Article

Risk Management Policy and Black-Box Warnings: A Qualitative Analysis of US FDA Proceedings

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Abstract

The US FDA increasingly applies risk management to drug safety policy. Little is known about the process by which the FDA approves labelling changes. Although advisory committees can recommend any of the risk management tools, including the use of 'black-box warnings', it is unknown whether they deliberate on these questions or how they apply the principles of risk minimization or management during their considerations of drug licensing. To examine the process by which risk management is considered by the FDA, including the role of FDA advisory committees. We also aimed to identify and describe drug labelling changes and additions, including the prevalence of black-box warnings. We electronically obtained publicly available information regarding drug approvals, drug revisions and advisory committee meetings over 3 years (2004-6) from the FDA. Data in the form of meeting transcripts and full histories of labelling changes were collected on drugs discussed by advisory committees. We then searched and qualitatively analysed the meeting transcripts to identify themes in the discussion. We also created a database of all prescription drug labelling changes for 3 years and examined which drugs have had the most changes. We describe the risk management consideration process and report the frequency and characteristics of labelling changes. Excerpts from the transcripts are selected to illustrate both typical and atypical features of the discussion. A total of 174 black-box changes were made in the 3-year period of our study, of which 77 were new black-box warnings and 97 were revisions in black-box warnings. Of 77 new black-box warning additions, only 11 drugs were discussed by the advisory committees. Of the 17 most frequently revised drug labels in these 3 years, two were discussed in the advisory committee meetings. Advisory meeting discussions revealed confusion about black-box warnings and emphasized potential consequences of the warnings rather than their content. The safety labelling of drugs on the market is changed often. Panels of advisors consider only a few drugs, rarely discuss the labelling requirements, and display confusion about applying black-box warnings. The creation and application of black-box warnings on prescription medications should receive closer attention from the FDA and its advisors.

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... Beliefs surrounding risk management are cognitions that an individual uses to evaluate risks while also identifying ways to minimize negative outcomes (Connor & Normal, 2005). Risk management beliefs about consumer products are likely to affect consumer risk and harm perceptions of those products. ...
... One category of risk management beliefs involves organizational or institutional risk management beliefs held by the consumer. For example, to assess and minimize risk of consumer products, such as prescription drugs and medical devices (Cook et al., 2009;Task Force on Risk Management, 1999;Hamburg & Sharfstein, 2009), FDA implements risk management strategies (e.g., standards of product efficacy and safety) (Hamburg & Sharfstein, 2009;Federal Food, Drug, and Cosmetic Act, 1938;Greene & Podolsky, 2012;Kefauver Harris Amendment (Drug Amendments of 1962), 1962. Consumers who are aware of FDA regulatory authority over products such as drugs or medical devices are likely to perceive increased safety associated with those products as the role of FDA is to minimize risk through regulation and enforcement (Hamburg & Sharfstein, 2009). ...
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The research-based pharmaceutical industry in the US strongly supports the concepts of risk management and sees formal risk management as playing a major role in the development of safe medicines for the public, as well as providing a mechanism to ensure that decisions concerning individual drug benefit and risk are made based on scientific evidence. Safe medicines refer to those drugs whose benefits have been found to outweigh their risks when they are used according to the approved labelling. Risk management is the comprehensive and proactive application of scientifically based methodologies to identify, assess, communicate and minimise risk throughout the life cycle of a drug so as to establish and maintain a favourable benefit-risk balance in patients. Although there are certainly a number of global risk management initiatives in place or being undertaken, harmonisation has yet to be achieved. Industry is faced with a variety of different risk management approaches and tools. There is a need to move the focus of risk management from the post-approval arena to earlier in the development process and tools need to be developed to support risk management throughout the lifecycle of a drug. The focus in the US on risk minimalisation strategies will also be an area for methodological development. A key factor in the success of overall risk management is the dialogue between industry and regulators throughout the development, review and marketing of the product. It is through such dialogue that appropriate, efficient and effective risk management strategies will be developed and implemented and the best decisions regarding the safe use of pharmaceutical products will be made.
