(5:v9-v12). http://ndt.oxfordjournals.org/cgi/ 11. World Health Organization. Regulatory content/full/21/suppl_5/v9 pathways for biosimilar products. WHO Drug Information 2008 22(1). www.who.int/ 21. Biosimilars and biopharmaceuticals: what druginformation the nephrologists need to know—a position paper by the ERA–EDTA Council. Nephrology 12. World Health Organization. Multisource Dialysis Transplantation 2008 23(12):3731– (generic) pharmaceutical products: guidelines 3737 http://ndt.oxfordjournals.org/cgi/content/ on registration requirements to establish inter- full/23/12/3731 changeability. In: WHO Expert Committee on Specifications for Pharmaceutical Prepara- 22. Casadevall H, Nataf J, Viron B et al. Pure tions. Fortieth Report. Technical Report red-cell aplasia and anti-erythropoietin Series, 937, Annex 7, 347–390. antibodies in patients treated with recombinant erythropoietin. N Engl J Med 2002 346:469– 13. European Medicines Agency. Guideline on 475. the Investigation of Bioequivalence, CPMP/ EWP/QWP/1401/98 Rev. 1. Draft released for 23. Schellekens H. Immunologic mechanisms consultation in July 2008. www.emea.europa. of EPO-associated pure red cell aplasia. Best eu/pdfs/human/qwp/140198enrev1. Pract Res Clin Haematol 2005 18:473–480. 14. European Medicines Agency. Valtropin. 24. Rosenberg AS. Effects of protein aggre- European Public Assessment Report, Revi- gates: an immunologic perspective. AAPS sion 1. www.emea.europa.eu/humandocs/ Journal 2006 8: E501–E507. Humans/EPAR/valtropin/valtropin.htm. 25. Schellekens H. Immunogenicity of thera- 15. Park SS, Deechongkit S, Patel SK. peutic proteins: clinical implications and future Analytical comparisons of certain erythropoi- prospects. Clin Ther 2002 24:1720–1740. etin products from Asia and Amgen’s epoetin alfa. Abstract M-PO-0592. World Congress of 26. Schellekens H. The first biosimilar epoetin: Nephrology, April 21–25, 2007, Rio de but how similar is it? Clin J Am Soc Nephrol Janeiro, Brazil. Available at: http://www.wcn 2008 3:174–178. 2007.org 93
  • 11. Pharmacovigilance Focus WHO Drug Information Vol 23, No. 2, 2009 27. Schellekens H. Erythropoietic proteins and Brussels, Belgium, Novermber 8–13, 2008, antibody-mediated pure red cell aplasia: a http://www.ich.org/cache/compo/276-254- potential role for micelles. Nephrol Dial 1.html Transplant 2004 19:2422. 30. Frost and Sullivan. Biogenerics demand to 28. Lamarque V, Merle L. Generics and go up in Asia. Express Pharma Pulse October Substitution Modalities: Proposed Methods for 7 (2004), Available at: http://www.express the Evaluation of Equivalence, Traceability pharmaonline.com/20041007/biogenerics01. and Pharmacovigilance Reporting. Thérapie 2008 63:311–319 31. The Uppsala Monitoring Centre. http:// www.who-umc.org/DynPage.aspx 29. ICH Steering Committee Press Release. Evolving Science in Drug Safety and Quality, 94
  • 12. WHO Drug Information Vol 23, No. 2, 2009 Blood and Biomedicines Availability, quality and manufacture of medicinal products and in supply of other blood components such safety of blood and blood as platelets and red cells. products Developed countries have implemented Blood has been collected, stored, tested, procedures, policies and methods to and transfused as a therapeutic since the ensure the safety, quality and availability beginning of the Twentieth century. Until of all products derived from blood. This the 1950s, activities concentrated on has facilitated wider access to a compre- improving storage of cells and ensuring hensive range of safe blood products for blood group compatibility. Thereafter, patients with bleeding, immunological or methods were developed for preparing other severe diseases. Additionally, good therapeutic products from human blood manufacturing practices (GMP) have and plasma, for use in treating life- been introduced into plasma fractionation threatening diseases, and to support centres and are now also applied in blood complex surgical procedures and trans- establishments. Improvements in health plantation. and transfusion safety have been docu- mented by haemovigilance and phar- For the past 25 years, efforts have macovigilance programmes. Conversely, focused on improving the safety and comparable levels of availability, quality efficacy of components derived from and safety do not yet exist in many blood and plasma, developing and developing countries (1). validating new methods, and seeking new therapeutic uses. Blood products such as Equitable and universal access to blood blood clotting factors and human and blood products of assured quality immunoglobulins (polyvalent and specific) and efficacy will contribute to achieve- are now included in the World Health ment of the UN Millennium Development Organization’s (WHO) Model List of Goals relating to reduction of maternal Essential Medicines. This reflects the and child mortality, as well as to efforts to importance of blood and blood products prevent HIV, HBV and HCV transmission. in treating congenital, immune-acquired life-threatening diseases, and conditions Specific issues requiring such as bleeding or trauma. In vitro action diagnostic devices for sensitive detection of infectious disease markers play a role Wastage of blood plasma in successfully screening donor blood and Several reasons account for the lack of testing plasma pools prior to fractionation, blood products in developing countries. as well as in clinical diagnosis. Plasma collected in developed countries is restricted and the potential for generat- Transmission of infectious diseases by ing surplus products sufficient to meet the blood (notably HIV, hepatitis B (HBV) and needs of developing countries is small. hepatitis C (HCV)) has underscored the Moreover, such products would be too importance of quality systems and effec- expensive. Developing countries must tive regulation in the preparation of therefore create their own sustainable plasma as a raw material for use in the supplies of blood products using blood 95
