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Pharmacovigliance in India: Dreams Vs Reality

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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!


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