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America's governing system is unique in the extent to which scientists and other outside experts participate in the policy process. No other nation has used these experts as extensively - not merely for advice on the allocation of resources to science but in broad policy issues. This wide-ranging study traces the rise of scientists in the policy process and shows how outside experts interrelate with politicians and administrators to produce a unique and dynamic policy process. It also shows how the very openness of American government creates the potential for unusual conflicts of interest. Bruce Smith focuses on the experiences of agency and presidential-level advisory systems over the past several decades. He chronicles the special complexities and challenges resulting from the Federal Advisory Committee Act - the "open meeting" law - to provide a better understanding of the role of advisory committees and offers valuable lessons to guide their future use. He looks at science advice in the Departments of Defence, State, and Energy; the National Aeronautics and Space Administration; and the Environmental Protection Agency; then focuses on how science advisory mechanisms have worked at the White House. Rather than simply providing a description of structures and institutions, Smith shows the advisory systems in action - how the committees work or fail to work in practice. He analyzes how the advisory mechanisms influence the policymaking process and affect the life of the agencies they serve. Smith concludes with an assessment of the relationship between science advice and American democracy. He explains that the widespread use of advisory committees clearly reflects America's preference for pluralism. By scrutinizing agency plans, goals, and operations, these committees serve a variety of functions and attempt to strike a balance between citizen access to government and the need for sophisticated expertise. The challenge to the nation is to reconcile the integrity of science with the norms of democracy.
Article
Counseling psychologists face many approaches from which to choose when they conduct a qualitative research study. This article focuses on the processes of selecting, contrasting, and implementing five different qualitative approaches. Based on an extended example related to test interpretation by counselors, clients, and communities, this article provides a detailed discussion about five qualitative approaches— narrative research; case study research; grounded theory; phenomenology; and participatory action research—as alternative qualitative procedures useful in understanding test interpretation. For each approach, the authors offer perspectives about historical origins, definition, variants, and the procedures of research.
Article
The purpose of this review was to estimate the extent of under-reporting of adverse drug reactions (ADRs) to spontaneous reporting systems and to investigate whether there are differences between different types of ADRs. A systematic literature search was carried out to identify studies providing a numerical estimate of under-reporting. Studies were included regardless of the methodology used or the setting, e.g. hospital versus general practice. Estimates of under-reporting were either extracted directly from the published study or calculated from the study data. These were expressed as the percentage of ADRs detected from intensive data collection that were not reported to the relevant local, regional or national spontaneous reporting systems. The median under-reporting rate was calculated across all studies and within subcategories of studies using different methods or settings. In total, 37 studies using a wide variety of surveillance methods were identified from 12 countries. These generated 43 numerical estimates of under-reporting. The median under-reporting rate across the 37 studies was 94% (interquartile range 82–98%). There was no significant difference in the median under-reporting rates calculated for general practice and hospital-based studies. Five of the ten general practice studies provided evidence of a higher median under-reporting rate for all ADRs compared with more serious or severe ADRs (95% and 80%, respectively). In comparison, for five of the eight hospital-based studies the median under-reporting rate for more serious or severe ADRs remained high (95%). The median under-reporting rate was lower for 19 studies investigating specific serious/severe ADR-drug combinations but was still high at 85%. This systematic review provides evidence of significant and widespread under-reporting of ADRs to spontaneous reporting systems including serious or severe ADRs. Further work is required to assess the impact of under-reporting on public health decisions and the effects of initiatives to improve reporting such as internet reporting, pharmacist/nurse reporting and direct patient reporting as well as improved education and training of healthcare professionals.
Article
This study investigated crisis-response communication strategies Merck used in the first 4½ months following its recall of Vioxx by analyzing a variety of controlled corporate communications. As prescribed by Coombs's (1995) transgression decision flowchart and crisis communication standards (Coombs, 2004b), Merck used both rebuilding–mortification and reinforcing–ingratiation responses. However, Merck employed a new type of mortification—"rectification without assuming responsibility"—by making rectification through its corrective action of recalling Vioxx but without ever admitting fault, apologizing, or asking forgiveness for causing grave injury and death to Vioxx consumers. Analysis of 200 news or editorial items about Merck's Vioxx recall during the same period found The New York Times and The Wall Street Journal reported news of Merck's message strategies similarly. The study concluded the rectification without assuming responsibility response should be subjected to experimental testing and, depending on results, perhaps be added to the crisis strategy repertoire. Merck also used new "crisis events misrepresented" denial and "too soon to know/no answer yet" distance strategies, perhaps to its detriment, and these responses should be tested further.