  • 13. Blood and Biomedicines WHO Drug Information Vol 23, No. 2, 2009 plasma collected by their own blood material. Substantial improvement will establishments from their own popula- prevail through introduction and enforce- tions. Currently, however, a large percent- ment of appropriate independent and age of the plasma collected in developing transparent quality assurance regulations countries is categorized as a waste and inspection procedures. material and destroyed. This is because appropriate technology and enforcement Cross-border threats of GMP are not available. Fractionation The risks of disease migration are esca- capacity could, however, become avail- lating due to changes in habitat, increas- able if plasma production complied with ing mobility of populations, wars and internationally-agreed standards. global climate change. Pandemic infec- tions may also affect the supply of blood Risk of transfusion-transmitted and blood products in different ways. diseases These factors underscore the need to If rigorous standards for donor selection, introduce and strengthen quality assur- testing and donation are not applied, ance regulations in developing countries. blood products and blood transfusion The trend towards global regulatory remain potent vectors for transmission of convergence favours sharing of best infectious diseases. Unfortunately, current practices and the creation of internation- arrangements for blood plasma collection, ally agreed regulations. International processing and testing are inadequate in coordination, notably in areas such as the a vast number of developing countries. In manufacture of blood products, is there- addition, increasing international mobility fore becoming increasingly important. of populations and globalization of the blood industry highlight the need to WHO activities introduce and strengthen quality assur- For more than 50 years, WHO has been ance regulations. closely involved in setting quality and safety standards and training regulators The history of blood transfusion has in the manufacture and quality control of amply demonstrated the risks. Examples biological and blood products. The overall include transmission of HIV, HCV and technical responsibility for these activities HBV, bacteria, trypanosoma and malarial lies with the WHO Expert Committee on parasites, as well as emerging and re- Biological Standardization (ECBS). emerging diseases. Although worldwide Guidelines on the manufacture and expansion of human blood plasma quality control of blood and blood prod- collection and processing of blood prod- ucts have been developed, updated and ucts has the capacity to save lives, promoted by WHO (2–4). They represent without appropriate control and standardi- global consensus on the part of manufac- zation it can also amplify public health turers, regulators, professional interna- risks. tional societies and national blood pro- grammes with respect to production and Poor regulation of blood products in quality assurance procedures for blood developing countries and blood products. Developing countries recognize the need to regulate blood products and assure International biological reference prepara- blood safety. Blood establishments tions (5) to assist in establishing the should be subject to inspection and audit quality and safety of blood products and by national regulatory authorities and related in vitro diagnostic devices have fractionators should demonstrate effective also been adopted following validation in control and traceability of plasma raw global coordinated studies. The value of 96
  • 14. WHO Drug Information Vol 23, No. 2, 2009 Blood and Biomedicines reliable internationally agreed reference As a first step, up-to-date mechanisms for materials is that manufacturers, regula- implementing and enforcing quality tors and blood establishments can standards relating to blood products and compare results worldwide despite the blood safety-related in vitro diagnostic increasing diversity of products. devices will need to be introduced in countries. Activities should be supported Public health challenges demonstrate the by WHO guidelines for the production of need for international collaboration and blood plasma for fractionation, comple- cooperation and the need to create mented with additional guidelines to regulatory networks to support dissemina- promote and support implementation of tion of regulatory actions, knowledge GMP. Work should also be undertaken to transfer and organization of training review existing national regulations for programmes. The International Confer- blood products and to support and further ence on Drug Regulatory Authorities develop technical upgrading of medicines (ICDRA) provides regulatory authorities of regulatory authorities. Furthermore, WHO Member States with a forum to strategies should be sought to share the meet and discuss ways to strengthen expertise and experience already gener- collaboration. In 2005, the WHO Blood ated in developed countries and to Regulators Network was established in develop regional regulatory networks. response to the request by ICDRA participants and the ECBS. The Network The dimension and complexity of the was set up to foster development of situation requires a multifaceted strategy international consensus on effective incorporating input from partners at regulatory approaches. national, regional and international levels. Recognizing the importance of the WHO is well placed to secure the support provision of safe blood, blood compo- of international and nongovernmental nents and plasma derivatives, the Fifty- organizations, international professional eighth World Health Assembly in 2005 associations and other agencies devoted (Resolution 58.13) expressed its support to finding solutions for health problems. for “full implementation of well organized, nationally coordinated and sustainable Creating sustainable blood and plasma blood programmes with appropriate programmes with appropriate regulatory regulatory systems” and stressed the role systems will ensure both specific and of “voluntary, non-remunerated blood wider public health benefits including: donors from low-risk populations”. • optimal use of donated blood plasma; Improving access to blood • safer blood components; and blood products • sustainable and affordable supply of In order to ensure the availability of safe safe essential products for the treatment blood products in developing countries, of congenital diseases, trauma and Member States should be alerted to the immunologically mediated conditions; risks of inadequate regulation and guid- ance should be provided on establishing • reduction of infectious disease transmis- regulatory oversight of blood systems. sion via blood-borne pathogens, both Efforts should be made to increase the within countries and across national transfer of validated technology and to borders; build capacity with the overall aim of improving access to safe, effective and • improved quality and safety of all affordable blood products. products from blood establishments 97
