Ketek, FDA Hearing,

Dec. 2006 ÖM

Ketek (telithromycin)

Decisions and proceduresin the European Union

Örjan Mortimer, MD, Senior Expert,

Delegate EMEA/CHMP-PhVWP

Medical Products Agency, Sweden

Ketek, FDA Hearing,

Dec. 2006 ÖM

Outline of the presentation

• Regulatory System in the European Union (EU)

• Ketek – indications, changes to product information– assessments of hepatic safety– renewal of Marketing Authorization– assessments after the renewal

• Summary

Ketek, FDA Hearing,

Dec. 2006 ÖM

WPWP

WPWP

WPWP

PhVWPHMPC

COMPCVMP

FRUK

NL

DE

SE

CHMPEMEA

A (De)Centralized Network

Ketek, FDA Hearing,

Dec. 2006 ÖM

European Medicines Agency (EMEA)

• The EMEA coordinates the evaluation and supervision of medicinal products throughout the European Union.

• The Agency brings together the scientific resources of the 25 EU Member States in a network of the national competent authorities.

Ketek, FDA Hearing,

Dec. 2006 ÖM

The EMEA

• A network of some 3,500 European experts underpins the scientific work of the EMEA and its committees.

• Began its activities in 1995, when the European system for authorizing medicinal products was introduced

• Is primarily involved in the Centralised Procedure (CP).

Ketek, FDA Hearing,

Dec. 2006 ÖM

CHMP

PharmacovigilanceWP

Herbal MedicinalProduct WP

SafetyWP

BiotechnologyWP

EfficacyWP

Bloododucts Workin Party

Scientific advisory groups (SAGs)

QualityWP

CHMP and Working Parties (WP)

Ketek, FDA Hearing,

Dec. 2006 ÖM

CHMP responsibilities

• Opinions on granting, variation, suspension, of an authorization according to the CP

• Opinion on any scientific matter concerning the evaluation of medicinal products for human use in the EU.

Ketek, FDA Hearing,

Dec. 2006 ÖM

CHMP responsibilities

• Should formulate an opinion whenever there is disagreement between member states within other procedures as the mutual recognition procedure and decentralised procedure.

• General guidance, provide Guidelines

Ketek, FDA Hearing,

Dec. 2006 ÖM

Regulatory Procedures in EU. The Centralised Procedure

• Where the centralised procedure is used, companies submit one single marketing authorization application to the EMEA.

• A single evaluation is carried out through the Committee for Medicinal Products for Human Use (CHMP).

Ketek, FDA Hearing,

Dec. 2006 ÖM

Regulatory Procedures in EU. The Centralised Procedure (CP)

• If the Committee concludes that quality, safety and efficacy of the medicinal product is sufficiently proven, it adopts a positive opinion.

• The opinion is sent to the Commission to be transformed into a single market authorization valid for the whole of the European Union.

Ketek, FDA Hearing,

Dec. 2006 ÖM

Scope of Centralised Procedure

Mandatory for medicinal products• Developed by biotech processes• New therapies for AIDS, cancer, neurodegenerative

disorders, diabetes, and in May 08, for auto-immune diseases other auto-immune dysfunctions, viral diseases

• Orphans

Optional• Other new active substances• Generics (eligibility & applications)• ‘Biosimilar” products

Ketek, FDA Hearing,

Dec. 2006 ÖM

The Centralised procedure 1

A p p lica tion to E M E A fo r a pp ro v a l o f a n ew drug

R e po r t to 26n a tio n s fo rco m m e n ts

E va lua tio n re po rtw ith q ue s tio n s fo r

c la r i f ica tion

E va lua tio n a t thera pp or teu r ´s ag en cy

R e po r t to 26n a tio n s fo rco m m e n ts

E va lua tio n re po rtw ith q ue s tio n s fo r

c la r i f ica tion

E va lua tio n a t theco -ra pp or teu r ´s ag en cy

C H M P cho ses a ra pp or teu r an d a co - ra p po r te ur

PeerReview1 MS

Ketek, FDA Hearing,

Dec. 2006 ÖM

A n ew ro u nd sta r ts

N e w q u es tion s toth e c om pa ny

N o t O K

In g en era lW ith d ra w a l

N o

T he E u ro pe anC o m m iss ion

a p prov es

O K

C H M P

O K

R e po r t to theo the r 25 na tio ns

A ssess m e n t by thera pp or teu rs

R ep ly b y thed rug co m pa ny

T h e q ue stion s fromth e 2 7 n a tion s a re

p oo led

The Centralised Procedure 2

PeerReview1 MS

Ketek, FDA Hearing,

Dec. 2006 ÖM

Rapporteur’s Obligations• Presubmission Phase

– Organising assessment team• Agency and/or External

– Contact with applicant

• Assessment of MAA– Responsible for assessment according to timetable

• scientific quality• coordination with co-rapporteur, rest of CHMP, WP, external expertise • contact with applicant

• Post authorisation– Life-cycle perspective

• Variations, specific obligations/FUMs• Periodic Safety Update Reports (PSURs), Risk Management Plans

(RMP), reassessments, renewals, etc

Ketek, FDA Hearing,

Dec. 2006 ÖM

Ketek granted EU-MA June 2001Indications

• Treatment (in patients of 18 years or older)– mild to moderate community-acquired pneumonia, – acute exacerbation of chronic bronchitis, – acute sinusitis, – and as an alternative to beta-lactams for tonsillitis /

pharyngitis (in patients 12 years or older).

The dose recommendation is two 400 mg tablets once daily for 5 to 10 days.