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Article
Risk perceptions are important to the policy process because they inform individuals’ preferences for government management of hazards that affect personal safety, public health, or ecological conditions. Studies of risk in the policy process have often focused on explicating the determinants of risk perceptions for highly salient, high consequence hazards (e.g., nuclear energy). We argue that it is useful to also study more routinely experienced hazards; doing so shows the relevance of risk perceptions in individuals’ daily lives. Our investigation focuses on the impact perceived risk has on citizens’ preferences over hazard management policies (as distinct from identifying risk perception determinants per se). We use a recursive structural equation model to analyze public opinion data measuring attitudes in three distinct issue domains: air pollution, crime, and hazardous waste storage and disposal. We find that citizens utilize perceived risk rationally: greater perceived risk generally produces support for more proactive government to manage potential hazards. This perceived risk–policy response relationship generally holds even though the policy options respondents were asked to consider entailed nontrivial costs to the public. The exception seems to be when individuals know less about the substantive issue domain.
Article
Two myths about qualitative research are that real qualitative researchers do not count and cannot count. These antinumber myths have led to the underutilization of numbers in qualitative research and to the simplistic view of qualitative research as non- or antinumber. Yet numbers are integral to qualitative research, as meaning depends, in part, on number. As in quantitative research, numbers are used in qualitative research to establish the significance of a research project, to document what is known about a problem, and to describe a sample. But they are also useful for showcasing the labor and complexity of qualitative work and to generate meaning from qualitative data; to document, verify, and test researcher interpretations or conclusions; and to re-present target events and experiences. Although numbers are important in the treatment of qualitative data, qualitative researchers should avoid the counting pitfalls of verbal counting, overcounting, misleading counting, and acontextual counting. © 2001 John Wiley & Sons, Inc. Res Nurs Health 24: 230–240, 2001
Article
Risk evaluation and mitigation strategies (REMS) formerly known as Risk Minimization Action Plans (RiskMAPs) are a regulatory technique for dealing with anticipated risks of new medications and are especially important for new drugs with abuse potential. This paper describes the origin and history of risk-management plans for drugs that might be abused, the proper use of these plans in minimizing the risk to the public, and the special difficulties inherent in managing risks for drugs with abuse potential. Drugs with abuse liability are distinctive since the risks inherent in manufacture and distribution include not only risks to patients prescribed the medications, but also risks to the general public including subgroups in the population not intended to get the drug and who receive no medical benefit from the medication. The crafting of risk-management plans intended to protect nonpatient populations is unique for these products. The content, extent, and level of intensity of these plans affect areas of medical ethics, civil liability, and criminal prosecution. The need for risk-management plans for drugs with abuse liability can potentially act as a deterrent to investment and is a factor in decisions concerning the development of new medications for the treatments of pain, ADHD, anxiety disorders, and addictions. This paper provides a framework for moving the process of REMS development forward and criteria for evaluating the probity and adequacy of such programs.
Article
This article has no abstract; the first 100 words appear below. In 2005, after receiving case reports of suicides by patients taking anticonvulsant medications, the Food and Drug Administration (FDA) asked the manufacturers of 11 drugs in this class to report all suicide-related events in the controlled trials they had conducted over many years. This past January, nearly 3 years later, the agency completed its analysis of these data and announced that it had found a near-doubling of suicidal ideation and behavior among trial subjects randomly assigned to receive these drugs rather than placebo¹ (odds ratio, 1.8; 95% confidence interval [CI], 1.2 to 2.7²). For patients in epilepsy studies, the . . . No potential conflict of interest relevant to this article was reported. Source Information Dr. Avorn is a professor of medicine at Harvard Medical School, chief of the Division of Pharmacoepidemiology and Pharmacoeconomics at Brigham and Women's Hospital, and director of the Harvard Interfaculty Initiative on Medications and Society — all in Boston.