  • 15. Blood and Biomedicines WHO Drug Information Vol 23, No. 2, 2009 through the enforcement of national References (and international) quality assurance regulations; 1. Global Database on Blood Safety. http://www.who.int/bloodsafety/global_ • substantial contribution to national/ database/en/ regional public health programmes through, for example, improved popula- 2. World Health Organization. Requirements tion epidemiology for infectious dis- for the collection, processing and quality control of blood, blood components and eases such as HIV, HBV and HCV, plasma derivatives. Technical Report Series, prevention and control of disease No. 840 (1994). transmission, and blood donor health monitoring; 3. World Health Organization. WHO Recom- mendations for the production, control and • potential application of quality systems regulation of human plasma for fractionation. and GMP principles to other medical Technical Report Series, No. 941 (2007). laboratory disciplines, and 4. World Health Organization. Guidelines on • inclusion of developing countries in the viral inactivation and removal procedures international transfusion community and intended to assure the viral safety of human in activities of associated plasma blood plasma products. Technical Report fractionation industries. Series, No. 924 (2004). The strategic goal is to improve public 5. World Health Organization. WHO Interna- health by providing safe and effective tional Biological Standards: http://www.who. medicine to the world’s population. A risk– int/bloodproducts/catalogue/en/index.html benefit analysis must ensure that suffi- cient quantities of the required products are available at a cost that does not limit access. 98
  • 16. WHO Drug Information Vol 23, No. 2, 2009 New Regulatory Challenges Contribution of clinical pharmacologists to government: opportunities and challenges . Clinical pharmacology is a scientific discipline that focuses on evaluating the effect of medicines in humans. Within a wider context of promoting safety, maximizing efficacy and minimizing side-effects, the work of the clinical pharmacologist is par- ticularly valuable in clinical trials. Other branches of the discipline involve pharma- covigilance, pharmacokinetics, drug metabolism, pharmacoepidemiology and, more recently, pharmacoeconomics. The clinical pharmacologist collaborates closely with other clinicians, pharmacists, biologists, analytical chemists, statisticians, epidemi- ologists and health economists. The clinical pharmacologist receives training in the evaluation of drug therapy and drug products and this makes the profession valu- able in a number of public activities such as drug approval, post-marketing surveil- lance, drug therapy selection, reimbursement decisions and ethical review of re- search projects. Faced with the task of regulating increasingly complex medicines and biomedicines markets, many regulatory authorities and health departments in developing coun- tries rely for advice on pharmacists who may have a limited medical background and lack the resources to access and assess information on the latest clinical research. On the other hand, clinical pharmacologists have a rigorous medical and scientific training which enables them to evaluate evidence and produce new data through well designed studies and interaction with other healthcare professionals. A clinical pharmacologist can provide the link between government and health care outcomes, serving also as a powerful advocate of evidence-based medicine. They can be in- valuable in addressing current challenges such as assessing new medicines, pro- viding unbiased medicines-related information, contributing to treatment guideline development, identifying preventable adverse drug reactions through promoting ra- tional use of medicines and improving prescribing practices. Politicians are often unaware of the valuable role that clinical pharmacology can play in improving per- formance of regulatory and health systems through closing the gap between current medical practices and latest clinical science. Regulation and clinical tary and provide the means of attaining pharmacology: emerging the health and wellbeing of citizens. alliances In a broad sense, the role of regulatory As a function of protecting and promoting agencies is multidimensional. The World public health, a government must con- Health Organization (WHO) proposes that sider the ethical, scientific and develop- regulatory goals are achieved through mental aspects of medicines. Activities in ensuring the safety, efficacy and quality of these three dimensions are complimen- medicines, rational use, and providing 99
  • 17. New Regulatory Challenges WHO Drug Information Vol 23, No. 2, 2009 appropriate medicines information to the many essential and interrelated activities public and health professionals (1). which underpin the most important role of Similarly, the European Medicines the government in the broader sense: i.e., Agency (EMEA) coordinates the work of to protect the health and wellbeing of its national experts and has inter alia the citizens through ensuring and promoting following far reaching responsibilities (2): effective public health. “In the context of continuing globaliza- Governments and their respective institu- tion, to protect and promote public and tions are responsible for ensuring basic animal health by: human rights of citizens. In the event of research conducted within a country, they • developing efficient and transparent are expected to protect patients and trial procedures to allow rapid access by participants by maintaining effective users to safe and effective innovative systems for granting clinical research medicines and to generic and nonpre- authorization and oversight of trials. This scription medicines through a single challenging task involves assessment of European marketing authorization; whether the clinical research planned is based on scientific principles and consid- • controlling the safety of medicines for erations of safety and whether it will offer humans and animals, in particular the desired benefits to patients while through a pharmacovigilance network identifying and minimizing any possible and the establishment of safe limits for risks. This task forms the ethical dimen- residues in food-producing animals; sion of the government’s role. • facilitating innovation and stimulating Milestones in the current research, hence contributing to the ethical research environment competitiveness of the EU-based The International Covenant on Civil and pharmaceutical industry, and Political Rights (1966) states that ... “no one shall be subjected without his free • mobilizing and coordinating scientific consent to medical or scientific experi- resources throughout the EU to provide mentation”. These principles were devel- high-quality evaluation of medicinal oped with a particular focus on risk/ products, to advise on research and benefit in the World Medical Association’s development programmes, to perform Declaration of Helsinki and have been