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    An Introduction to

    PHARMACOVIGILANCE

    dr. J.W.S. Hajadi

    Survival

    Cure

    Quality of Life

    Conmfort

    Prevention

    Side Effect

    Toxicity

    Drug Interaction

    Zero risk doesnt exist !

    BENEFIT

    RISK

    DRUG

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    Drug Effect

    Patient

    Illness

    Drug

    Environment

    Pharmacovigilance - WHO

    Defini tion :

    Is the pharmacological science relating to the

    detection, assessment, understanding and

    prevention of adverse effects, particularly long-

    term and short-term side effects of medicines.

    Etymological roots :

    pharmacon (Greek) = drugvigilare (Latin) = to keep awake or alert, to keep

    watch

    Importance of PV,WHO - 2002

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    Definition of Pharmacovigi lance - MHRA

    Pharmacoviglance is the process of :

    Monitoring medicines including traditional herbal medicinesas used in everyday practice to identify previouslyunrecognised risks or changes in the patterns or frequencyof their adverse effects.Assessing the risks and benefits of medicines in order todetermine what action, if any, is necessary to improve theirsafe use. Providing information to users to optimise safe andeffective use of traditional medicine.

    Monitoring the impact of any action taken.

    Medicine and Healthcare products Regulatory Agency

    What is Pharmacovigilance ?

    Generally speaking, PV is the science of :

    - collecting,

    - monitoring,

    - researching,

    - assessing , and

    - evaluating

    information from healthcare providers and patients on the

    adverse effects of medication, biological products, herbalism

    and traditional medicines with a view to :

    Identifying new information about hazards associated withmedicines,

    preventing harm to patients.

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    Safety of Medicines

    WHO / Geneve 2002 - Guide to detecting andreporting adverse drug reactions :

    The objective of the Guide are to raise awareness of the

    magnitude of the drug safety problem and to convince

    health professionals that reporting of adverse drug

    rections is their moral and professional obligation.The ultimate goal of the Guide is to reduce drug morbidity

    and drug mortality by early detection of drug safety problems

    in patients and improving selection and rational use of drugs

    by health professionals.

    Marketing Authorisation

    Is granted by the Regulatory Authority

    after rigorous evaluation of data on :

    SAFETY

    EFFICACY

    QUALITY

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    Main steps of Pharmaceutical R&D

    Research (2-10 years)

    Preclinical testing (3-4 years)Laboratory and animal testing

    Phase I (1 year)20-80 Healthy volunteers used todetermine safety and dosage

    Phase II (2 years)100-800 Patient volunteers used to look forefficacy and side effects

    Phase III (3 years)1000-8000 Patient volunteers used to

    monitor adverse reactions to long-term use

    0 2 4 6 8 10 12 14 16Years

    5050--70%70%

    20%20%

    10%10%

    5%5%

    < 5%< 5%

    RelativeRelative

    CostCost

    10000001000000

    100100

    1010

    66

    22

    Agencies Review/

    Approval

    Drug Safety Evaluation along thevalue chain

    Clinical PhasesPreclinical Phases

    Phase I(safety)

    Phase II(safety/efficacy)

    Phase III(safety/efficacy)

    Phase IVPharmacovigilance

    SD ExplTox

    Teratology

    carcinogenicity

    Genetic ToxScreening

    Genetic Toxicity

    2-week Expl Tox

    1 month Tox

    Acu te Tox ici ty

    Female Fertility

    3/6 month Tox

    Male fertility

    Chronic Tox

    Pre-Post NatalItyFirst Dose in HumanGLP

    Mechanistic Toxicology

    Pharmacovigilance

    SafetyPharmacology

    Exploratory Safety Pharmacology

    PMS

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    Safety Data : CT vs Post-marketing

    Clinical Studies Marketed drugs Limited number of exposed patients

    Blinded or open studies

    Well-defined daily dose

    Limited number of prescribers

    (investigators)

    Well-defined indication

    Well-defined inclusion and non-inclusion

    criteria to be enrolled in the study

    Controlled co-medications

    Strict clinical and/or biological monitoring

    Large number of exposed patients

    Uncontrolled co-medications (self

    medication)

    Variable compliance

    Off label use

    Limited monitoring

    Difficult evaluation of the number ofexposed patients

    Specific regulations, Internal interfaces:

    Clinical development, projects, toxicology,

    regulatory affairs

    Specific regulations, Internal interfaces:

    Regulatory affairs, Business units,

    Current Drug Safety issues

    Recent reports in the media on new, unexpected

    and severe ADRs with new or existing products

    leading to widespread publicity has become part of

    our daily life.