The objectives of this study were 1) to determine the frequency with which adverse drug events result in an incident report (IR) in hospitalized patients; and 2) to determine if there were differences between quality assurance administrators, nurse leaders in quality assurance, and staff nurses as to whether an incident report should or would be filed for each adverse drug event. All patients admitted to five patient care units (one medical intensive care unit, two surgical intensive care units, and two medical general care units) in one academic tertiary care hospital were studied between February and July 1993. The main outcome measures used were adverse drug events (ADEs) and IRs. Consensus voting was used by senior hospital administrators, nursing leaders, and staff nurses to determine whether an adverse drug event should have been reported and would have been reported. Of 54 adverse drug events identified by the study, only 3 patients (6%) had a corresponding incident report submitted to the hospital's quality assurance program or called into the pharmacy hotline. One additional ADE was identified by an IR, but not by the ADE study. Of the 55 ADEs, 15 were preventable, and 26 were serious or life-threatening, yet only 2 of the 26 led to an incident report. The three voting groups agreed that most ADEs justified an IR, but judged that in actual practice, an IR would infrequently have been filed. Voluntary reporting identified only a small fraction of ADEs. Using IRs for quality assurance/quality improvement will lead to significant bias when assessing quality of care.
Article
Publishing case reports of suspected ADRs in medical journals is an established way of alerting others to possible drug hazards. However, it has limitations as only a very small proportion of cases can be published, reports are sometimes poorly documented, publication depends on editorial selection and there is often considerable delay between occurrence and publication. Companies and some regulatory authorities actively monitor the published literature for such reports. This will involve screening key journals where ADRs are described, monitoring publications such as ‘Reactions Weekly’ (ADIS International) and running regular standard searches on databases such as Medline and Excerpta Medica. With efficient regulatory and company safety surveillance it is now relatively rare for a new ADR to be signalled primarily through published cases, however, publication of well characterised ADRs still fills an important function in alerting physicians. A more recent development is reports of possible ADRs appearing on the Internet and many companies are still determining how they should best handle them.
Article
The U.S. Food and Drug Administration (FDA) is responsible for protecting consumers from unsafe or ineffective drugs and medical devices. The agency's role is defined by a growing and increasingly complex set of statutes, which reflect Congress's desires, on the one hand, to prevent product hazards and, on the other, to expedite FDA review and approval of promising new medical technologies. Congress's latest attempt to calibrate regulation to achieve these goals, the 1997 Food and Drug Administration Modernization Act, endorses certain of the FDA's own innovations and changes in the agency's ways of doing business.
Article
Recently approved drugs may be more likely to have unrecognized adverse drug reactions (ADRs) than established drugs, but no recent studies have examined how frequently postmarketing surveillance identifies important ADRs. To determine the frequency and timing of discovery of new ADRs described in black box warnings or necessitating withdrawal of the drug from the market. Examination of the Physicians' Desk Reference for all new chemical entities approved by the US Food and Drug Administration between 1975 and 1999, and all drugs withdrawn from the market between 1975 and 2000 (with or without a prior black box warning). Frequency of and time to a new black box warning or drug withdrawal. A total of 548 new chemical entities were approved in 1975-1999; 56 (10.2%) acquired a new black box warning or were withdrawn. Forty-five drugs (8.2%) acquired 1 or more black box warnings and 16 (2.9%) were withdrawn from the market. In Kaplan-Meier analyses, the estimated probability of acquiring a new black box warning or being withdrawn from the market over 25 years was 20%. Eighty-one major changes to drug labeling in the Physicians' Desk Reference occurred including the addition of 1 or more black box warnings per drug, or drug withdrawal. In Kaplan-Meier analyses, half of these changes occurred within 7 years of drug introduction; half of the withdrawals occurred within 2 years. Serious ADRs commonly emerge after Food and Drug Administration approval. The safety of new agents cannot be known with certainty until a drug has been on the market for many years.