Ketek, FDA Hearing,

Dec. 2006 ÖM

Ketek – usage in the EU

• In total estimated 13 million courses (world wide estimate 27 million courses)

• France > 50 %

• Also extensive use in Italy, Germany, Spain and Greece

Ketek, FDA Hearing,

Dec. 2006 ÖM

Most important Variations (= Update of Product Information)

• March 2002 – interaction with rifampicin

• November 2002 – update of information regarding visual disturbances

• April 2003 – aggravation of Myasthenia gravis

Ketek, FDA Hearing,

Dec. 2006 ÖM

Variations of product information• October 2003 –

– ADR section updated with info concerning hepatic ADRs, anaphylactic reactions and visual disorders

– Driving section updated with information concerning visual disorders which may impair the ability to drive

Ketek, FDA Hearing,

Dec. 2006 ÖM

Variations of product information

• November 2004 – monitoring of PT-INR while patients are receiving telithromycin and anticoagulants simulataneously

• July 2005 –transient loss of consciousness added to ADR section and accordingly also a driving warning was introduced

Ketek, FDA Hearing,

Dec. 2006 ÖM

Variations of product information

• February 2006 – warnings regarding severe hepatitis and liver failure which may occur with short latency and in most cases were reversible. Patient should be informed of signs and symptoms

• September 2006 – contraindication in patients with previous liver reactions during exposure to telithromycin + hepatic fatalities

Ketek, FDA Hearing,

Dec. 2006 ÖM

Assessment of hepatic safety January 2006

• The PhVWP and the CHMP considered that: – characteristics of serious hepatic reactions were

not well described in the product information

– that the short latency to onset of these reactions was of concern in patients treated in primary care

– an update of product information be requested

Ketek, FDA Hearing,

Dec. 2006 ÖM

Hepatic safety January 2006 contd.

– further assessment of available data needed

– a Risk Management Plan on hepatic safety be requested

Accordingly, the product information was updated and a List of Question was sent to the MAH

Ketek, FDA Hearing,

Dec. 2006 ÖM

Assessment hepatic safety, May 2006.(Follow-up measure 26).

• Most of the available data on hepatic safety was considered consistent with the current labelling.

• No risk factors could be identified except a tendency for patients with CAP to be at higher risk of liver reactions

Ketek, FDA Hearing,

Dec. 2006 ÖM

Assessment hepatic safety, May 2006.

• The RMP was considered satisfactory and the presented protocol for an epi-study of severe hepatic events in the USA should be updated.

• The risk-benefit of Ketek was still considered favourable

Ketek, FDA Hearing,

Dec. 2006 ÖM

Assessment hepatic safety, May 2006.

• The assessment of available data on hepatic safety of Ketek in the EU member states was continued.

Ketek, FDA Hearing,

Dec. 2006 ÖM

Renewal of the Marketing Authorization

• The application for renewal of the MA was assessed in parallell with the re-assessment of the hepatic safety

• In June 2006, the CHMP considered the benefit-risk of Ketek continues to be favourable based on a review of the available information (quality, efficacy and safety).

Ketek, FDA Hearing,

Dec. 2006 ÖM

Renewal of the Marketing Authorization

• Considering the increased awareness of safety issues, especially the hepatic safety, the CHMP was of the opinion that one additional five-year renewal on the basis of pharmacovigilance ground was required.

• The MAH should continue to submit annual Periodic Safety Update Reports

Ketek, FDA Hearing,

Dec. 2006 ÖM

Assessment of cases of serious hepatic ADRs reported in the EU (September 2006).

• 49 cases reported in the EU, most of them in France and Germany.

• For 3 fatal cases (all from France) limited information was provided and/or there were other factors causing the hepatic reaction

Ketek, FDA Hearing,

Dec. 2006 ÖM

Assessment of cases of serious hepatic ADRs reported in the EU (September 2006)

• The reporting rate or serious hepatic reactions was estimated to be 4-10 cases per million courses

• These data were in line with the current product information and did not alter the conclusions drawn by the CHMP in June 2006.

Ketek, FDA Hearing,

Dec. 2006 ÖM

Assessment of cases of serious hepatic ADRs reported in the EU (September 2006)

• Taking global data into consideration, information regarding the occurrence of fatal hepatic reactions should be added to the product information.

• Further evaluation of the prescription and reporting of ADRs in the EU warranted.

• A full Risk Management Plan was requested (according to the new legislation)

Ketek, FDA Hearing,

Dec. 2006 ÖM

Additional regulatory measures in the EU

• The product information has been updated with regard to hepatic safety– contraindication in patients who have

experienced a hepatic reaction during treatment with Ketek

– add information that fatal hepatic reactions have been reported

Ketek, FDA Hearing,

Dec. 2006 ÖM

Summary• Ketek was authorized in the EU > 5 years ago• The Product Information has been updated with

safety information regarding – risk of interactions– visual disturbances– risk of aggravation of myasthenia gravis, some fatal– risk of loss of consciousness– risk of serious hepatic reactions, some fatal

Ketek, FDA Hearing,

Dec. 2006 ÖM

Summary• Re-assessment of the hepatic safety was

made in parallell with the renewal of the MA

• The Marketing Authorization was renewed by the EU-commission in July 2006, based on the CHMP opinion.

• A second five-year renewal will take place.

Ketek, FDA Hearing,

Dec. 2006 ÖM

Summary• Annual Periodic Safety Update Reports should

be submitted, and several safety issues are closely monitored.

• A full Risk Management Plan has been requested (Submitted 13 December 2006)

• The use of Ketek in the EU is extensive and will be followed closely.