330 likes | 478 Views
Pharmaco igilance. Mukesh Dheda dhedam@health.gov.za Byte Conference Centre 19 Jun 2009. Disclaimer / Caveat. The views expressed are those of the presenter. Pharmacovigilance. Assessment. Detection. Understanding. Prevention. Assessment of the effectiveness of these interventions.
E N D
Pharmaco igilance Mukesh Dheda dhedam@health.gov.za Byte Conference Centre 19 Jun 2009
Disclaimer / Caveat The views expressed are those of the presenter.
Pharmacovigilance Assessment Detection Understanding Prevention Assessment of the effectiveness of these interventions
Size and severity of the problem 25 studies 1970-95 • Hospital admissions due to ADRs • 4.2 - 6.0% with a median of 5.8% Pharmacoepidem & Drug Safety 6; suppl 3: s71-s77 (1997)
Somerset Hospital Study N=665 patients • Hospital admissions due to ADRs (6.3%) • Patients developed an ADR in hospital (6.3%). Mehta U et al. Br J Clin Pharmacol 2007; 65(3):396-406
National pharmacovigilance MEDUNSA NPC NADEMC OTHER PV CENTRES
Pharmacovigilance Whose Responsibility? • Responsibility is shared between • Manufacturer, distributor, regulatory authority, HCPs, media and consumers • Responsibility is retained throughout the product life cycle even beyond the point of use • Role and functions may differ between these players • What is industry’s role?
Common goals of Regulators and Industry • early detection of unknown safety problems • quantifying risks • detection of increases in frequency • identification of risk factors • assessing risk-benefit • preventing or minimising patient harm
Why South Africa needs its own Pharmacovigilance programme? Differences in: • Access, distribution and use (e.g. indications, dose, availability) • Genetics, diet, traditions, language, • Culture of medicine and drug use • Pharmaceutical quality and composition (excipients) of products • Profile of diseases prevalent in the population • Health care infrastructure, skilled human resources and access to information, regulatory enforcement capacity
A presentation on Promoting Safety of Medicines for Children by Anders Rane, National centres meeting, Sweden, 2008.
Development of drug metabolising enzymes in man % (100 %) Activity in an adult individual 100 Most cytochromes P450s 50 Conjugation with glucuronic acid Conjugation with sulphate Cytochrome P450 3A7 0 Birth A Rane Sep 03
Paracetamol metabolism in fetal and neona-tal period sulfate PARACETAMOL glucuronide oxidised metabolite glutathione conjugate sulfate PARACETAMOL glucuronide oxidised metabolite glutathione conjugate in adult life
WATER 35 GRAPEFRUIT JUICE 7 Bailey et al. Br J Clin Pharmacol; 1998; 46: 101-110
Sorry doc, but…. could you please give me the other drug just now? This is your medicine. Tell me if you will have any adverse reactions and I’ll give you another drug.
Major Pharmacovigilance Methods in SA • Individual Case Reports (Spontaneous reports) • Clinical Trials • Observational Cohort studies (controlled and uncontrolled e.g. CEM) • Case control studies
Spontaneous ADR reporting Principle The alert health professional connects an undesirable medical event with drug exposure SUSPICION Reports suspicion to information collecting centre
Spontaneous ADR reportingPrimary method --- reasons • large population • all medicines • hospital and out-patient care • long perspective • patient analyses possible • non-interventional • low cost
Spontaneous ADR reportingdisadvantages • under-reporting • difficult to detect • delayed reactions • reactions with high background incidence • number of exposed unknown • bias
Post-Registration Safety Reporting in SA • Based on Regulation 37 of Act 101 (1965) • Guidelines on Reporting Adverse Drug Reactions in South Africa • May 2003
Good Pharmacovigilance Practice includes… • A culture of safety awareness among sales, regulatory and marketing staff • A proper data management system for ADR reports • Procedures to ensure that appropriate and timely action can be taken including a crisis management plan • Compliance with local regulations and guidelines • Compilation/co-ordination of safety reports and analyses requested by regulatory authority • A responsible appropriately trained person for pre- and post-marketing surveillance (if not a HCP, should have access to a medically qualified person) • Inform MRA of who this individual is
Do not submit a report unless it has the following minimum information… • An identifiable source (reporter). • This should include the name , address and qualification. • An identifiable patient. • Name, initials or reference number. • Suspected product(s). • Suspected reaction(s). Reports with all minimum info can still be of poor quality!
What constitutes a good quality report? • Patient clinical condition (i.e. underlying disease, co-morbidity, gender, age, weight, renal function etc) • Drug information (include all concurrent medication e.g. OTC, complementary and chronic meds not suspected by reporter) • Event details (include baseline and subsequent lab data, objective evidence of the event if any, response to dechallenge and rechallenge, documented alternative causes etc) • Reporter qualifications, address and if patient referred, then referring doctor to enable follow-up and further investigation
What happens to reported ADR • On receipt ---assign number • Acknowledgement • Database • Evaluated individually and also check for similar reports • Recommendation made to committee/council • Act on recommendation (draft MSA, PI changes, request additional data from applicant, inform other departments in DoH)
Opportunities to Improve Individual Case Reporting • Pregnancy exposures with no outcome reported • Duplication of reports • Lack of efficacy reports – with details of event not given • No identifiable patient, reporter, ADR, or drug • Inadequate clinical data/ summarised clinical data submitted as ADR report instead of complete report submitted by initial reporter • Name of initial reporter anonymised – not in keeping with guidelines
Opportunities to improve communication of post-registration safety information • Published safety studies and other regulatory decisions – communication delayed or no communication • Changes to risk-benefit profile or where significant PI changes are required (i.e. changes in conditions of registration) –within 3 calendar days • Current guidelines do request that all safety data derived from risk management activities are submitted when regulatory action is necessary
Doctors v. Gun Owners Number of physicians in the US: 700,000 Accidental deaths caused by physicians per year: 120,000 Accidental deaths per physician: 0.171 (U.S. Dept.of Health & Human Services) Number of gun owners in the US: 80,000,000 Number of accidental gun deaths per year (all age groups): 1,500 Accidental deaths per gun owner: 0.0000188 Statistically, doctors are approximately 9,000 times more dangerous than gun owners "Not everyone has a gun, but just about everyone needs a doctor."
Reporting Rates for South Africa (< 100 reports/million inhabitants)
Thank you for your attention! The future