SLIDE 1 An agency of the European Union
Risk Management
Presented by: Dr Stella Blackburn EMA Risk Management Development and Scientific Lead
SLIDE 2 1
Topics
Some Pharmacovigilance concepts Why don’t we know all the side effects of a medicine? What are the new requirements for risk management plans What does a risk management plan look like How does it affect patients?
SLIDE 3
The Drug Developm ent Program m e
Cost of $1.3 - $11 billion Median time 11 years
(range 3 - > 25 years)
Median 1480 patients exposed
(range 129 - 9,400)
SLIDE 4 What we know at the end of the clinical trial programme
Efficacy
SLIDE 5 What happens when the drug is used in normal practice What is its adverse event profile
What we don’t know
Efficacy
SLIDE 6 Certain ethnic groups
Peopl eople of e often ex en excluded uded from
clini nical cal tr tria ials
Young Elderly W om en of childbearing age Pregnant w om en
SLIDE 7
people with concomitant disease
cardiac disease renal disease hepatic disease multiple impairments
- people on concomitant medication
Peopl eople e of
en ex excluded f uded from
clini nical cal t trial als
SLIDE 8 Other ADRs which are unlikely to be identified in clinical trials
- adrs which have a long latency
- adrs which need prolonged exposure
- adrs due to cumulative effects
- adrs which are rare
- adrs which mimic common diseases
SLIDE 9 8
Tim e Know ledge about drug W e need access to new m edicines as soon as possible W e w ant drugs to be as safe as possible
When to licence?
SLIDE 10
The Positive Benefit Risk Balance
Oh * * * * * ! the benefit risk balance has gone down to 4.3
SLIDE 11 10
At the tim e the m edicine is authorised, the benefits
- utw eigh the risks for the
average patient in the approved indication What we actually mean
SLIDE 12
The Risk management System
Definition:
a set of pharm acovigilance activities and interventions designed to identify, characterise, prevent or m inim ise risks relating to m edicinal products, including the assessm ent of the effectiveness of those interventions
SLIDE 13
Part I Part II Part III Part IV Part V Part VI Part VII Product(s) Overview Safety Specification Plans for post-authorisation efficacy studies Summary of the RMP Risk Minimisation Measures Annexes Pharmacovigilance Plan
New RMP structure
RMP is substance based
SLIDE 14 Information Flow in the RMP
Safety Specification Pharmacovigilance Plan Risk Minimisation Measures
Plans for post-authorisation efficacy studies
Summary of the RMP Product Overview
SLIDE 15 Safety specification
Identify:
what is known what is not known
Safety concerns Drug Disease Target population
Pharmacodynamics Pharmacokinetics How will it be used? Adverse event profile Class effects? Interactions? Level of confidence? Who was studied? Who wasn’t studied? Risk factors? What events can we expect in this population? Natural history Epidemiology What events occur as part of disease? Important identified risks Important potential risks Important missing information
SLIDE 16 Part I I I : Pharm acovigilance Plan
Routine PhV
activities
Safety concerns
I dentify and characterise
Risk Min Measures Measure effectiveness
Additional PhV activities
active surveillance case control studies cohort studies record linkage ( eHR) drug utilisation clinical trials Pre-clinical studies
SLIDE 17
Applicability of efficacy to all patients in the target population
Part I V: Plans for post-authorisation efficacy studies
List of post-authorisation efficacy studies
SLIDE 18 Prevent or m inim ise
Routine risk m inim isation
Part V: Risk Minim isation Measures
Safety concerns
Additional Risk Minim isation m easures
Controlled distribution Educational m aterial Patient alert card Patient m onitoring card Training program m es Legal status Pack size SPC Package leaflet Labelling
SLIDE 19
Summary of Product Characteristics (SmPC)
SLIDE 20 Package leaflet
19
SLIDE 21
Product Labelling
SLIDE 22 Prevent or m inim ise
Routine risk m inim isation
Legal status Pack size SPC Package leaflet Labelling
Additional Risk Minim isation m easures
Controlled distribution Educational m aterial Patient alert card Patient m onitoring card Training program m es
Part V: Risk Minim isation Measures
Safety concerns
SLIDE 23 Summary of the RMP
Possible options/ tools to communicate information on the RMP
1. Updated EPAR summary template
– Incorporate key information on the main safety concerns and measures taken to mitigate the risk
2. Produce a stand-alone RMP summary in lay language 3. Tabulated information in the assessment report
22
SLIDE 24 How does the RMP affect patients?
As a patient Routine risk minimisation Additional risk minimisation Providing input into the RMP Is the risk too great or should patients have the choice? Balancing needs for access with needs to minimise risk Is the educational material understandable?
23