Article
The Food and Drug Administration and pharmaceutical manufacturers use "Dear doctor" letters to alert physicians about drug safety. To determine how such warnings may be improved, we retrospectively examined how variations in the wording of one series of "Dear doctor" letters affected their impact on concomitant dispensing of cisapride (Propulsid; Janssen Pharmaceutica, Titusville, NJ) and several medications contraindicated for concomitant use. Concomitant dispensing was defined as dispensing cisapride and a contraindicated medication on dates when the intended duration of the two dispensings overlapped on at least 1 day. Using outpatient pharmacy claims from a New England health insurer, we calculated a concomitant dispensing rate for each calendar month as the number of concomitant cisapride dispensings divided by the total number of cisapride dispensings. We grouped drugs contraindicated for concomitant use with cisapride as (1) explicitly named in the warnings, (2) only mentioned as examples of a drug class, or (3) only implied as drug class members. We used multivariate analysis to relate temporal changes in concomitant dispensing rates to type of warning (explicit, example, or implied), patient demographic characteristics, season, calendar year, and temporal relationship to the "Dear doctor" warnings. A highly publicized letter sent in June 1998 was associated with a notable decline (58%) in the concomitant dispensing rate with explicitly contraindicated drugs but not in the concomitant dispensing of cisapride with the example or implied drugs. An earlier letter, which had been explicit but was accompanied by less publicity, had no measurable effect on this study's measure of coprescription, nor did a later letter that emphasized comorbidities. Explicit, well-publicized drug warnings can change prescriber behavior.
Article
Drug development and regulation are often presented as purely matters of technical science. In this paper it is argued that, in principle, toxicology, clinical pharmacology and pharmacovigilance in drug testing and regulation are necessarily a combination of science and politics. This has important implications for how one attempts to make progress in drug regulation, such as in interpreting technical evidence and in the setting of regulatory standards with which evidence should be evaluated. In practice, drug testing and regulation are shown to be hybrids of science and politics. Moreover, drawing on existing empirical evidence, it is suggested that this mixture currently, and for some time, has had the wrong ingredients for optimal drug safety and public health outcomes. For example, too often the balance of the scientific doubts about drug safety are weighed to the interests of manufacturers rather than to those of patients and public health, while some scientific standards with which drug safety is to be interpreted are being reshaped in ways that give insufficient priority to the protection of public health. Finally, it is proposed that: drug regulation should include comparative efficacy testing; regulatory agencies should conduct some key tests, charging the costs to industry and without duplication; and the regulatory system should be less secretive and more accountable to public scrutiny. Greater efforts should be made to eliminate experts' conflicts of interest within the regulatory process.
Article
The importance of medication safety has been recognized for many years, but only recently has it reemerged as a major public health issue based on numerous recent studies and high-profile safety events.1 Drug safety dates back to the 1950s, when in response to reports of chloramphenicol-associated aplastic anemia, the American Medical Association established an adverse drug reaction (ADR) reporting system and the Food and Drug Administration began requiring pharmaceutical manufacturers to report ADRs.1 This effort to detect heretofore unknown, serious adverse effects of medications in postmarket use relied on voluntary reporting, which also became common practice in most health care organizations.
Article
Public policies to mitigate the impacts of extreme events such as hurricanes or terrorist attacks will differ depending on whether they focus on reducing risk or reducing vulnerability. Here we present and defend six assertions aimed at exploring the benefits of vulnerability-based policies. (1) Risk-based approaches to covering the costs of extreme events do not depend for their success on reduction of vulnerability. (2) Risk-based approaches to preparing for extreme events are focused on acquiring accurate probabilistic information about the events themselves. (3) Understanding and reducing vulnerability does not demand accurate predictions of the incidence of extreme events. (4) Extreme events are created by context. (5) It is politically difficult to justify vulnerability reduction on economic grounds. (6) Vulnerability reduction is a human rights issue; risk reduction is not.
Article
This article has no abstract; the first 100 words appear below. About 1000 committees advise the federal government. Many of them address scientific, technical, and medical issues. There is a continuing dispute about whether the administration of President George W. Bush has compromised the system of advisory committees by manipulating it for political and ideological reasons and seeking scientific advice that matches the administration's own views. In turn, administration officials have rejected these charges as politically motivated. They maintain that they are supporting a strong system, not subverting it by stacking the committees. The controversy comes at a time of exceptional partisanship in Washington, with major battles over many issues, including . . .