inspections for ensuring fundamental incorporated into national and interna- GXP (good clinical practice, good tional laws and regulations. manufacturing practice and good In 1949, the Council for International laboratory practice collectively) provi- Organizations of Medical Sciences sions are consistently achieved, and to (CIOMS) was founded under the aus- provide useful and clear information to pices of WHO and the United Nations users and healthcare professionals. Educational, Scientific and Cultural Organization (UNESCO). The most The ethical dimension important of CIOMS publications is its In addition to their role in ensuring the International Ethical Guidelines for safety, efficacy and quality of medicines, Biomedical Research Involving Human governments are also tasked with the Subjects. The latest version was pub- responsibility of exerting an ethical lished in 2002 (3) and, based on the influence on processes in the develop- Declaration of Helsinki, is designed to be ment and marketing of medicines. The of use in defining the ethics of biomedical regulatory authority is responsible for research, applying ethical standards in 100
  • 18. WHO Drug Information Vol 23, No. 2, 2009 New Regulatory Challenges local circumstances, and establishing or Above all, governments have to ensure redefining adequate mechanisms for that only effective and safe good quality ethical review of research involving medicines are used to treat their citizens. human subjects. The Guidelines are Nowadays, all medicines are subject to targeted to ethics committees, and review marketing authorization prior to being boards, sponsors and investigators. The prescribed. Approval is based on assess- CIOMS guidelines — to which several ment of quality, safety and efficacy of the clinical pharmacologists have contributed product. The safety monitoring of medi- — also provide the basis for government cines during their whole life-cycle (from thinking about clinical research, espe- marketing authorization to potential cially in resource poor settings. withdrawal from the market) is also a task for governments. Usually, these and other Good clinical practice (GCP) is a “stand- medicines-related regulatory functions ard for the design, conduct, performance, are carried out by specialized govern- monitoring, auditing, recording, analysis mental agencies, such as the Food and and reporting of clinical trials that pro- Drug Administration (FDA) in the USA or vides assurance that the data and re- the European Medicines Agency (EMEA). ported results are credible and accurate, and that rights, integrity and confidential- Scientific dimension ity of trial subjects are protected.” Many It is important for regulators involved in national and regional GCP guidelines are the evaluation of medicines prior to based on, or refer to, the Declaration of marketing to have the best possible Helsinki, including WHO GCP Guidelines scientific education and background or to published in 1995 (4) and the Interna- be able to call on expertise which is tional Conference of Harmonization (ICH) relevant to the work in hand. A critical GCP (E6) from 1996 (5). scientific review of the clinical data will address the known and unknown aspects A priority requirement for the ethical of an assessment and provide relevant review of a scientific study, research or conclusions. The larger regulatory agen- clinical trial involving human subjects is cies possess their own clinical pharma- submission of a research proposal for cology units. For example, the US FDA independent evaluation by scientific, has in its Center for Drug Evaluation and regulatory and ethical review committees. Research (CDER) Office of Clinical Nowadays, many governments define Pharmacology. Safety surveillance and procedural aspects of the work of the pharmacovigilance is also entrusted to ethics committees in detail. regulatory agencies, and here, also, expertise in clinical pharmacology is For example, the European Commission essential. has laid down strict timelines for process- ing research applications that affect the Governments, either directly or through work of ethical review committees in all their specialized agencies, are also 27 European Union countries. This can involved in taking decisions about medi- be perceived as the European Commis- cines selection for public procurement, sion’s attempt to facilitate and promote developing national treatment guidelines clinical research. Clinical pharmacologists and proposing inclusion of medicines in can be particularly valuable as members reimbursement lists. This work may also of the ethical review committee because involve composing and updating national of their extensive knowledge of the essential medicines lists as promoted by effects of medicines and the related area WHO. The real life performance of drugs of clinical research. following regulatory approval requires a 101
  • 19. New Regulatory Challenges WHO Drug Information Vol 23, No. 2, 2009 cost-effectiveness assessment by highly hand evidence that electronic health qualified specialists using different mod- records can offer added value for phar- els and again calls on the expertise of the macogenetic research and pharmacovigi- clinical pharmacologist. lance (7). Clinical pharmacologists should be actively involved in designing elec- These various activities support the tronic patient health records due to their rational use of medicines, sometimes also potential for future clinical research use, called “quality use” (6). Governmental including monitoring of rational use and institutions involved in such activities safety. include the National Institute for Health and Clinical Excellence (NICE) in the Government efforts to create a research United Kingdom. Activities are based on friendly environment should include legal the best possible scientific methodologies and other systems with effective function- and knowledge and are part of the ing and well-informed scientific govern- scientific dimension of the Government’s ment backup. Due to the relative lack of obligation to its citizens. Clinical pharma- new therapies and pressure from patient cologists are well prepared to meet the groups and industry, governments have challenges needed in the complex as- been exorted to grant “early market sessment of medicines. approvals” under certain preconditions. However, effective methodologies for Developmental dimension pharmacovigilance and safety studies in Lastly, governments carry the responsibil- the context of early market access have ity of improving the health of their citi- yet to be created and tested and clinical zens. Stimulating the necessary research pharmacologists have an important role and