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Vaginal Insertion of Mesh for Incontinence and Prolapse ; How will the Recent FDA Warning Impact our Clinical Practice. MICKEY KARRAM MD DIRECTOR OF UROGYNECOLOGY THE CHRIST HOSPITAL CLINICAL PROFESSOR OF OB/GYN & UROLOGY UNIVERSITY OF CINCINNATI. OBJECTIVES.
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Vaginal Insertion of Mesh for Incontinence and Prolapse; How will the Recent FDA Warning Impact our Clinical Practice MICKEY KARRAM MD DIRECTOR OF UROGYNECOLOGY THE CHRIST HOSPITAL CLINICAL PROFESSOR OF OB/GYN & UROLOGY UNIVERSITY OF CINCINNATI
OBJECTIVES 1-Review current FDA requirements for approval of a drug or device 2-Discuss the history of industry driven mesh kits for incontinence and prolapse 3-Review prevelance of mesh complications after surgeries for SUI and Pelvic Organ Prolapse 4-Discuss impact of recent FDA warning 5-Future of pelvic floor surgery and medico-legal implications
WHY IS THE PROCESS REQUIRED BY THE FDA SO DIFFERENT FOR A DRUG VS A DEVICE? Budget differences between CDRH vs CDER 1976 ruling on devices that occurred after Dalkon Shield problems Differences between financial status of pharmaceuticals vs device companies FDA Regulatory Process;A DOUBLE –EDGED SWORD
Regulatory Approval - Drugs Four phase process IV I III II TIME ( 7 -10 yrs)
Regulatory Approval - Drugs Phase I Safety Initial human exposure – healthy volunteers CV, Metabolic, Bioavailability Pharmacokinetics (half life etc) Pharmacodynamics (unique issues with compound)
Regulatory Approval - Drugs Phase II Class specific adverse events Safety monitoring Dose ranging Pharmacokinetics Usually 20-80 patients 2-3 year process
Regulatory Approval - Drugs Phase III BIG DECISION; REQUIRES HUNDREDS/THOUSANDS OF PATIENTS; RCT – expanded exposure May include active comparator (not absolute) Efficacy / Tolerability / Safety Special patient populations Several year process ;70-90% get approved
DULOXETINE (LILLY) INTRINSA (P&G) Recent Drugs that went through Phase III trials and got rejected by FDA
Phase IV Postmarket studies to define additional information including risks benefits, and optimal use Regulatory Approval-Drugs
Filing for a new device or material 510(K) Premarket Notification Process PMA Premarket Approval Process FDA Regulations
Class I-Low potential for harm (bandages, gloves etc) Class II-May be harmful, requires special controls, labeling requirements, post market surveilence (meshes, instruments etc) Class III-Should require PMA (heart valves,breast implants etc) Classes of Devices
TMJ implant Bladder slings Renu moisture/loc Heart valves Orthopedic prosthesis Examples of 510(k) products that were withdrawn from market
HISTORY OF INDUSTRY DRIVEN MESH KITS FOR INCONTINENCE AND PROLAPSE 1-In 1996 Boston Scientific obtained 510(k) approval for the PrtoGen Sling 2-In 1998 Ethicon/Gynecare obtained 510(k) approval for TVT 3-In 2002 Ethicon/Gynecare obtained 510(k) approval for Gynemesh for repair of prolapse
510 (k) Clearance of Surgical Mesh (1992-2010)
CURRENTLY AVAILABLE SYNTHETIC SLINGS • RETROPUBIC; below to above vs above to below • PREPUBIC • TRANSOBTURATOR; outside in vs inside out • MINI-SLING; urogenital diaphragm vsobturatorinternus • GENERIC SYNTHETIC SLINGS
MESH KITS – TROCAR BASED SYSTEMS 1- Prolift (Gynecare) 2- Apogee & Perigee (AMS) 3- Avaulta (Bard)
1-ELEVATE (AMS) 2-UPHOLD & PINNACLE (BSC) 3-PROSIMA (GYNECARE) MESH KITS; DIRECT ACCESS SYSTEMS
MAUDE DATABASE Manufacturer and User Device Experience Database; • Requires mandatory reporting by manufacturer • Voluntary reporting by user; most users do not manage their own mesh complications
Recent warning from July 2011;What the FDA said • Between Jan 1, 2008 & Dec 31, 2010; the FDA received 2874 reports of complications associated with surgical mesh used to repair SUI and POP; with 1503 associated with POP. • The most frequent complications reported were erosion through the vagina, pain, infection, bleeding, dyspareunia, organ perforation, and urinary problems. • There were also reports of recurrent prolapse, neuromusculsar problems, vaginal scarring or shrinkage, & emotional problems.
FDA Recommendations to Physicians 1-Obtain specialized training for each mesh placement technique 2-Be vigilant for potential adverse events especially erosion and infection 3-Watch for c/o associated with the tools; especially bowel, bladder and blood vessel perforation 4-Inform patients about the potential for serious complications; including pain and narrowing of the vagina 5-Provide patients with a copy of the patient labeling from the manufacturer if available
Vaginal Exposure Vaginal Pain & Dyspareunia Vaginal Scarring and Loss of Vaginal Tissue Visceral Injury Thigh Pain and Referred Pain MESH COMPLICATIONS
FDA White Paper Extensive review of published data with conclusions that question efficacy of mesh for prolapse repair
FDA Obstetrics & Gynecology Devices Advisory Committee Meeting; Sept 8 & 9; 2011 Panel will be asked to discuss 1-Risks associated with vaginal mesh for POP repair 2-Based on available data is their adequate assurance of the effectiveness of vaginal mesh used for POP repair 3-Do risks of mesh repair outweigh potential benefits 4-Are more studies needed to document safety and efficacy; if so recommend study design outcome measures etc 5-Does the panel agree with the FDA regarding abdominal mesh repair has been proven to be safe and efficacious 6-SHOULD VAGINAL MESH KITS BE RECLASSIFIED AS CLASS III DEVICES
Mayo Data – Mesh Complications Complications specific to synthetic material use continue to increase Multiple surgeries to address complications may be necessary, and may incompletely resolve symptoms Potential for underreporting – only 14% referred from original treating physician Dyspareunia and recurrent prolapse are common reasons for referral Blandon et al. Int Urogynecol J 2009 Feb10 (EPub)
Mesh Complications; How Common are They The BIG QUESTION Severe mesh complications are occurring; but are the majority of them TECHNICAL or WOULD THEY OCCUR IN THE BEST OF HANDS
Vaginal anatomy; bulge, pressure, mass Visceral symptoms: Urinary and bowel symptoms Sexual activity and expectations Future surgical procedures or medicines to manage failures or complications Outcomes for Pelvic Organ Prolapse
The company that makes and sells the device. The hospital in which the surgeon performs the surgery The medical organization or society that represents the surgeon. A formal credentialling board made up of an expert panel. Certified, trained proctors that have demonstrated competence in this area or device. Other Who should ultimately be responsible for training surgeons to utilize new devices or materials?
Will this warning have a long term impact on our clinical practice? YES 1-How we teach and train 2-How we consent 3-Medico-legal implications 4-Hospital credentialing 5-Reimbursement by third party payers