Article
Recent changes in the regulatory environment have called attention to the need for and potential benefits of greater and more detailed evidence to inform decisions based on the risk-benefit profile of medications. Nevertheless, access to potentially beneficial therapies continues to be impeded by a lack of sufficient information that could help optimize benefits and minimize risks of treatments for patients. Over-reliance on pre-marketing clinical trials and the FDA's spontaneous reporting adverse event system to support regulatory decisions has sustained an information void. Clinical trials are the gold standard for demonstrating efficacy, but they cannot fully predict safety when drugs are used in the real world. Spontaneous reporting can identify new signals, but cannot quantify those signals or place them in appropriate clinical context. In the face of new safety signals, absence of better information on how medications are used and how they perform in the real world setting, regulators are often limited to either continuing drug marketing without significant changes or withdrawing a medication from the market. Experience shows that information collected proactively, to better understand the background risks associated with the underlying disease and to better quantify the product risks, can influence these decisions to include a wider range of options regarding a product's availability, labeling and additional risk management strategies. This article presents several case studies of medications, including those in which insufficient data were available to address important safety signals and decisions were made to withdraw products, as well as those in which epidemiologic data were available to provide reassurance of product safety and allow continued product use, even though some may be marketed with additional risk management programs. More extensive and earlier epidemiologic assessment of risks and benefits of new products will create a new standard of evidence for industry and regulators and is likely to result in more effective and balanced regulatory actions, thereby affording better care for patients.
Article
The research-based pharmaceutical industry in the US strongly supports the concepts of risk management and sees formal risk management as playing a major role in the development of safe medicines for the public, as well as providing a mechanism to ensure that decisions concerning individual drug benefit and risk are made based on scientific evidence. Safe medicines refer to those drugs whose benefits have been found to outweigh their risks when they are used according to the approved labelling. Risk management is the comprehensive and proactive application of scientifically based methodologies to identify, assess, communicate and minimise risk throughout the life cycle of a drug so as to establish and maintain a favourable benefit-risk balance in patients. Although there are certainly a number of global risk management initiatives in place or being undertaken, harmonisation has yet to be achieved. Industry is faced with a variety of different risk management approaches and tools. There is a need to move the focus of risk management from the post-approval arena to earlier in the development process and tools need to be developed to support risk management throughout the lifecycle of a drug. The focus in the US on risk minimalisation strategies will also be an area for methodological development. A key factor in the success of overall risk management is the dialogue between industry and regulators throughout the development, review and marketing of the product. It is through such dialogue that appropriate, efficient and effective risk management strategies will be developed and implemented and the best decisions regarding the safe use of pharmaceutical products will be made.
Article
Although it is often vigorously contested and has several different formulations, the precautionary principle has in recent decades guided environmental policy making in the face of scientific uncertainty. Originating from a criticism of traditional risk assessment, the key element of the precautionary principle is the justification for acting in the face of uncertain knowledge about risks. In the light of its growing invocation in various areas that are related to public health and recently in relation to drug safety issues, this article presents an introductory review of the main elements of the precautionary principle and some arguments conveyed by its advocates and opponents. A comparison of the characteristics of pharmaceutical risk management and environmental policy making (i.e. the setting within which the precautionary principle evolved), indicates that several important differences exist. If believed to be of relevance, in order to avoid arbitrary and unpredictable decision making, both the interpretation and possible application of the precautionary principle need to be adapted to the conditions of pharmaceutical risk management.
Article
By going beyond individual case studies and solely quantitative surveys, this paper systematically examines why there were over twice as many new prescription drugs withdrawn from the market on grounds of safety in the UK as there were in the US between 1971 and 1992. Drawing on interviews with regulators, industry scientists and others involved, and on regulatory data never before accessed outside governments and companies, five key hypotheses which might explain this difference in drug safety withdrawals are analysed. These are: (1) simply because the UK approved more new drugs than the US; (2) because of an industrial corporate strategy to seek approval of 'less safe' drugs in the UK earlier; (3) because British regulators were more vigilant at spotting post-marketing safety problems than their US counterparts; (4) because the slowness of the US in approving new drugs enabled regulators there to learn from, and avoid, safety problems that had already emerged in the UK or European market; and (5) because more stringent regulation in the US meant that they approved fewer unsafe drugs on to the market in the first place. It is concluded that the main explanation for fewer drug safety withdrawals in the US is that the regulatory agency there applied more stringent pre-market review and/or standards, which took longer than UK regulatory checks, but prevented unsafe drugs marketed in the UK from entering the US market. Contrary to the claims frequently made by the pharmaceutical industry and regulatory agencies on both sides of the Atlantic, these results imply that it is likely that acceleration of regulatory review times in the US and the UK since the early 1990s is compromising drug safety.