developing research capacities is to play here (8, 9). Clinical pharmacology therefore a regulatory function. Action also contributes to the discipline of should be directed to facilitating research pharmacoepidemiology, which is some- in areas where lack of effective or safer times the only available method to evalu- health care interventions impedes im- ate the benefits and risks of long term provement to public health. Recent pharmacotherapy. Similarly, pharmaco- examples provide evidence that private economics attempts to give a financial sector initiatives and funding are insuffi- cost and value to everyday medicines use cient in developing and promoting public and contributes to rational reimbursement health through medicines research. Thus, systems. governments may also be involved in providing financial support to stimulate In the implementation of these various clinical research in medicines. Clinical dimensions, governments create various pharmacologists are well positioned to tools, including laws and regulations, help make appropriate judgements on the infrastructure and institutions, with sup- scientific value of government funding of porting resource allocations. A key research proposals. resource is properly trained specialists who are capable of taking decisions An important emerging issue is the based on the best possible scientific adoption of electronic patient health methodology and evidence. These records implemented or planned to be dimensions are interrelated and interde- implemented in many countries. Although pendent. Good ethics cannot do without these may be perceived as mostly admin- good science and developmental goals istrative tools, they hold scientific poten- cannot be achieved without following tial for monitoring of safety and quality ethical principles and a sound science medicines therapy. There is already first- base. 102
  • 20. WHO Drug Information Vol 23, No. 2, 2009 New Regulatory Challenges The clinical pharmacologist is thus a 3. The Council for International Organizations unique specialist and ally who can serve of Medical Sciences (CIOMS). International the public best by ensuring that only safe Ethical Guidelines for Biomedical Research and effective medicines are authorized for Involving Human Subjects, Geneva, 2002. http://www.cioms.ch/ use, as well as facilitating cost effective prescribing and improving rational use of 4. World Health Organization. Guidelines for drugs. In order to meet the needs of good clinical practice (GCP) for trials on various governmental services and pharmaceutical products. Technical Report ensure that the best scientific knowledge Series, No. 850, 1995. http://www.who.int/ is used to make decisions, clinical phar- medicines/library/par/ggcp/GGCP.shtml macology as a discipline should be harmonized with the objectives and 5. International Conference of Harmonization policies of governments to ensure a (ICH) E6: Good Clinical Practice: Consoli- benefit to public health dated Guideline. http://www.ich.org/cache/ compo/276–254–1.html Equally, governments of emerging econo- 6. Smith AJ, McGettigan P. Quality use of mies and developing countries may medicines in the community: the Australian benefit hugely from the expertise of experience. Br J Clin Pharmacol (2000) 50(6): clinical pharmacologists and experience 515–519. has shown that a qualified clinical phar- macologist can make a great difference at 7. Wang X, Hripcsak G, Markatou M, et al. country level. Active computerized pharmacovigilance using natural language processing, statistics and References electronic health records: a feasibility study. J Am Med Inform Assoc (2009). 1. World Health Organization. WHO Policy Perspective on Medicines No 7, “Effective 8. Lesko LJ. Paving the Critical Path: How can Medicines Regulation: Ensuring Safety, Clinical Pharmacology Help Achieve the Efficacy and Quality”, November 2003. http:// Vision? Clinical Pharmacology & Therapeutics www.who.int/medicines/organization/mgt/ (2007) 81:170–177. PolicyPerspectives.shtml 9. Massol J, Puech A, Boissel JP. How to 2. EMEA Mission Statement. http:// anticipate the assessment of the public health www.emea.eu.int/mission.htm benefit of new medicines? Therapie. (2007) 62(5):427–35. 103
  • 21. WHO Drug Information Vol 23, No. 2, 2009 Safety and Efficacy Issues Etanercept: histoplasmosis Reference: Communication from Amgen. 21 April 2009 at Health Canada. http://www. hc- and invasive fungal infections sc.gc.ca/dhp-mps/medeff/advisories-avis/prof/ _2009/index-eng.php Canada — The manufacturer of etanercept (Enbrel®) has informed healthcare professionals of the risk of Zonisamide: metabolic invasive fungal infections, including acidosis histoplasmosis. Etanercept is indicated for the treatment of rheumatoid arthritis, United States of America — Following psoriatic arthritis, juvenile idiopathic a review of updated clinical data, the arthritis, ankylosing spondylitis and Food and Drug Administration (FDA) has plaque psoriasis. determined that treatment with zonis- amide can cause metabolic acidosis in There have been reports of serious some patients. Zonisamide (Zonegran® pulmonary and disseminated histoplas- and generics) is indicated as adjunctive mosis, coccidioidomycosis, blastomycosis therapy in the treatment of partial sei- infections, sometimes with fatal out- zures in adults with epilepsy. comes, in patients taking TNF blockers, including etanercept. Histoplasmosis and Chronic metabolic acidosis can have other invasive fungal infections have not adverse effects on the kidneys and on been recognized consistently in patients bones, and can retard growth in children. taking TNF blockers. This has led to Patients with predisposing conditions or delays in instituting appropriate treatment, therapies, including renal disease, severe sometimes resulting in death. respiratory disorders, diarrhoea, surgery, ketogenic diet, or certain other drugs may For a patient taking a TNF blocker who be at greater risk for developing meta- presents with signs and symptoms of bolic acidosis following treatment with systemic illness, such as fever, malaise, zonisamide. The risk of zonisamide- weight loss, sweats, cough, dyspnoea, induced metabolic acidosis appears to be and/or pulmonary infiltrates, the health- more frequent and severe in younger care professional should ascertain if the patients. Although not approved by the patient has lived or worked in or travelled FDA, zonisamide is sometimes used in to areas of endemic mycoses, and children. Metabolic acidosis increases the appropriate empiric antifungal treatment risk for slowed growth in children and may be initiated while a diagnostic could reduce the overall height that they workup is being performed. As with any achieve. serious infection, the TNF blocker should be stopped until the infection has been The FDA recommends that healthcare diagnosed and adequately treated. professionals measure serum bicarbo- nate before starting treatment and peri- Prescribers should discuss with patients odically during treatment, even in the and their caregivers the risk for infections absence of symptoms. If metabolic while receiving TNF blockers, including acidosis develops and persists, consid- infections caused by viruses, fungi, or eration should be given to reducing the bacteria including tuberculosis (TB). dose or discontinuing zonisamide (using 104
