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Pharmacovigilance in India: Dreams
Vs RealityNational Seminar on Pharmacovigilance, CADD and Drug
Development
Pushpagiri College of Pharmacy, Tiruvalla16th Sept 2011
Unnikrishnan M KCollege of Pharmaceutical Sciences, Manipal 576 104
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The Healers Doubtful Credentials!
Do you know the meaning of allopathy ? Doctors have been the butt of many jokes!
Vaidayraja namasthubhyam
Yamaraja sahodara
Yamo harathi pranaani
Vaidyo praana dhanaanichaTo undergo treatment you have to be healthy,
because you have to withstand both sicknessand the medicine! - Moliere
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Iatrogenic Deaths in USA
12,000 -----unnecessary surgery 7,000 -----medication errors in hospitals
20,000 -----other errors in hospitals
80,000 -----infections in hospitals 106,000 ----non-error, negative effects of drugs
Total = 250,000 deaths/year are iatrogenic
Third leading cause of death in U S A after heart disease and cancer
Only 60,000 Americans died in Vietnam war!
(Report in JAMA by B Starfield of Johns Hopkins School of Hygiene & Public Health)
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Evolution of Pharmacovigilance
Thalidomide tragedy in 1961 first systematic international efforts toaddress drug safety Led to WHO Pilot Research Project for International Drug Monitoring in 1968
WHO Collaborating Centre for International Drug Monitoring Uppsala Monitoring Centre (UMC)
Creation of International Society of Pharmacoepidemiology (ISPE) in1984 & European Society of Pharmacovigilance (ESOP later ISoPthe International Society) in 1992 PV formally introduced into research & academic world,
PV integrated with clinical practice
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The Global burden of Unsafe Care
Patient safety global public health problem
WHO estimates
millions of disabling injuries/death every year ~1 in 10 harmed while receiving health care in wellfunded &
technologically advanced hospital settings
Very little evidence for burden of unsafe care in developingcountries where :
16 billion injections administered each year for curative care
40% of this administered by reusing unsterilized syringes & needles
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Global Burden of Unsafe Care
(contd)
Economic burden is compelling Added medical cost in some countries between US$ 6 - 29 billion a year
World Alliance for Patient Safety
Mobilize global efforts in health care safety in WHO MemberStates
Develop a global research agenda & locally adapted research tools Training & research funding
Creating a global research network
Translating research into safer care
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International Pharmacovigilance(PV)
Landscape
ADRs cause of hospitalizations, morbidity & even death
Pharmacovigilance aims at preventing:
ADRs & its impact on patients
both in premarketing & post marketing phases of drug
development
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International Pharmacovigilance(PV)
Landscape
Pharmacovigilance
began with WHOs Program for International Drug
Monitoring (1968)
extends beyond detecting new signals of safetyconcerns
a tool for development & marketing of safer medicines Drug Expertise: a sine qua non for safety
Number of drugs has increased dramatically
36th
Edn of Martindale has > 430 pages of general index!
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Two stories of contrast India Vs
Australia
Zolpidem story
Alendronate story
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Australian ADR Database
Up to 4 January 2008, 1032 reports of suspectedADRs to zolpidem entered TGA's ADR database
394 of 1032 reports mentioned parasomnia events
103 reports (10% ) included sleep driving
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Therapeutic Goods Administration,
Australia Warning Feb 2008
TGA Issues Black Box Warning!
"Zolpidem may be associated with potentially
dangerous complex sleep-related behaviourswhich may include sleep walking, sleep drivingand other bizarre behaviours. Zolpidem is not tobe taken with alcohol. Caution is needed withother CNS depressant drugs. Limit use to fourweeks maximum under close medicalsupervision.
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Bisphosphonatesinduced
osteonecrosis of jaw
Severe pain, numbness, soft tissue infection,loosening of teeth
Excruciating pain, disfigurement leading tosuicides
The strategy is to warn doctors, healthcare team,
dentists etc.