    Affecting : patients,

    their doctor,

    pharma company,

    regulatory agencies,

    legal system.

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    Need for Postmarketing Surveillance and

    ADR reporting The information collected during the pre-marketing phase of

    drug development is inevitably incomplete with regard topossible ADRs. This is mainly because :Animal tests are insufficient to predict human safety; Patients used in clinical trials are selected and limited in number,the conditions of use differ from those in clinical practice and theduration of trials is limited; By the time of licensing, exposure of less than 5000 humansubjects allows only the more common ADRS to be detected;At least 30.000 people need to be treated with a drug to be surethat you do not miss at least one patient with an ADR which has anincident of 1 in 10,000 exposed individuals; Information about rare but serious adverse reaction, chronic

    toxicity, use in special groups (i.e. children, elderly, pregnancy) ordrug interactions is often incomplete or not available.

    Thus, post-marketing surveillance is important to permitdetection of less common but sometimes very serious ADRs.

    Current PV issues

    First World August 14, 2007FDA : Stronger warning to be added to some type 2 diabetesdrugsThe FDA announced that a stronger warning on the risk of heartfailure will be added to the thiazolidinedione class of type 2diabetes drugs (rosiglitazone and pioglitazone).

    First World October 18, 2007EU regulator confirms benefit-risk profile for rosiglitazone andpioglitazoneThe EMEA concluded that the benefits pf rosiglitazone and

    pioglitazone outweigh the risk in approved indications. The agencystated that it conducted a review of thiazolidinediones because ofnew information on potential side effects including bone fracturesin women and ischemic heart disease

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    Current PV issues

    First World September 17, 2007New York City, State suing Merck&Co. over VioxxThe city and state of New York filed a lawsuit against Merck&Co.over allegations that the drug maker misrepresented the risks ofVioxx. The suit is seeking tens of millions of dollars in damages andcivil penalties as restitution for money spent on prescriptions for theCOX-2 inhibitor therapy through healthcare program.

    First World November 09, 2007Merck&Co. to settle Vioxx lawsuits, shares riseTo pay 4.85 billion to settle state and federal claims related to Vioxxin the US (as of October 9 : 27,000 lawsuits 47,000 plaintiff

    groups as well as 264 class-action suits).

    Current PV issues

    Buletin BERITA MESO, Vol 25 No 2,November 2007 Pembatalan ijin edar dan penarikan produk yangmengandung Clobutinol HCl dari peredaran.....karena adanya informasi potensi efek samping KV.Walaupun belum ada laporan efek samping tersebut olehPusat MESO Nasional, namun keputusan ini merupakanbagian dari keputusan global......... Rosiglitazone terkait efek samping pada KV Metoklopramide terkait peningkatan laporan gejala ekstra-piramidal

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    Magnitude of the Problem

    Estimated that ADRs are the 4th 6th largest

    cause for mortality in the USA

    Percentage of hospital admissions due to ADRs in

    some countries is about or more than 10% :

    Norway 11.5% France 13.0% UK 16.0%

    A high financial burden on health care for drug

    related problems. Medicine related problems

    include drug abuse, misuse, poisoning,

    therapeutic failure and medication errors.

    Lazarou J. et al, 1998. Incidence of ADR in hospitalized patients : a meta-

    analysis of prospective studies.JAMA, 1998,279 (15) 1000-5.

    Why PV is needed in every country

    There are differences among countries (and even

    regions within countries) in the occurence of ADRs

    and other drug-related problems. This may be due

    to differences in eg : diseases and prescribing practices;

    genetics, diet, traditions of people;

    drug manufacturing processes used which influence

    pharmaceutical quality and composition;

    drug distribution and use, including indication, dose andavailability;

    the use of traditional and complementary drugs (e.g. herbal

    remedies) which may pose specific toxicological problems,

    when used alone or in combnation with other drugs.

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    How voluntary reporting on ADRs can prevent new medicine

    tragedies from developing

    It took many decades before the deleterious effects of aspirin on the G-I

    tract became apparent or that the protracted abuse of phenacetin could

    produce renal papillary necrosis. 35 five years elapsed before it became

    clear that amydopyrine could cause agranulocytosis; and several years

    before the association of phocomelia and thalidomide became obvious.

    Withdrawals from the market as a result of spontaneous reportingINN Reason for Year of Year of

    (brand name) withdrawal marketing withdrawal

    bromfenac (Duract) serious hepatotoxic effect 1997 1998

    encainide (Enkaid) excessive mortality 1987 1991

    flosequinan (Manoplax) excessive mortality 1992 1993

    temafloxacin (Omnifox) haemolytic anemia 1992 1992

    benoxaprofen (Oraflex) liver necrosis 1982 1982

    mibefradil (Posicor) multiple drug interaction 1997 1998

    terfenadine (Seldane) fatal cardiac arrhytmias 1985 1998

    How voluntary reporting on ADRs caninfluence labelling

    Cyclophosphamide has been on the market for several years inmany countries. In January 2001 there were some new reactionsincluded in the labels : Steven-Johnson syndome and toxicepidermal necrolysis; they were not included in the PDR 1995.