  • 22. WHO Drug Information Vol 23, No. 2, 2009 Safety and Efficacy Issues dose tapering), and modifying the pa- ously identified an association between tient’s antiepileptic treatment as appropri- PML and use of some monoclonal anti- ate. If the decision is made to continue, bodies such as natalizumab (Tysabri®, then alkali treatment should be consid- used to treat multiple sclerosis) and ered. rituximab (MabThera®, indicated for non- Hodgkin lymphoma and severe active Reference: FDA Alert, 23 February 2009 at rheumatoid arthritis). An association has http://www.fda.gov/medwatch also now been identified between PML and efalizumab (Raptiva®). Progressive multifocal leukoencephalopathy Up to 6 January 2009, the MHRA has received 19 suspected reports of PML, in United Kingdom — Progressive three of which PML was listed as the fatal multifocal leukoencephalopathy (PML) is suspected reaction. a rare and usually fatal re-infection of the CNS characterized by progressive Reference: Medicines and Healthcare damage and inflammation of the white Products Regulatory Agency, Drug Safety matter in the brain, in multiple locations. Update, Volume 2, Issue 8 March 2009 at PML is caused by a type of human http://www.mhra.gov.uk/Safetyinformation/ polyoma virus known as the JC, or John Cunningham virus. The JC virus is Severe adverse reactions with widespread, with about 70–90% of adults intravenous immunoglobulin presenting antibodies. Australia — Intravenous immunoglobu- The virus usually remains latent in lin, normal (human) (IVIG) is used to treat healthy individuals, only causing disease a variety of deficiencies and disorders when the immune system is severely with an immune (or presumed immune) compromised. PML has been studied in aetiology. IVIG preparations, including patients with HIV infection, where inci- Intragam P®, Sandoglobulin®, and dence is approximately 5% of the disease Octagam®, have been available since the population. PML also occurs in patients 1980s. Use worldwide and in Australia with cancer and those who have has more than doubled over the past received kidney or bone-marrow trans- decade (1) partly due to increasing use in plants. In PML, gradual destruction of the off-label indications. myelin sheath covering nerve axons Nausea and vomiting are most commonly leads to impaired transmission of nerve observed with IVIG, as are hypersensitiv- impulses. PML causes rapidly progres- ity reactions which may include anaphy- sive focal neurological deficits including: laxis. Those with IgA deficiency have a higher risk of hypersensitivity to IVIG due • cognitive and behavioural changes; to the presence of IgA antibodies. Less • paraesthesia; common but also serious reactions are aseptic meningitis, haemolysis and • visual problems; transfusion-related acute lung injury — one case has been reported in Australia • gait abnormalities and loss of limb coordination, and and one in Canada (2). Recently, Health Canada highlighted an association • hemiparesis. between IVIG and thromboembolic events (3). The Medicines and Healthcare Products Regulatory Agency (MHRA) has previ- To date, the Therapeutic Goods Adminis- tration (TGA) has received 356 reports of 105
  • 23. Safety and Efficacy Issues WHO Drug Information Vol 23, No. 2, 2009 adverse reactions associated with IVIG: Exenatide: risk of severe IVIG was the sole suspected agent in pancreatitis and renal failure 90% of reports. Thirty-five per cent describe serious reactions, including United Kingdom — Exenatide (Byetta®), where the outcome was fatal due to: an incretin mimetic, is a glucagon-like- stroke/myocardial infarction, myocardial peptide-1 analogue that stimulates insulin infarction, convulsions, hepatic and renal release from pancreatic cells in a glucose failure, and respiratory failure respec- dependent manner. Exenatide is indi- tively. In fatal cases, patients generally cated for treatment of type 2 diabetes had thrombogenic risk factors such as mellitus in combination with metformin, hypertension, obesity, increasing age, or with or without sulphonylureas in patients past history of stroke. who have not achieved adequate glycae- mic control on maximally tolerated doses The TGA has also received substantial of these oral therapies. numbers of reports describing pyrexia (58), chills (41), haemolysis or anaemia Exenatide should not be used in patients (32), meningitis (20), neutropenia (12), with type 1 diabetes or for the treatment hepatic disorders (11), and renal failure/ of diabetic ketoacidosis. It should not be impairment (8). In some of the cases, the used in patients with type 2 diabetes reactions — particularly those suggesting who require insulin therapy due to cell hypersensitivity — occurred during the failure. IVIG infusion and improved with slowing or stopping the infusion. Suspected adverse reaction reports of necrotizing and haemorrhagic pancreatitis Before and during the use of IVIG, any have been received in association with pre-existing thrombogenic risk factors exenatide. Some of these reports had a should be assessed and all patients fatal outcome. If pancreatitis is diag- should be monitored closely during nosed, exenatide should be permanently infusion. A slow infusion rate of IVIG discontinued. Reports of renal impair- should be considered for all patients with ment, including acute renal failure and risk factors (as recommended in the PI). worsened chronic renal failure have also Extracted from the Australian Adverse been received. Exenatide is not Drug Reactions Bulletin, Volume 28, recommended for use in patients with Number 2, April 2009 at http:// end-stage renal disease or severe renal www.tga.gov.au/adr/aadrb/aadr0904.htm impairment References Reference: Medicines and Healthcare Products Regulatory Agency, Drug Safety 1. National Blood Authority. Criteria for the Update, Volume 2, Issue 8 March 2009 at clinical use of intravenous immunoglobulin in http://www.mhra.gov.uk/Safetyinformation/ Australia. Australian Health Ministers’ Confer- ence. December 2007. Benefits of methylphenidate 2. Case Presentation: Intravenous immune continue to outweigh risks globulin – suspected association with transfu- United Kingdom — The EMEA’s Com- sion-related acute lung injury. Canadian mittee for Medicinal Products for Human Adverse Reactions Newsletter Oct 2008; 18/4. Use (CHMP) concluded that on the basis 3. Intravenous immune globulin: myocardial of currently available data, the benefits of infarction and cerebrovascular and thrombotic methylphenidate continue to outweigh the adverse reactions. Canadian Adverse Reac- risks when used in its licensed indication. tions Newsletter Jan 2008; 18/1. Methylphenidate is indicated as part of a 106
