Tuesday, October 23, 2018

Pharmacovigilance in India : How Safe are the New Drugs? How Sure are We?


Pharmacovigilance in India : How Safe are the New

Drugs?


         How Sure are We?


Shashank R Joshi*, SM Sapatnekar**

“The Physician … must have two special objects in view with regard to disease, namely, to do good or to do no harm(Primum Non Nocere) “1              … Hippocrates

Are we not too familiar with this quote by the Father of Modern Medicine? But then, familiarity does breed contempt. Or else, practicing clinicians would have paid heed to this basic principle medical practice. Then Drug Related Problems (DRP) would not have resulted in 8.1 million hospital admissions in USA in 1992.1 Johnson and Bootman’s decision-analytic model shows three types of incorrect or inappropriate attention by physicians; viz., Adverse drug reactions, Drug interactions, Drug use without indication. Even this oft quoted study of 1995 has not made the medical profession any wiser or practise their art more responsibly. Overall, the cost of drug- related morbidity and mortality exceeded $ 177.4 billion in 2000. Hospital admissions accounted for nearly 70%.2 This pandemic is ascribed to unnecessary prescribing, imprecise diagnosis, the uncritical application of evidence-based medicine, the outstanding development of new drugs and their unjustified promotion.3 The last aspect is particularly worrying. While the procedures for Drug Trials – often referred to as Clinical Research have evolved, been standardized and carry statutory obligations can one say that the Drug is safe? The license to market a new drug by Food & Drug Authority gives a legal authority to the manufacturer. Alas, it also gives a false sense of security to the Medical Profession. What ought to be remembered is that we are playing with laws of probability and taking calculated risks while permitting a new drug to be marketed. Even with all protocols, procedures and laws, we do not know if the new compound is safe for humans. At best it is “not unsafe” and

may be tested further with extreme caution.

Phase 1 trials try to determine dosing, identify acute side effects in about 20-80 healthy volunteers. Phase 2 trials include about 100-300 volunteers to seek preliminary evidence of the drug’s efficacy. If the benefits and risks are considered acceptable, the drug moves to Phase 3, where 1000 to 3000 subjects are enrolled in the study, testing the product’s effectiveness, monitors side effects, and compares the product’s effects to a standard treatment. As more and more participants are tested over longer periods


*Endocrinologist, Joshi Clinic, Lilavati and Bhatia Hospital, Mumbai, India. **Director and Dean, Clinical Research Education & Management Academy, Mumbai 400 059.





of time, the less common side effects are more likely to be revealed.5 This goes to show that a marketed drug has taken care to ensure that the common side effects to this new drug are not serious. But then, the corollary is that we are not aware about the rare side effects of this new drug and we do not know if these are occurring, how often and are these going unreported. The only way to find out such occurrences is to be on active lookout for adverse events over a long tome horizon in large population and in different host conditions with regard to ethnicity, age, gender, and physiological state. We know that each one can alter the response to a drug.

Year
Drug
Toxicity
Remarks




1950
Chroramphenicol
Aplastic anemia
Still its use



continued
1961
Thalidomide
Phocomelia
National disaster
1970
Clioquinol
SMON
After 30 years of



use
1970
Diethylstilbestrol
Adenocarcinoma
In utero


of the cervix and
exposure.


vagina
Manifestation



after 20 years
1975
Practolol
Oculo-mucocutan-
5 years after


eous syndrome
marketing
1976
Zomepirac
Anaphylaxis


(NSAID)


1980
Ticrynafen
Deaths from liver



disease

2004
Vioxx
Sudden cardiac
5 years after


deaths
suspecting

Based partly on Pharmacoloepidemiology by Brian L. Strom

The need for conscious vigilance was perceived as early as late 1960’s. The World Health Organization offered guidelines for International Drug Monitoring6 defining the role of National Centre in 1972. Previously new drugs used to be introduced in the Indian market several years after they were launched in other countries. The regulatory bodies in India approved drugs based on the data generated in the countries where these products were earlier approved and marketed. India’s regulatory agencies and drug companies based their safety assessments on Data derived from long-term drug use in US, European and Japanese markets. India did not have a formal Pharmacovigilance system in the past to detect adverse reactions of marketed drugs as very few new drugs were discovered in India.

It was on November 23, 2004, The Central Drugs Standard Control Organization (CDSCO) of Govt. of India launched


© JAPI  •  VOL. 56  •  DECEMBER 2008                                 LearnLync                                                                                                   933

a formal National Pharmacovigilance Program7 (NPP) that became functional from January 1, 2005, with a nationwide network with 25 peripheral centers, 5 regional centers, and 2 zonal centers was established, in a hierarchical fashion, with predefined tasks and responsibilities allocated at each level. The National Pharmacovigilance Program at CDSCO aims to: (1) monitor the adverse drug reactions of medicines to identify unexpected adverse drug reactions.