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Picture in UK, a developed country
National Health Services spends ~ 2bn a yeartreating patients with adverse reaction to
prescribed drugsEnough to pay for 10,000 new midwives or cost of
combating MRSA infections
ADRs result in 6.5% of hospital admission = Imillion / year in UK alone
average stay of 8 days in hospital @ 228 a day
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Drug Companies Suppress
Information on ADR
Merck knew that Vioxx, caused heart attacks,
GSK knew that Antidepressant Seroxat, (Paroxetin) increased suicidal thinking in young
There are instances when Glaxo paid up to 3 billionsto escape litigation without admitting guilt
Weve agreed to this settlement to avoid the
delay, expense and uncertainty of litigation,
Mary Anne Rhyne, a company spokeswoman.
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Why dont we have data like
Australia? 1070 million Indians Vs 20 million in Australians
Much more opportunity to gather data
Much more racially diverse,
Many more diseases in abundant numbers!
A visiting team of Australian health care providerswitnessed Typhoid for the first time in India!
Many more systems of medicine
Much more freedom to bend & twist rules
Much greater nefarious opportunity to improvise
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Some Attitude problems; some
Resources problems! We dont have a good system of keeping records Still thrive on an oral tradition
Very little discussion between the Prescriber, the
Dispenser and Patient (Overworked Doctor,busy Pharmacists, high cash transactions)
We lack faith in ourselves
We want our observations to be supported bypublished literature from the West
India has not contributed a single innovation in
therapy
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Major flaw: poor networking!We are working in isolation
We have to learn from our own mistakes
Developed countries learn from others mistakes!
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How things go wrong a Case Study
in Kerala
Nair 47 yrs h/o diabetes goes to hospital withvomiting and respiratory difficulty
Decides for himself that his case must be seenby a gastroenterologist
9 days in the hospital, returns with the foll
diagnosis (Hospital bill > Rs 25000/-) Upper esophageal polyps,
LRT, Pleural effusion, Functional bowel disorder
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Mr Nairs prescription on discharge1 T deriphyllin retard 500 1-0-12 T glimipiride 2 1-0-1
3 T Cefuroxime 500 1-0-1
4 Seroflo 100 (rotahaler) 1-0-1
5 Tegasarod 6mg* 1-0-1
6 Sod picosulphate 10 0-0-2
7 Deflazocort 6 mg 1-0-1
8 Faropenem 200 1-1-19 Flupentixol 0.5 + melitracen 10 1-1-0
10 Clonazepam 1 0-0-1
11 Rappit + (??) 1-0-0
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Nair Discharged!!
At home, Nair is feeling worse
His wife and mother in law very anxious
But they think the treatment is over withdischarge!
Blames fate! Waits for things to worsen!!
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Nair hopelessly ill; off to the next
hospital
Breathless, pedal edema, very sick
Goes to another (bigger, more famous) hospital
The revised diagnosis CCF
Dialated cardiomyopathy
Severe LV dysfunction
Type 2 DM
Coronary angiogram shows Triple vessel disease
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Tegaserod withdrawn from USA
On March 30, 2007, FDA requested Novartis towithdraw Zelnorm from shelves.
FDA found a relationship between tegaserodand increased risks of heart attack or stroke
Was still available as generic in India
Prescribed for constipation, irritable bowel syndrome
Recently banned in India along with Gatifloxacin
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Nairs prescription on discharge T clopidogrel 75 1-0-1
T Amiodarone 100 1-0-0
T Ramipril 5 1-0-0
Glimipiride 2 1-0-1/2 Spironolactone 25 1-0-1
Carvedilol 12.5 1-0-1
Digoxin 0.5 1-0-1 Isosorbide dinitrate 10 1-1-1
Lasix 40 1-0-1-0
Pantoprazole 40 1-0-1
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Nair back on his feet!
Now much better, takes medicines regularly
Short morning walks to the gate and back
Breathless after about 10 min walk
Advised CABG
Now waiting to get fit for CABG
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Male >55 yr
Dx: HTN (uncontrolled)
Rx: Clonidine, Beta blocker & CCB.