    For example : EPIDERMAL NECROLYSISERYTHEMA MULTIFORMESTEVEN-JOHNSON SYNDROME

    Losartan was marketed in the USA since 1995. Some of the newreactions that have been discovered after launch and included inthe PDR are :

    VASCULITISPURPURA ALLERGIC (incl. Henoch-Schoenlein purpura)

    ANAPHYLACTIC SHOCKANAPHYLACTOID REACTION

    Levofloxacin was launched in the USA in 1997. In February 2000the label

    TORSADES DES POINTES

    was included.

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    How to recognize ADRs (1)

    1. Ensure that the medicine ordered is the medicine received

    and actually taken by the patient at the dose advised;

    2. Verify that the onset of the suspected ADR was after the

    drug was taken, not before and discuss carefully the

    observation made by the patient;

    3. Determine the time interval between the beginning of drug

    treatment and the onset of event;

    4. Evaluate the suspected ADR after discontinuing the drugs

    or reducing the dose and monitor the patients status. If

    appropriate, re-start the drug treatment and monitor

    recurrence of any adverse events.5. Analyse the alternative causes (other than drug) that could

    on their own have caused the reaction;

    How to recognize ADRs (2)

    6. Use the relevant up-to-date literatures and personal

    experience as a health professional on drugs and their

    ADRs and verify if there are previous conclusive reports

    on this reaction. The manufacturer of the drug can also be

    a resource to consult;

    7. Report any suspected ADR to the person nominated for

    ADR reporting in the hospital or directly to the National

    ADR Center.

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    What should be reported ? For new drugs report all suspected reactions, including minor

    ones (In many countries drugs are still considered new up to 5years after marketing authorization);

    For established or well-known drugs report all serious orunexpected (unusual) suspected ADRs;

    Report if an increased frequency of a given reaction is observed;

    Report all suspected ADRs associated with drug-drug, drug-food ordrug-food supplement (including herbal and complementaryproducts) interactions;

    Report ADRs in special field of interest such as drug abuse, druguse in pregnancy and during lactation;

    Report when suspected ADRs are associated with drugwithdrawals;

    Report ADRs occuring from overdose or medication error;

    Report when there is a lack of efficacy or when suspectedpharmaceutical defetcs are observed.

    Thus, report all suspected adverse reaction that you consider

    clinically important as soon as possible !

    How to report ADRs ?

    There are different Case Report Forms used in

    different countries. Basically all of them have at

    least 4 sections which should be completed :

    1. Patient Information

    2. Adverse Event or product problem

    3. Suspected Medication(s)

    4. Reporter

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    1. Patient Information

    Patient identifier

    Age at time of event or date of birth

    Gender

    Weight

    2. Adverse event or product problem

    Description of event or problem

    Date of event

    Date of this report

    Relevant tests/laboratory data (if available)

    Other relevant patients information/history

    Outcomes attributed to adverse event

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    3. Suspected medication(s)

    Name (INN and brand name)

    Dose, frequency & route of administration

    Therapy date

    Diagnosis for use

    Event abated after use stopped or dose reduced

    Batch number

    Expiration date

    Event reappeared after reintroduction of the

    treatment

    Concomitant medical products and therapy dates

    4. Reporter

    Name, address and telephone number

    Speciality and occupation

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    Company A

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    Where to send ADR reports

    National Drug Regulatory Authority (in

    Indonesia : Badan POM, Jl. Percetakan

    Negara No. 23, Jakarta Pusat).

    The manufacturer of the suspected

    product.

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    Systems for PMS of drug-associated

    events Voluntary reporting

    Intensified adverse drug reaction reporting

    Special regiestries of drug-associated disorders

    Intensive hospital monitoring

    Multiple case control surveillance

    Disease-based case control surveillance

    Medical record linkage

    Prescription event monitoring

    Computers in physicians office

    Terminology in PV

    Adverse events

    Adverse drug reactions

    Side effects

    Seriousness

    Causality

    Expectedness

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    Terminology

    Adverse events (experience)Any untoward medical occurence in a patient

    treated with a pharmaceutical product wich is not

    necessarily suspected as being due to the drug.