  • 24. WHO Drug Information Vol 23, No. 2, 2009 Safety and Efficacy Issues comprehensive treatment programme for 2. Further information on brands of attention deficit/hyperactivity disorder methylphenidate available in the UK, see (ADHD) in children aged 6 years or older BNF, p 216 (edn 56; www.bnf.org). and adolescents who are diagnosed 3. Information on DSM-IV criteria is at according to DSM-IV criteria or guidelines http://www.psychiatryonline.com/; in ICD-10 and when remedial measures information on ICD-10 is at alone are insufficient. http://www.cdc.gov/nchs/about/otheract/i cd9/abticd10.htm Treatment must be under the supervision of a specialist in childhood behavioural 4. Medicines and Healthcare Products disorders. Patients should be monitored Regulatory Agency, Drug Safety Update, during treatment, which should be inter- Volume 2, Issue 8 March 2009 at http:// rupted at least once a year to determine www.mhra.gov.uk/Safetyinforma tion/ whether continuation is needed. Chromic phosphate P32: Contraindications—methylphenidate acute lymphocytic leukaemia should not be used in patients with: Canada — Information has been pro- • Diagnosis or history of severe depres- vided on important new safety information sion, anorexia nervosa or anorexic concerning Chromic phosphate P32 disorders, suicidal tendencies, psychotic suspension (Phosphocol® P32) which is symptoms, mania, schizophrenia, authorized for intracavitary instillation for severe mood disorders, or psychopathic the treatment of peritoneal or pleural or borderline personality disorder. effusions caused by metastatic disease. • Diagnosis or history of severe and Physicians should be vigilant for signs episodic (type I) bipolar (affective) and symptoms of leukaemia in patients disorder that is not well-controlled. who have received Phosphocol® P32. • Pre-existing cerebrovascular disorders The Canadian product monograph will be — e.g., cerebral aneurysm and vascular updated to include the following warning. abnormalities, including vasculitis or stroke. Leukaemia: Phosphocol® P32 may increase the risk of leukaemia in certain • Unless specialist cardiac advice has situations. Two children (ages 9 and 14) been obtained, in pre-existing cardio- with haemophilia developed acute lym- vascular disorders, including severe phocytic leukaemia approximately 10 hypertension, heart failure, arterial months after intra-articular injections. occlusive disease, angina, haemody- Phosphocol® P32 is not indicated in the namically significant congenital heart treatment of haemarthroses. disease, cardiomyopathies, myocardial infarction, potentially life-threatening In addition, the product monograph will be arrhythmias, and dysfunction of cardiac updated to include post-marketing reports ion channels of radiation injury (necrosis and fibrosis) to the small bowel, caecum, and bladder References: following peritoneal administration of Phosphocol® P32. 1. EMEA press release at http://www. emea.europa.eu/pdfs/human/ Reference: Health Canada, Alert dated 25 referral/methylphenidate/2231509en.pdf; March 2009. at http://www.hc-sc.gc.ca/dhp- question-and-answer document at mps/medeff/advisories-avis/prof/_2009/index- http://www.emea.europa.eu/pdfs/human/ eng.php 107
  • 25. Safety and Efficacy Issues WHO Drug Information Vol 23, No. 2, 2009 Warning for metoclopramide- frequently than other agents. Prescribers containing drugs are advised to monitor all patients taking antipsychotics for adverse metabolic United States of America — The Food effects. and Drug Administration (FDA) has announced that manufacturers of meto- References clopramide, a drug used to treat gastroin- testinal disorders, must add a boxed 1. http://www.bpac.org.nz/magazine/2007/ february/antipsychotics.asp warning to labelling about the risk of long- term or high-dose use. Chronic use of 3. Prescriber Update 2009;30(2):12 at http:// metoclopramide has been linked to www.medsafe.govt.nz/profs/PUarticles.asp tardive dyskinesia even after the drugs are no longer taken. Cefaclor and serum sickness- Metoclopramide works by speeding up like reactions in children the movement of the stomach muscles, Australia — The association between thus increasing the rate at which the cefaclor and serum sickness-like reac- stomach empties into the intestines. It is tions (SSLR), particularly in children, has used as a short-term treatment of gastro- long been recognized (1). These reac- oesophageal reflux disease in patients tions are characterized by a variety of who have not responded to other thera- rashes, which include urticaria or ery- pies, and to treat diabetic gastro-paresis. thema multiforme, with or without It is recommended that treatment not angioedema, accompanied by arthritis/ exceed three months. arthralgia, with or without fever. Reference: FDA News, 26 February 2009 at http://www.fda.gov The reactions are rare but occur more often after a second or subsequent Metabolic effects of course of treatment. Onset time is often a few days after cefaclor is commenced antipsychotics and signs and symptoms typically sub- New Zealand — Although schizophrenia side a few days after the drug is ceased. itself is associated with several adverse However, onset may also be delayed and metabolic effects it is now clear that all occur 7–21 days after stopping cefaclor. antipsychotics, and in particular some Children are more susceptible than atypical antipsychotics, are associated adults. with adverse effects on weight, blood glucose, and lipid concentrations. All of The TGA continues to receive about 10 these adverse effects have long-term reports per year of cefaclor-related SSLR consequences in terms of life expectancy. in children. If cefaclor must be prescribed to a child, the parents/caregivers should While the effects of antipsychotics on be advised to remain alert for the devel- weight gain may be responsible for the opment of new or worsening symptoms increased risk of diabetes and hyperlipi- that might indicate a hypersensitivity daemia, a direct effect on glucose me- reaction to the drug and to contact their tabolism may also occur. doctor immediately if there are concerns. Not all atypical antipsychotics are associ- Extracted from the Australian Adverse ated with the same level of risk. Clozap- Drug Reactions Bulletin, Volume 28, ine and olanzapine are considered to Number 2, April 2009 at http:// cause adverse metabolic effects more www.tga.gov.au/adr/aadrb/aadr0904.htm 108