After 3 days patient c/o eye pain, dryness & discomfort , Suggests referral to ophthalmology
Pharmacist suspects that it is due toClonidine
Physician decreased the dose of Clonidine & added Prazosin Eye discomfort resolved
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A patient with Zinc phosphide poisoning Physician query: on Clinical presentation &
Treatment
Pharmacists response: an article stating the use ofsteroids and immunosuppressants
Physician:Starts Steroids &
Immunosuppressants
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Female 48 yrs pesticide: contact poisoning
C/o : pigmentation , vesicles, rash & itching, burning on righthand malar area, right side of neck & palmar region of left hand.
H/o application of pesticide powder to buffaloes and whilewashing she came in contact with pesticide on Hands, malar area
and right side of neck
Medication History: Chlophenirmine and dexamethasone. (after8 hr of exposure)
Symptoms didn't subside admission to KMC
Dermatologist's opinion: possible photo toxic reaction byunidentified pesticide
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Pharmacist analysed the pesticide contents & read up on its phototoxic effects
Pesticide found to be " METHYL PARATHION an Organophosphorous compound.
Methyl parathion on exposure to atmosphere reacts with oxygen toform methyl paraoxan, which binds to non vital organs pigmentation, irritation and burning
Pharmacist recommends acetyl cholinesterase level in blood AchE level below normal 4963 ( normal 5300-12500)
No systemic complaints: prescribed betamethasone cream
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Female 54yrs
k/c/o type 2 diabetes mellitus c/o pain abdomen, fever & vomiting for 10 days. On admission CXR showed Rt lower zone(LZ) haziness.
Repeat CXR worsening of left LZ haziness for which
tazobactum was started. She improved significantly 16th day Pt febrile , developed pain abdomen, itching &
rash
WBC drastically decreased (neutropenia). Query to Pharmacist : Pipzo produces neutropenia rarely
Drug stopped WBC Improved to 7300 after 4 days
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A 55 yr old female
k/c/o cellulitis (MRSA) Type 2 DM, Hypertension Rx Inj. H.Actrapid 25-25-15 s/c,
Inj .Tazomac (piperacillin-tazobactam) 4.5 gm, Inj. Linid
(Linezolid) 600mg IV BD,T. wysolone 20mg , T.Calcimax
forte , T.Pantocid 40mg, T.Glytop 5mg, Inj. Tramazac(Tramadol)
Pharmacist: warns interaction b/n linezolid & tramadol
serotonin syndrome (hyperthermia, hyperreflexia,myoclonus,). Can be fatal!
Suggests replacing Linezolid with Inj. CloxacillinPhysician: approves
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Indians Ignore ADRs !
Why?
Reluctance to admit error! (The Indian Ego!)
Ego is part of our Caste-ridden Patriarchy!
Apology is considered as a sign of weakness
Bigger the man, greater the reluctance !
Afraid of legal wrangles!
ADR is NOT medical negligence! Sabrina Brierton Johnson, unsuccessfully sued Johnson &
Johnson, after SJS blinded her
ADR is a part of accepted risk
You cannot sue Maruti when there is a car accident!
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Pharmacovigilance Programme of
India (PvPI)
Constituted Under the..
Central Drugs Standard Control Organization,
Directorate General of Health Services, Min of
Health & Family Welfare Govt of India
in collaboration with
Indian Pharmacopoeia Commission,
Ghaziabad, U.P.
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Goal of PvPI
To ensure that the benefits of use of medicineoutweighs the risks and thus safeguard the
health of the Indian population.
