1 drug safety oversight board update dia annual meeting philadelphia, pa june 21 st, 2006 susan k....

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1 Drug Safety Oversight Board Update DIA Annual Meeting Philadelphia, PA June 21 st , 2006 Susan K. Cummins, MD, MPH Executive Director Drug Safety Oversight Board Center for Drug Evaluation and Research Food and Drug Administration

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Drug Safety Oversight Board UpdateDIA Annual Meeting

Philadelphia, PAJune 21st, 2006

Susan K. Cummins, MD, MPHExecutive Director Drug Safety Oversight Board

Center for Drug Evaluation and Research

Food and Drug Administration

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Today’s Talk

Review the first year’s activities for the Drug Safety Oversight Board

Provide update on other DSB Activities Draft Drug Watch Guidance

Posting of information sheets about emerging important drug safety concerns

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Definition: Important Drug Safety Issue

A Drug Safety issue with the potential to:

Significantly alter the risk-benefit analysis of a drug

Affect physician’s decision to prescribe

Affect patient’s decision to use

Includes and is broader than regulatory definition of “serious and/or life-threatening” adverse event

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Drug Safety Oversight Board

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Definition: Oversight

Oversight1 (n):

1. Watchful care or management; supervision.

2. An unintentional omission or mistake.

1The American Heritage® Dictionary of the English Language, Fourth Edition, 2000 by Houghton Mifflin Company

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Drug Safety Oversight Board Charge

Provide independent oversight and advice to Center Director on:

Management of Important Drug Safety Issues

Adjudication of organizational disputes

Policies about management of drug safety issues

Risk communication about important emerging drug safety concerns

Development of HCP & patient information sheets

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Drug Safety Oversight BoardOperational Principles

Fosters effective CDER management of important emerging drug safety concerns

DOES NOT replace Public Advisory Committees

DOES NOT replace current internal responsibility for Regulatory Decision-making

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Drug Safety Oversight Board: the First Year

Held nine meetings

June 17th 2005 to June 15th 2006

Public Summaries are at: http://www.fda.gov/cder/drug/DrugSafety/DSOBmeetings/default.htm

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Drug Safety Oversight Board: the First Year

Focus of meetings Didactic sessions about CDER processes Defining role within CDER Advising on when and what to communicate

about emerging risk Consider how to track emerging important

drug safety issues Pre-decisional discussions about many drugs

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When does FDA communicate about emerging risk?

Factors that favor early communication:

If a new risk is a “important drug safety concern”

Affects prescribing or monitoring

When there are measures to be taken to prevent harm

If unapproved (off-label) use poses a significant and/or yet undescribed risk

If a specific and/or vulnerable subpopulation may be affected (children or the elderly)

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DSB does Not Replace AC Meetings or Reduce Public Input DSB Meetings :

Many products discussed

Process-oriented

Surfaces & addresses internal conflicts

Discusses confidential commercial information

AC Meetings :

Reviews single drug or drug class

Regulatory action oriented

Venue for obtaining public input

FDA information provided to public

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Drug Safety Oversight Board Staff Activities

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Proposed Drug Watch Draft Guidance

Many comments

Support for early communication; unfavorable comments about Watch concept

Comments have been collated, synthesized & evaluated by team

New draft under development

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Risk Communication Venuesfor Patients and the General Public Plain Language health communication

Public Health Advisory Summarizes the specific public health concern

with actions to take

Patient Information Sheet “FDA Alert” summarizing safety concern

Highlights about product from the approved label

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Risk Communication Venuefor Health Care Professionals

Health Care Professional Information Sheet

“FDA Alert” summarizing the safety concern

Recommendations and Considerations—implications for practice

Information & data that are the basis for concern

Studies being done to better understand the concern

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Drug Safety Alert Challenges Striking the right balance—don’t want to

Over warn OR Under warn

Communicating complex information simply Determining when to inform the public when the

nature of the data is evolving and early Anticipating & managing unintended consequences Balancing the communication of emerging risk with

communication of benefit

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Drug Safety HC Professional and

Patient Information Sheets At least 49 drugs with safety postings through May 31 2006

6 Product class issues 3 Market suspensions

Palladone (hydromorphone hydrochloride ext release) Tysabri (natalizumab) (Return to Market 06/05/06) Neutrospec [Technetium (99m Tc) fanolesomab]

3 Product withdrawals Bextra (valdecoxib) Cylert (pemoline) Tequin (gatifloxin)

40 with added warnings to product label

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Drug Class Risks Described in HC Professional & Patient Information Sheets

Antidepressants—suicidality in adults & children Atypical antipsychotics—increased risk of death in dementia

(unapproved use) Non-steroidal anti-inflammatory drugs—increased

cardiovascular risk Erectile dysfunction drugs—non-arteritic anterior ischemic

optic neuropathy Topical Immunosuppressant calcineurin inhibitors—potential

cancer risk Long-acting beta agonists—increased risk of severe asthma

episodes that may lead to death

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Drug Safety HC Professional & Patient Information Sheets: Examples

Accutane (isotretinoin)—new restricted access program to prevent pregnancy in treated women

Paxil (paroxetine)—Pregnancy Category changed--C to D Strattera (atomoxetine)—increased pediatric suicidality risk Palladone (hydromorphone)— Withdrawn due to dose

dumping with concomitant alcohol exposure Campath (alemtuzumab)—idiopathic thrombocytopenic purpura

in patients with multiple sclerosis (unlabeled use) Neutrospec (99mTechnetium fanolesomab)—serious and life

threatening cardiopulmonary events shortly after administration

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Summary

Drug Safety Oversight Board and its risk communication efforts are a major component of CDER’s effort to strengthen drug safety efforts

Sharing emerging important issues early

Improving management through internal oversight