    Adverse drug reaction

    Side effect

    Terminology

    Adverse events

    Adverse drug react ionsA response which is due to the drug and

    considered noxious and unintended.

    WHO : occures at doses normally used in man.

    Side effects

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    Terminology

    Adverse events

    Adverse drug reactions

    Side effects

    broad term to express any untoward event

    occuring with the use of a product.(therapeutic effect = an unintended/undesirable

    consequence of medical treatment),

    (unintended consequence = effect that is unforeseen,

    regardless of type / quality).

    Severe vs Serious Event

    Severe :

    Term to describe the intensity (severity) of a

    specific event.

    Grading : mild moderate severe

    Serious :

    Term which is based on patient outcome criteria,

    serves as a guide for defining regulatory reportingobligations.

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    Seriousness Criteria

    A serious medical occurence is one that at any dose

    results in death

    requires in-patient hospitalisation or

    prolongation of current hospitalisation,

    results in persistent or significant

    disability/incapacity ,

    is life-threatening,

    cancerand congenital anomaly,

    any event which suggests a signi ficant hazard

    to a patient.

    Expectedness

    From the perspective of previously observed, an

    event could be :

    - Expected (= labelled)

    The event is consistent with the available data in

    the official product information (e.g. Investigators

    Brochure, Core Data Sheet, Product

    Information/label, etc.).

    - Unexpected (= unlabelled)The event has not been recorded previously

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    Causality

    Certain

    Probably / likely

    Possible

    Unlikely

    Unclassified

    Causality

    CertainImplies a plausible time relationship to drug

    administration which cannot be explained by

    concurrent disease or other drugs/chemicals.

    Response to dechallenge (= drug withdrawal)

    should be clinically plausible.

    Event must be definitive pharmacologically, using

    a satisfactory rechallenge procedure if necessary.

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    Causality

    Probable / likelyEvent had a reasonable time sequence to

    administration of drug which is unlikely to be

    attributed to concurrent disease or other

    drugs/chemicals.

    There must be a reasonable response on drug

    withdrawal.

    Rechallenge is not required to fulfil this definition.

    Causality

    PossibleEvent had a reasonable time sequence to

    administration of drug, but it could also be

    explained by concurrent disease or other drugs /

    chemicals.

    Information on dechallenge may be lacking or

    unclear.

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    Causality

    Unlikely

    Temporal relationship to drug administration

    makes a causal relationship improbable, or

    Other drugs / chemicals, underlying disease or

    other factors provide a more plausible explanation.

    Causality

    UnclassifiedThere is insufficient information to decide on other

    options, or unclassifiable if the required

    information in not likely to be forthcoming.

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    Category of Report

    CRITERIA

    Seriousness

    Expectedness

    Relatedness

    SERIOUS NON-SERIOUS

    UNEXPECTED EXPECTED

    RELATED UNRELATED

    X

    X

    X

    Source of Report (unsolicited)

    Health Care professionals :

    physicians, dentists, nurses, pharmacists, midwife,

    etc.

    Consumer (patient, lawyer, etc.)

    Health Authorities

    Literatures (journals, newspapers, etc.)

    Internet

    Etc.

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    Source of Report (solicited)

    Clinical trials

    Registries

    Post-approval programs

    Disease management

    Etc.

    Reporting Procedures

    National Drug Safety(BPOM)

    Local Industry/Affiliate

    Physician

    MR

    Form MESO

    HQ Intl Agencies

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    Timeframe for Reporting

    In SERIOUS cases :

    International Companies have to report to their

    HQ within 24 hours.

    HQ has the obligation to report to the European

    Agency or FDA within 15 days.

    Closing notes

    Continuous monitoring on the safety aspects of a drug (and

    device) is important to secure the safety of patients/

    consumers.

    Roles of regulatory agencies, physician, consumers and

    industry are complementory and important

    To ensure more active participation in PV activities (e.g.

    reporting), National Center for Drug Safety to conduct

    regular training on PV and establish a system to collect

    reports on adverse event at least for those meeting SURcriteria.

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    Thank You for Attention,

    SAFETY FIRST !

    Biodata

    Name : Wiriadi S. Hajadi (James)

    Place & DoB : Jakarta, June 22, 1951

    Education : Medical Doctor, ATMA JAYA Catholic University

    Jakarta (1980)

    Working experience :

    1990 2007 : sanofi-aventis Group (Medical & Regulatory

    Director, Affiliate Pharmacovigilance Head, Member

    of Management Committee)

    1985 1990 : WKS / Dokter Puskesmas Jakarta Selatan1979 1985 : Ciba-Geigy Pharma (Associate Medical Director)

    1978 1979 : Le Laboratoires Servier (Scientific Coordinator)