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Objectives
To monitor ADRs in Indian population
To create awareness among health care pros about theimp of ADR reporting in India
To monitor benefit-risk profile of medicines
Generate independent, evidence basedrecommendations on the safety of medicines
Support the CDSCO for formulating safety related
regulatory decisions for medicines Communicate findings with all key stakeholders
Create a national centre of excellence at par with globaldrug safety monitoring standards
P d
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Programme governance and
reporting structures
The PvPI administered and monitored by the
I. Steering Committee
II. Strategic Advisory Committee Technical support will be provided by
I. Signal Review Panel
II. Core Training PanelIII. Quality Review Panel
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ADR MONITORING CENTRES
MCI Approved Medical Colleges & Hospitals
Private Hospitals ( Manipal is among the
proposed centres)
Public Health Programmes
Autonomous Institutes (ICMR etc.)
5 YEAR ROADMAP
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5 YEAR ROADMAP
(Year 20102015 )
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Purpose of collaboration with WHO-Uppsala
Monitoring Centre (UMC)
Training of staff at PvPI national coordinating centre
Usage of UMCs Vigiflow software (for medicines)& Paniflow (for vaccines) at no cost to PvPI
Access to Vigibase, containing worldwide medicinessafety data
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Selection of ADR Monitoring centers
Medical Colleges as centresIn 2012-13 and 2013-14 (100 centres each will be enrolled)
Technical, administrative & financial support by CDSCO
Medical institutes/central institutes/autonomousinstitutes will be included (no CDSCO support)
Public & corporate hospitals inclusion on voluntarybasis (no CDSCO support)
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Operational Aspects
Roles and responsibilities of different personnel in PvPI
Training of program personnel
Centre management (including infrastructure, manpower,status reports)
Processing & reporting of suspected ADRs
Compliance & quality assurance Regulatory decision making
Communication among stakeholders
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Functions of stakeholders in Programme
PvPIADRMonitoring Centre inMedical College
Collection of ADR reports Perform follow up with the complainant Data entry into Vigiflow Reporting to PvPI National
Coordinating Centre Training/ sensitization/ feedback to
physicians through newsletterscirculated by PvPI NCC
PvPIADRMonitoring Centre otherthan medical colleges
[Corporate hospitals, autonomousinstitutes, Pharmaceutical industry,public health programmes]
Collection of ADR reports Perform follow up with the complainant Report the data to CDSCO HQ
PvPI National Coordinating Preparation of SOPs guidance documents &
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PvPI National CoordinatingCentre(PvPI NCC ,IPCGhaziabad)
Preparation of SOPs, guidance documents &training manuals
Data collation, Cross-check completeness,Causality Assessment
Conduct Training workshops of enrolled centers
Publication of Medicines Safety Newsletter Reporting to CDSCO HQ Analysis of the PMS, PSUR, AEFI data received
from CDSCO HQ
ZONAL/Subzonal CDSCO
Offices
Provide procurement, financial and administrative
support to ADR monitoring centers Report to CDSCO HQ
CDSCO, HQ, New Delhi Take appropriate regulatory decision & actions onthe basis of recommendations of PvPI NCC
Propagation of medicine safety related decisions tostakeholders
Collaboration with WHO-Uppsala MonitoringCenter - Sweden
Provide for budgetary provisions & administrativesupport to run National PvPI
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Safety Database
Vigiflow software provided by WHO-UppsalaMonitoring Centre utilized as safety database
All data originating from India will be maintained in asecure and confidential manner
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Risk Management
Ensure availability & management of funds
Conduct frequent training & awareness of
Pharmacovigilance
Detect & respond to under reporting of ADRs
Ensure quality of filled ADR forms
Proper supervision of functioning of centers
Feed back to Health Care Professionals
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Monitoring & Evaluation
i. Process Indicators No. of ADR monitoring centers, AMC personnel trained
Funds budgeted & spent
ii. Outcome Indicators Software platform established
No. of ADR reports received/processed/submitted to Vigiflow
iii. Impact Indicators No. of signals generated & confirmed
No. of safety related alerts issued by CDSCO