  • 26. WHO Drug Information Vol 23, No. 2, 2009 Safety and Efficacy Issues Reference: ADRAC. Cefaclor in the young • If signs or symptoms that may be patient: arthritis and arthralgia <http:// associated with cardiac arrhythmia www.tga.gov.au/adr/aadrb/aadr9508.htm# occur during treatment with toremifene, cefaclor>. Aust Adv Drug React Bull 1995; 14 treatment should be stopped and an (3). ECG should be performed. Toremifene: prolongation Currently, toremifene 20 mg/day and 80 of QTc interval mg/day are being studied in prostate cancer indications. United Kingdom/European Union — The manufacturer of toremifene Reference: Communication from Orion (Fareston®) has informed healthcare Pharma UK at http://www.mhra.gov.uk/ professionals of new information on Safetyinformation/ prolongation of the QTc interval related to toremifene. The approved therapeutic Atomoxetine: risk of psychotic indication for toremifene 60 mg/day is the or manic symptoms first line treatment of hormone dependent metastatic breast cancer in postmeno- United Kingdom — Atomoxetine pausal patients. (Strattera®) is a selective noradrenaline reuptake inhibitor, authorized since 2004 Both in preclinical investigations and in for use in the treatment of attention- humans, changes in cardiac electro- deficit/hyperactivity disorder (ADHD) as physiology have been observed following part of a comprehensive treatment exposure to toremifene, in the form of QT regimen. Continued case reports of prolongation. Consequently: possible nervous-system and psychiatric adverse effects prompted a review of • Toremifene is therefore contraindicated data from all sources resulting in updated in patients with: information on the risk of new-onset or worsening of serious psychiatric disor- Congenital or documented acquired QT ders, including psychotic reactions, prolongation; electrolyte disturbances, hallucinations, mania, and agitation. particularly in uncorrected hypokalae- mia; clinically relevant bradycardia; Product information for prescribers has clinically relevant heart failure with been updated to reflect more fully the reduced left-ventricular ejection fraction; emerging safety information. Atomoxetine previous history of symptomatic arrhyth- is associated with treatment-emergent mias. psychotic or manic symptoms in children and adolescents without a history of such • Toremifene should not be used concur- disorders. If such symptoms occur, rently with other drugs that prolong the consideration should be given to a QT interval. possible causal role of atomoxetine and discontinuation of treatment. • Toremifene should be used with caution in patients with ongoing proarrhythmic Advice for healthcare professionals: conditions (especially elderly patients) such as acute myocardial ischaemia or • At normal doses, atomoxetine can be QT prolongation as this may lead to an associated with emergent psychotic or increased risk for ventricular arrhyth- manic symptoms (e.g., hallucinations, mias (including Torsade de Pointes) and delusional thinking, mania, or agitation) cardiac arrest. in children and adolescents without a history of psychotic illness or mania. 109
  • 27. Safety and Efficacy Issues WHO Drug Information Vol 23, No. 2, 2009 • If such symptoms occur, consideration In February 2008, the manufacturer should be given to a possible causal informed healthcare professionals of very role of atomoxetine and discontinuation rare liver injuries and serious skin reac- of treatment. tions associated with moxifloxacin. This was in response to a worldwide review of • It remains possible that atomoxetine serious, including fatal cases of hepato- might exacerbate pre-existing psychotic toxicity and bullous skin reactions such as or manic symptoms Stevens-Johnson syndrome (SJS) and toxic epidermal necrolysis (TEN) reported Reference: Medicines and Healthcare for moxifloxacin. Products Regulatory Agency, Drug Safety Update, Volume 2, Issue 8 March 2009 at To date, HSA has received 22 local http://www.mhra.gov.uk/Safetyinformation/ spontaneous adverse drug reaction reports associated with oral moxifloxacin. Lignocaine with chlorhexidine Patient exposure to moxifloxacin to date is estimated to be 230 577, according to gel: anaphylaxis local figures provided by the manufac- United Kingdom — Lignocaine 2% gel turer. In the interpretation of the above with chlorhexidine 0.05% is an anaes- figures, there is a need to consider the thetic/antiseptic/disinfectant combination significant degree of under-reporting of used as a lubricant for urology proce- adverse reactions as is the case with all dures and examination, and as sympto- spontaneous adverse drug reaction matic treatment of painful urethritis. reporting programmes. References Since 1990, the TGA has received 19 reports of suspected adverse reactions to 1. EMEA Press Release. European Medicines lignocaine with chlorhexidine gel. Eleven Agency recommends restricting the use of oral of these were of anaphylaxis. Some were moxifloxacin-containing medicines. http:// life threatening, but there have been no www.emea. europa.eu/pdfs/human/press/ fatalities. 2. Direct Healthcare Professional Communica- The MHRA warns of the potential for tion regarding moxifloxacin (Avelox®) and serious hepatic and bullous skin reactions. anaphylaxis or other hypersensitivity http://www.mhra.gov.uk/ reactions with both lignocaine and chlor- hexidine. Users of local anaesthetic 3. HSA Safety News, 19 Mar 2009 at http:// preparations should check which prod- www.hsa.gov.sg ucts contain chlorhexidine and are reminded of the risk of severe allergic reactions to medicines, even when Codeine toxicity applied topically. in breastfed infants Singapore — Codeine is found in many Reference: Medicines and Healthcare prescription and non-prescription pain Products Regulatory Agency, http:// www.mhra.gov.uk/Safetyinforma tion/ relievers and cough syrups. Once in- gested, codeine is metabolised by cyto- chrome P450 2D6 (CYP2D6) to its active Moxifloxacin safety update metabolite, morphine, which relieves pain Singapore — Moxifloxacin (Avelox® and or cough. Limited evidence suggests that Vigamox®) is a broad-spectrum antibac- individuals with a specific CYP2D6 terial that is available locally. genotype (otherwise known as ultra-rapid metabolisers) may convert codeine to 110