Article
The Adverse Event Reporting System is the primary surveillance database used by the Food and Drug Administration for identifying postmarketing drug safety problems. We analyzed all reports of suspected adverse drug reactions submitted to the Food and Drug Administration from the inception of the Adverse Event Reporting System database in 1969 through December 2002. We documented drug withdrawals and restricted distribution programs based on safety concerns. During the 33-year period from 1969 when adverse drug event reporting was initiated through 2002, about 2.3 million case reports of adverse events for the cumulative number of approximately 6000 marketed drugs were entered in the database. Most reports were for female patients. During this period, numerous drug reactions have been identified and added to the product labeling as boxed warnings, warnings, precautions, contraindications, and adverse reactions. More than 75 drugs/drug products have been removed from the market due to safety problems. In addition, 11 drugs have special requirements for prescriptions or have restricted distribution programs. Drugs withdrawn or restricted represent a small proportion (about 1%) of marketed drugs. The Food and Drug Administration's Adverse Event Reporting System is the primary surveillance database used for the identification of safety problems of marketed drugs. Despite the limitations of underreporting, differential reporting, and uneven quality, submitted reports often allow the identification of serious adverse events that are added to the product labeling information. In rare instances, additional regulations, up to and including market removal, have been required. We encourage physicians, pharmacists, other health care professionals, and patients to continue to report serious suspected and known adverse drug reactions to manufacturers and the Food and Drug Administration.
Article
How the Food and Drug Administration (FDA) responds to criticism of its drug safety process will determine whether drug safety actually improves. Propping up the Office of Drug Safety with more bureaucratic prominence or adding new requirements to the preapproval process will add to the cost of drug development and not make drugs safer. New information tools can dramatically improve postmarketing surveillance and collection of data on safety. This information could then be used to reach more definitive regulatory conclusions sooner. New incentives will be needed to entice payers and product developers to work on building a broader, more robust system for collecting data on drug safety.
Article
Black box warnings (BBWs) are the Food and Drug Administration's (FDA) strongest labeling requirements for high-risk medicines. It is unknown how frequently physicians prescribe BBW drugs and whether they do so in compliance with the warnings. The purpose of the present study was to assess the frequency of use of BBW medications in ambulatory care and prescribing compliance with BBW recommendations. This retrospective study used automated claims data of 929 958 enrollees in 10 geographically diverse health plans in the United States to estimate frequency of use in ambulatory care of 216 BBW drugs/drug groups between 1/1/99 and 31/6/01. We assessed dispensing compliance with the BBW requirements for selected drugs. During a 30-month period, more than 40% of enrollees received at least one medication that carried a BBW that could potentially apply to them. We found few instances of prescribing during pregnancy of BBW drugs absolutely contra-indicated in pregnancy. There was almost no co-prescribing of contra-indicated drugs with the two QT-interval-prolonging BBW drugs evaluated. Most non-compliance occurred with recommendations for baseline laboratory monitoring (49.6% of all therapy initiations that should have been accompanied by baseline laboratory monitoring were not). Many individuals receive drugs considered to carry the potential for serious risk. For some of these drugs, use is largely consistent with their BBW, while for others it is not. Since it will not be possible to avoid certain drug- associated risks, it will be important to develop effective methods to use BBWs and other methods to minimize risks.
