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DRAFT SLIDES FOR NDA 21-198 ADVISORY COMMITTEE PRESENATIONS
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Pravachol 10 mg Tablets Rx to OTC Switch Daiva Shetty, M.D. Division of Over-the-Counter Drug Products (HFD-560) Food and Drug Administration Friday, July 14, 2000
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Actual Use Studies Background Simulate OTC Use Have few exclusion criteria Objectives depend on the specific product and concerns related to that product such as: compliance, dosing, duration of use off-label use safety and efficacy in OTC population
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Actual Use Issues for Pravachol Are consumers able to: self-diagnose know their own cholesterol values understand serum cholesterol values self-select identify risk factors for CHD
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Actual Use Issues for Pravachol Are consumers able to: self-treat hypercholesterolemia when to start treatment are they able to follow label directions for dosing and duration of use do they understand the treatment goal
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Review of Pravachol Actual Use Trials PREDICT, Protocol # 800-01-97 OPTIONS, Protocol # 800-03-97
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Actual Use Trials PREDICT The Pravachol Experience Documented In a Consumer Trial
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Study PREDICT Study design: multi-center randomized parallel open-label 6 months duration To test: behavior efficacy tolerability
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Study PREDICT Study design (cont.) recruitment done via advertising (newspapers, radio, pharmacies) the call center directed interested subjects to the enrollment site the call center also served as a screening site for premenopausal or childbearing potential women
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Study PREDICT Study design (cont.) Inclusion criteria: > 18 years
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Study PREDICT Study design (cont.) Exclusion criteria: less than 18 years old females of childbearing potential breast feeding females participation in a research study within the last 30 days
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Study PREDICT Criteria for treatment on the label: Total cholesterol 200-240 mg/dl LDL cholesterol > 130 mg/dl
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Study PREDICT Primary Objective: Proportion of OTC randomized subjects, who having purchased OTC Pravachol 10 mg, consult a physician within two months of using medication
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PREDICTResults
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119 subjects were ineligible to participate 61 (2%) women of childbearing age Of the 11,065 who called, unknown how many were women of childbearing potential
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Behavior of OTC Population (n=1,924)
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Treatment Guidelines Initiate Treatment/LDL-CGoal/LDL-C No CHD or diabetes & 2 risk factors >130 mg/dl, < 190 mg/dl< 130 mg/dl No CHD or diabetes, <1 risk factor >160 mg/dl, < 190 mg/dl< 160 mg/dl
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PREDICTResults Lipid Profile at Baseline in Qualified and Treated Population LDL-C: Mean 162 mg/dl + 17 Median 163 mg/dl TC: Mean 245 mg/dl + 21 Median 245 mg/dl
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Behavior of OTC Treated Population 290 (58%) withdrew from the study 123 were withdrawn from the study by a physician Discontinuation due to adverse events 8% OTC vs. 5% Rx 53 subjects were titrated to a higher dose
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PREDICTResults Compliance Assessed by pill count and self-report, and defined by 80-120%: 54% OTC vs. 65% RxCI -19%,-3.7% Mean duration of treatment: 109.4 days OTC vs. 152.5 days RX
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Are consumers able to self-diagnose hypercholesterolemia?
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Knowledge about Cholesterol values Randomized Population (n=3,872) Healthy level TC: < 20074% Unknown21% Healthy level LDL-C: < 13012% Unknown80% Knowledge of HDL-C was not tested
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Actual Use Trials OPTIONS OTC Pravachol Trial In an Observed Naturalistic Setting
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Study OPTIONS Study design: multi-center open-label pharmacy based 3 months duration To assess: behavior compliance safety
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Study OPTIONS Study design (cont.) Inclusion criteria: > 18 years member of a participating HMO for at least 6 months
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Study OPTIONS Study design (cont.) Exclusion criteria: pregnancy or lactation participation in a research study within the last 30 days less than 18 years old
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Study OPTIONS Study design (cont.) Recruitment was done via: mailing the study brochure to the HMO members walk through traffic in the participating pharmacies radio newspaper
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Study OPTIONS Population was not representative of overall U.S. OTC population: restricted to certain geographical areas all participants had health care insurance and prescription drug coverage
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Study OPTIONS Study design (cont.) Criteria for treatment on the label Total serum cholesterol 200-240 mg/dl > 35 years for men > 55 years for women
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Study OPTIONS Primary Objective To determine the proportion of subjects, who having purchased Pravachol 10 mg, contact their health care provider within 2 months of using the medication
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OPTIONSResults
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95 (24%) purchase population were not recommended Pravachol by their health care provider Median total-C level 235 mg/dl Median LDL-C level 151 mg/dl 59.8% women were <55 years old
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Proposed Label Total cholesterol 200-240 mg/dl “Bad” cholesterol (LDL) > 130 mg/dl Do not use if you are under 18 years if you have liver disease or drink >3 alcoholic beverages daily if you are allergic to pravastatin
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Latest Proposed Label Total cholesterol 200-240 mg/dl “Bad” cholesterol (LDL) > 130 mg/dl For men over 35 years of age For women over 45 years of age
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Overall Conclusions Low consumer understanding of specific serum cholesterol values Substantial number of self-selection errors High withdrawal rate Poor adherence
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Overall Conclusions Behavior of childbearing age women was not addressed in these 2 trials Consumer understanding was not assessed about: the goal (to lower cholesterol) the length of the therapy titration to a higher dose Targeted OTC population on the current proposed label has not been studied
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