(2) review Periodic Safety Update Reports (PSURs) submitted by pharmaceutical companies for all new chemicals drugs for 4 years. (3) maintain contacts with international regulatory bodies. (4) assess the regulatory information relating to safety. & (5) provide information to end-users through adverse drug reaction news bulletins, drug alerts and seminars.8

Thus, the Physician has most important role to play in Pharmacovigilance. Not merely because he is the first person to whom the patient will come with symptoms; but also to suspect an ADR. By their training the Physicians have the abilities to suspect and detect; they need to augment this by inculcation of intuitive skills. A drug rash or nausea is always at the front of our mind as ADR; but not the tinnitus or neutropenia. The diagnosis in such cases is invariably missed or is at advanced stage of complications. Quite often the diagnosis is in hindsight. This does not help the patient. Merely the history of years of use of a drug in millions of patients with an established drug also is not a guarantee of its safety. Chloramphenicol continued to be prescribed in spite of knowing that it might cause Aplastic anemia in 1950 till an effective alternative was available in the 1980’s. The physicians therefore ought not to have a false sense of security with license issued by FDA or by traditional large scale use of a drug. WHO (1972) offered its definition of ADR as ”A response which is noxious and unintended and which occurs at doses normally used in humans for the prophylaxis, diagnosis or therapy of disease, or for the modification of physiological function”. Such a reaction may lead to an Adverse Event that is defined as “Any untoward medical occurrence that may present during treatment with a pharmaceutical product but which does not necessarily have a causal relationship with this treatment.” Rawlins and Thompson classification is easy in routine clinical practice. Therein the following types are described. Type A (augmented) two subclasses; viz., Exaggerated Desired Effect or an Undesired Effect. Type B (bizarre) adverse event are called pharmacologically unexpected, unpredictable, or idiosyncratic adverse reactions; with two subclasses; viz., Immunologic or Idiosyncratic. There are many other classifications that have higher level of clarity and complexity. One such classification is by JK Aronson and RE Ferner.9

Several attempts of pharmacovigilance are now done by various regional centers and we encourage physicians to manually or e-report ADRs. We encourage physicians to share ADRS though not only medical journals but also through the national centers of pharmacovigilance. In this issue of JAPI Ramchandran et al report the first Indian


case of Exenatide pancreatitis.10 The GLP – 1 analogue like Exenatide are incretins which have novel new axis of pharmacointervention for diabesity. This pancreatic ADR is a new ADR of which little is known. We have postulated a cholinergic hyperstimulation pancreatitis as a mechanism. Seven deaths due to hemorrhagic pancreatitis have been reported in the US recently. A direct cause effect relationship with the drug and pancreatitis has not yet been established but we need to be vigilant and use the drug with care and caution. Rimonabant a novel weight loss compound was recently suspended in the EU and failed US FDA though is available in India due to serious Neuropyschiatric ADRs including suicidal ideation. More than 2.5 billion US$ have been spent on the CB-1 pathway which is now closed globally.

There is an element of inevitability in occurrences of Adverse Drug Reactions (ADRs); particularly for new drugs. The sponsor has invested millions of dollars in drug discovery and development. There is the urge to market the drug as soon as the permission to do so is obtained. Any report of ADR is construed as a speed breaker and is likely to be neglected. There may be conscious efforts to neglect what is suspected or there might be an innocent omission to value a danger signal. In either case, it is the life and welfare of human beings at stake, and the primary responsibility of a physician is to safeguard these. The physician therefore has a role to play in terms of constant vigilance in mind and due diligence in practice. He will suspect uncommon and detect the rare. He will report ADR and deport dangerous drugs. He will do this not for any award; but for the reward of making the world safer for humankind to live and thrive.

REFERENCES

1.     Hippocrates; Epidemics; http://ancienthistory.about.com

2.     Johnson JA, Bootman JL. Drug-related morbidity and mortality. A cost-of-illness mode. Arch Intern Med 1995;155:1949-56.
3.     Frank R Ernst. J Am Pharm Assoc 2001;41(2):192-199,

4.     Hugh McGavock; Journal of Evaluation in Clinical Practice; Volume 10 Issue 4, Pages 491 - 497

5.     Carol Rados. Inside Clinical Trials; Testing Medical Products in People; FDA Consumer magazine; Sept.-Oct. 2003 Issue

6.     WHO Technical Report Series No.498.

7.     Pharmacovigilance Official website www.pharmaco vigilance.co.in/ home.html

8.     CDSCO official website http://cdsco.nic.in/

9.      Aronson JK, Ferner RE; Joining the DoTS: new approach to classifying

adverse drug reactions; BMJ 2003; 327: 1222 - 1225.

10.    Tripathy NR, Basha S, Jain R, Shetty S , Ramachandran A. Exenatide and Acute Pancreatitis. J Assoc Physician India 2008;56:987-8.


                                                                                              

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