Dia Psur 6-15-04

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"The Utility of the Periodic Safety Update Report as a Useful Source of Medical Information"

Michael J. Klepper, MD President and CEO Integrated Safety Systems, Inc. Research Triangle Park, NC
ISS, Inc. 2004

Topics
Purpose and Origin of the PSUR Format and Content Strengths and Weaknesses Utility for Providing Important Medical Information

ISS, Inc. 2004

Purpose and Origin of the PSUR

ISS, Inc. 2004

Periodic Safety Report for Marketed Drugs = PSUR

ISS, Inc. 2004

Purpose of the PSUR


A stand alone global-standardized document that can be used worldwide for:
Identification of new safety signals Identification of changes to benefit-risk profile of medical product
Change in product label Change in product name/package/promotional material Dear Doctor Letter Need for risk management initiatives Withdrawal from the market

Monitoring effectiveness of risk management initiatives


ISS, Inc. 2004

Periodic Reports
For marketed products Quarterly for first three years, annually thereafter (US) - current PSUR - every 6 months for first 2 years, annual for 3 years, then every 5 years US Traditional Adverse Drug Reaction Periodic Report very different than PSUR PSUR currently used in European Union, Japan, other countries
ISS, Inc. 2004

Origin of PSUR
1992 - International Reporting of Periodic Drug-Safety Update Summaries (Council for International Organizations of Medical Sciences [CIOMS] II) 1996 - Guidance for Industry E2C Clinical Safety Data Management: Periodic Safety Update Reports for Marketed Drugs

ISS, Inc. 2004

Origin of PSUR
2001 - Current Challenges in Pharmacovigilance: Pragmatic Approaches (CIOMS V) 2002 Draft Consensus Guideline Addendum to ICH E2C Clinical Safety Data Management Periodic Safety Update Reports for Marketed Drugs
ISS, Inc. 2004

Proposed US Safety Regulations The TOME


Change periodic report to PSUR format (ICH E2C) Periodicity
Every six months for the first 2 years Annually for the next 3 years Every 5 years thereafter

Interim Periodic Safety Report (IPSR)


At 7.5 years and 12.5 years after U.S. approval Same information as PSUR excluding summary tabulations
ISS, Inc. 2004

Format and Content

ISS, Inc. 2004

Key PSUR Definitions


Company core data sheet (CCDS) Company core safety information (CCSI)
Safety information in CCDS

Listed/Unlisted
Based on CCSI (expected/unexpected based on country-specific product information)
ISS, Inc. 2004

Key PSUR Definitions


International Birth Date (IBD)
First approval in the world

Data Lock Point (DLP)


Cut-off date for data to be included in report

ISS, Inc. 2004

Table of Contents of PSUR


Introduction Worldwide market authorization Update of regulatory authority or MAH actions taken for safety reasons Changes in reference safety information Patient exposure Presentation of individual case histories
ISS, Inc. 2004

Table of Contents of PSUR


Studies Other information Overall safety evaluation Conclusion Appendix
Company Core Data Sheet Consumer Reports (US)
ISS, Inc. 2004

Table of Contents of PSUR


Introduction
Brief summary of the the drugs characteristics When the data lock date was, and what period of time the report covers What number the report represents, e.g., this is the first periodic report, this is the 6th periodic report
ISS, Inc. 2004

Table of Contents of PSUR


Worldwide market authorization
Typically a table summarizing:
Countries where the drug has been approved Countries where there was a lack of approval, etc.

ISS, Inc. 2004

Table of Contents of PSUR


Update of regulatory authority or MAH actions taken for safety reasons - for example:
Failure to obtain marketing re-authorization Withdrawal from the market Suspension of clinical trials, etc.

ISS, Inc. 2004

Table of Contents of PSUR


Changes in reference safety information
Summarizes what changes to CCSI have or will be made from current one

ISS, Inc. 2004

Table of Contents of PSUR


Patient exposure
Estimate of exposure and methodology used:
Number of tablets sold Number of bottles of medication distributed Number of prescriptions written

ISS, Inc. 2004

Table of Contents of PSUR


Presentation of individual case histories
Listings Capsule view of all the AEs reported by a patient with the most serious listed first
All serious reactions, and non-serious unlisted reactions, from spontaneous notifications; All serious reactions (attributable to drug by either investigator or sponsor), available from studies or namedpatient (compassionate) use; All serious reactions, and non-serious unlisted reactions, from the literature; All serious reactions from regulatory authorities

Tabulation of AEs including a tabulation for nonserious, listed reactions Analysis of individual case histories
ISS, Inc. 2004

Table of Contents of PSUR


Studies
Completed studies with new safety information

ISS, Inc. 2004

Table of Contents of PSUR


Other information
New relevant efficacy information Late breaking news

ISS, Inc. 2004

Table of Contents of PSUR


Overall safety evaluation - A concise analysis of the data presented, taking into account any late-breaking information, and followed by the MAHs assessment of the significance indicating a change in the benefit-risk profile of the drug
In addition:
Specifically looks at certain populations, e.g., elderly, pediatric, pregnancy Drug interactions Overdose Long-term effects Etc
ISS, Inc. 2004

Table of Contents of PSUR


Conclusion
Should indicate the safety findings that are different than that found in the current reference safety information Indicate what actions were or will be taken
Change in CCSI Risk management initiatives, etc.

ISS, Inc. 2004

Table of Contents of PSUR


Appendix
Company Core Data Sheet Consumer Reports (US)

ISS, Inc. 2004

Strengths and Weaknesses

ISS, Inc. 2004

Strengths
Aggregate data to better identify new safety signals especially rare adverse events Worldwide data safety signal strengthened if seen in more than one country Multiple sources of information - also strengthens the safety signal
Spontaneous reports Healthcare professionals, Consumers (US) Literature Studies Animal Findings ISS, Inc. 2004

Weaknesses
Resource intensive Quality dependent Garbage in garbage out No set numerator or denominator to calculate accurate incidences Retrospective, potentially biased Safety signal identification (not verification) Label change required before information can be used officially
ISS, Inc. 2004

Utility for Providing Important Medical Information

ISS, Inc. 2004

Utility for Providing Important Medical Information


Hypothesis generating need for new study(ies) results ultimately affect medical information Change in label new medical information Dear Doctor Letter new medical information Metrics determines effectiveness of content of/mechanism of providing, medical information
ISS, Inc. 2004

Knowledge is Power!

ISS, Inc. 2004

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