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Perspectives and Achievements with Rational Pharmacotherapy The role of the authorities Gunnar Alvan MD, Ph D, Prof Director General Medical Products Agency (MPA) Gunnar Alvan November 2002 Rational pharmacotherapy Rational or based on reason would mean science or evidence based Gunnar Alvan November 2002 Science The gold standard for regulatory work T. Sjöstrand 1907-1987 "Science is a social process through which man, by making observations and experiments is providing factual data to found a system of concepts which will approximately describe reality as we experience it and which should be tested by further observations and experiments." (translation by G.A.) Gunnar Alvan November 2002 What is rational pharmacotherapy? An ideal situation 1. Indication for drug therapy in relation to all prevailing circumstances: age, disease, abuse, pregnancy, sex, nutrition, concomitant drug use or other strategy…. 2. Choice of drug according to factual criteria: pathophysiology, mechanism of action, the above conditions, characteristics of drug product…. Gunnar Alvan November 2002 What is rational pharmacotherapy? An ideal situation 3. Drug treatment should be carried out according to knowledge based principles: choice of dose, evaluation of effect, dose adjustment, therapy and adverse effect monitoring. 4. Therapy should be withdrawn when a defined and preset endpoint has been reached. Gunnar Alvan November 2002 Pharmacotherapy The role of authorities • Great mission to fulfil • Goal given in the official instruction • Contribute on many levels Gunnar Alvan November 2002 The emphasis for authorities has shifted Scientific evaluation of documents Post approval laboratory control Information (SPC, PIL) Pharmacovigilance Therapeutic advice Media Environment Gunnar Alvan November 2002 The role of the authorities • Preregistration – Clinical trials, compassionate use • Registration – Evaluation and approvals • Post registration – – – – – Information, follow-up studies ADR monitoring, evaluation, actions Control laboratories Inspections Legal actions (advertisements, illegal claims etc) Gunnar Alvan November 2002 Role of guidelines • Rationality - scientifically based work • The guidelines are continuously developed and reflect the movement of the research front. Gunnar Alvan November 2002 Scientific domain Observation Description Analysis Cause-effect relationship Statistical perspective: reality/uncertainty Objectivity Reproducibility Hypothesis: confirmation/rejection Consistence Evolution Gunnar Alvan November 2002 Adopted Guidelines 2002 (Efficacy, Safety and Quality) Note For Guidance on: • Clinical Investigation of Medicinal Products in the Treatment of Diabetes Mellitus • Clinical Investigation of Medicinal Products in the Treatment of Depression • Clinical Investigation of Medicinal Products in the Treatment of Peripheral Arterial Occlusive Disease • Carcinogenic potential • Photosafety Testing • Quality of Water for Pharmaceutical Use • Requirements for Pharmaceutical Documentation for Pressurised Metered Dose Inhalation Products Gunnar Alvan November 2002 Abbreviations • SPC: Summary of Product Characteristics • PIL: Package Insert Leaflet • EPAR: European Public Assessment Report Gunnar Alvan November 2002 SPC and PIL • Products description documents with instructions for use • Founded on evaluated facts presented in registration file • Anyone can view • Problems: update, translation, disharmony, no reference list Gunnar Alvan November 2002 Aim of PIL • Patients can be aware of and correctly use the product • Communication task, should be easy to read • Problem: neglected? negativity? Gunnar Alvan November 2002 At the time of approval…. • Is it possible for the professionals in the health care system to evaluate new drugs? • To which extent is it possible to find clinical studies in PubMed at the time of approval of new drugs? Gunnar Alvan November 2002 Number of published studies vs total number of clinical studies Cipralex Zyban Vioxx Synagis Subutex Sonata Reminyl Relenza Nexium Celebra Avandia 0 10 20 30 40 50 Number Published studies Clinical studies Gunnar Alvan November 2002 Treatment guidelines Expert meetings (6-8/year) together with the Norwegian drug authority . with reviews as basis Internet Guidelines WS-books Information pharmacists Drug committees Information from the MPA bulletin Gunnar Alvan November 2002 Continuous drug communication is the basis for rational drug use • New drugs • New knowledge about old drugs • How to use the drug- treatment guidelines Gunnar Alvan November 2002 Non commercial drug information actors • Drug committees and Public drug information centres • Drug regulatory agencies • Pharmacies • Independant drug bulletins i.e. La Revue Prescrire and The International Prescriber • Medical technology assessment and research Gunnar Alvan November 2002 organisations From darkness into light • Drug monographs on NCE:s and new indications – Presentation of all, including unpublished, clinical trials – Safety assessment – Comments on the value of the drug Gunnar Alvan November 2002 Distribution of the information • Information from the MPA ”Bulletin” • Internet - www.mpa.se • A workshop book series • Drug committees • Information propagated from doctors and pharmacists Gunnar Alvan November 2002 Is the drug information role hampered by legal requirements? • NO! • However, the file is under business secrecy. • The approval, SPC and monographs is the outcome of the total file submitted. • There is no crucial information ”hidden” in the files, but there will be bias in publication and citation. Gunnar Alvan November 2002 DTC - direct to consumer advertising • The European Parliament voted against the Commissions proposal to allow companies to communicate directly with consumers about some prescription medicines. A personal view: • No inhibition of Internet sites that discuss drug treatment. • Advertising in public media for Rx is not in the interest of public health. The public sector will have to pay for the advertising and also receive information without tools to evaluate its reliability. Gunnar Alvan November 2002 Made up DTC examples Slogans we will not see in the underground • Got cystitis? Get Uricure®! • No more morning anxiety with Gloomy®! • When it comes to high blood pressure use A-stop®, turns off your A-II receptors better than any other drug! • Erected on Niagara®! • Get high on Himalaya®! Gunnar Alvan November 2002