Article
In the past years, several drugs commonly used by allergy specialists have received a "black box" warning added to their package insert at the direction of the Food and Drug Administration (FDA). A "black box" warning is the highest level of 5 possible warning categories found in the package insert. The FDA has never articulated the basis for "black box" warnings. They generally appear to be based on clinical data, but occasionally can be based on serious animal toxicity. In the last several years, several drugs commonly used by allergists have received recommendations for "black box" warnings. Long-acting beta-agonists (salmeterol and formoterol) received "black box" warnings because of reports of the occurrences of severe asthma exacerbations in some patients with asthma, with some associated death. Topical calcineurin inhibitors (tacrolimus and pimecrolimus) received a recommendation for application of a "black box" warnings because of a possible increase of cancer developing in patients taking these drugs. Although the addition of a "black box" warning was recommended by the FDA Pediatric Advisory Committee for these 2 topical agents, the FDA has not yet implemented this warning. Informed consent principles require that a patient be adequately informed of the risks (among other components) of any recommended treatment. The risks, as described, of the long-acting beta-agonists and topical immunosuppressants should be presented to the patients to aid them in deciding whether they are willing to take these drugs when recommended by their physician.
Article
A prominently displayed boxed warning, the so-called "black box," is added to the labeling of drugs or drug products by the Food and Drug Administration when serious adverse reactions or special problems occur, particularly those that may lead to death or serious injury. Healthcare providers are often not knowledgeable about the origin, meaning, and implications of these "black box" warnings. In this review, our goal is to provide insight into how the Food and Drug Administration evaluates, communicates, and manages drug benefit/risk. We discuss drug labeling, the emphasis on safety throughout the drug approval process, legislative initiatives for safe use of drugs in children, and postmarketing safety surveillance. In addition, we encourage health care providers to report drug reactions to the Food and Drug Administration's MedWatch program. A discussion of new Food and Drug Administration initiatives to improve drug safety processes and methods to serve the public better are highlighted.
Article
The purpose of this review was to estimate the extent of under-reporting of adverse drug reactions (ADRs) to spontaneous reporting systems and to investigate whether there are differences between different types of ADRs. A systematic literature search was carried out to identify studies providing a numerical estimate of under-reporting. Studies were included regardless of the methodology used or the setting, e.g. hospital versus general practice. Estimates of under-reporting were either extracted directly from the published study or calculated from the study data. These were expressed as the percentage of ADRs detected from intensive data collection that were not reported to the relevant local, regional or national spontaneous reporting systems. The median under-reporting rate was calculated across all studies and within subcategories of studies using different methods or settings. In total, 37 studies using a wide variety of surveillance methods were identified from 12 countries. These generated 43 numerical estimates of under-reporting. The median under-reporting rate across the 37 studies was 94% (interquartile range 82-98%). There was no significant difference in the median under-reporting rates calculated for general practice and hospital-based studies. Five of the ten general practice studies provided evidence of a higher median under-reporting rate for all ADRs compared with more serious or severe ADRs (95% and 80%, respectively). In comparison, for five of the eight hospital-based studies the median under-reporting rate for more serious or severe ADRs remained high (95%). The median under-reporting rate was lower for 19 studies investigating specific serious/severe ADR-drug combinations but was still high at 85%. This systematic review provides evidence of significant and widespread under-reporting of ADRs to spontaneous reporting systems including serious or severe ADRs. Further work is required to assess the impact of under-reporting on public health decisions and the effects of initiatives to improve reporting such as internet reporting, pharmacist/nurse reporting and direct patient reporting as well as improved education and training of healthcare professionals.
Article
Therapeutic risk management is required to ensure that the benefits of a particular drug outweigh the risks in general practice. Current risk management strategies and handling of risk management and pharmacovigilance issues differ across borders. Differences in key regulatory decisions on the same product around the world, including the handling of safety issues with cisapride, dofetilide, and isotretinoin, bring into question the robustness of these decisions and the procedures currently in place to manage the risks to the public of products with potentially unfavorable risk-benefit balances. These differences may be partly due to differences in health care systems, regulatory requirements and procedures, and cultures. Greater international harmonization in approaches to risk management potentially would improve safety of medicines around the world by developing a greater uniformity in acquiring and interpreting risk-benefit evidence. The appropriateness and effectiveness of risk management interventions in different regions should be examined, and international strategies should be 'fine-tuned' for each regional health care setting. Recently issued international guidance on risk management and pharmacovigilance may help to improve consistency of decision-making around the world and promote better international communication and collaboration.