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FDAAA (FDA Amendments Act)
Passed in 2007; Effective since 2008
FDAA Title XI :
demands REMS (Risk Evaluation & Mitigation Strategy)for identified drugs
imposes stricter post marketing safety surveillance frommarketing authorization holders (MAH)
New FDA Initiatives to enhance Drug
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New FDA Initiatives to enhance Drug
safety during development
Industry guidance document for premarketing safetyassessment for drug induced liver injury
Safe Use Initiative, 2009 - to reduce the likelihood ofpreventable harm from medication use & devisingmechanism to overcome harm
IND regulation revision, Sep 2010 - governs safety reportingrequirements for INDs & BA/BE studies
New FDA Initiatives to enhance Drug
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New FDA Initiatives to enhance Drug
safety during development
(contd) New FDA requirements designed to :
Improve usefulness & quality of safety reporting & ability
to review critical information Strengthen ability to review critical safety information
Improve safety monitoring of human drug & biologicals
Harmonize safety reporting with recommendations byICH, CIOMS, EU
Some EU Legislation in
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Some EU Legislation in
Pharmacovigilance development
Risk Management Plan - introduced in 2005
to ensure that benefitsof a particular medicine exceed risks
EU Directive 2010/84 -(published in Dec 2010; to be in effect from July2012) - enforces EU coordination of PV activities via coordinationgroup/PV Risk Assessment Committee
Direct reporting of SAR (suspected adverse reactions)by HCPs &patients
Improved SmPC (Summary of Product Charateristics) of a drug
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Newer EU initiatives in drug safety
ENCePP: European Network of Centres forPharmacoepidemiology & Pharmacovigilance
To enhance post authorization monitoring of medicinalproducts by multicentre safety / lack of efficacy studies
EU Innovative Medicines Initiative : IMI
Stakeholder collaboration to accelerate development ofeffective medicines with fewer adverse effects
by improved predictivity of safety & efficacy; knowledge
management; education & training
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Are we truly committed to
Pharmacovigilance? 1986 Proposal for a formal ADR monitoring in 12
regional centres, each covering 50 million,
1989, Drug controller ,India set up , 6 regional centres
Mumbai, New Delhi, Kolkata, Lucknow, Pondicherry &Chandigarh.
1997, India joined WHO International Drug MonitoringProgram by Uppsala Monitoring Centre, Sweden.
Dept of Pharmacology, AIIMS was identified as thenational centre,
Of the six centres, only Mumbai & Delhi were active,
Yet spontaneous reporting of ADRs was poor.
National Pharmacovigilance
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National Pharmacovigilance
Programme (NPVP) : Abortive
attempt? CDSCO launched NPVP in November 2004. World Bank annual grant of US$ 0.1 million for 5 yrs
Became functional from January 2005
2 zonal centres with 3 regional centres under them
Manipal reported ADRs to regional centre at JIPMER
World bank funds ended in 2009
Manipals ADR reports started piling up
Nobody forwarded our reports to Uppsala
Uppsala suspended its India connection.
PvPI is the third attempt at Pharmacovigilance!!
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Global PV Challenges
Globalization
increased exposure of massive populations to largevolumes of medicines
Web-based sales and information
uncontrolled sale of medicines across nationalborders
Broader safety concerns- array of medicinal productsgrows
Public health versus pharmaceutical industry
economic growth
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Global PV Challenges (contd)
Monitoring of established products
Monitor safety of generics throughout the world
Developing and emerging countries Outside OECD countries, pharma industry not been
committed to pharmacovigilance
Attitudes and perceptions to benefit and harm
Morbidity/mortality from drug-induced diseases recentlybeing recognized as important in public health.
Outcomes and Impact
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Conclusion FROM thalidomide tragedy (1950) TO recent rofecoxib &
rosiglitazone controversy science of PV has come a longway
PVvery reactive nature Evolved from a mere regulatory requirement for marketing
proactive generation of safety signals for marketed drugs
PV most important bridge between patient, HCPs &pharma companies for safer health care
India is waking up!! Professional
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Thank you!
Jai PvPI
Jai Hind!