COMMENTS FROM PRESCRIRE <CONTACT PERSON>

Similar documents
COMMITTEE FOR MEDICINAL PRODUCTS FOR HUMAN USE (CHMP)

Guideline on the acceptability of names for human medicinal products processed through the centralised procedure

COMMITTEE FOR MEDICINAL PRODUCTS FOR HUMAN USE (CHMP)

Procedural advice on publication of information on withdrawals of applications related to the marketing authorisation of human medicinal products

Safety and usability of packaging and labelling:

Frequently asked questions

EMEA WORKING PARTY ON HERBAL MEDICINAL PRODUCTS

EUROPEAN COMMISSION HEALTH AND FOOD SAFETY DIRECTORATE-GENERAL. PHARMACEUTICAL COMMITTEE 21 October 2015

(Legislative acts) REGULATIONS

COMMITTEE FOR MEDICINAL PRODUCTS FOR HUMAN USE CHMP GUIDELINE ON CLINICAL EVALUATION OF NEW VACCINES ANNEX: SPC REQUIREMENTS

C 178/2 Official Journal of the European Union

Guideline on influenza vaccines submission and procedural requirements

Other EU Activities Contributing to Harmonization of Labeling

EMEA PANDEMIC INFLUENZA CRISIS MANAGEMENT PLAN FOR THE EVALUATION AND MAINTENANCE OF PANDEMIC INFLUENZA VACCINES AND ANTIVIRALS

The European Medicines Agency (EMA)

Submission of comments on 'Policy 0070 on publication and access to clinical-trial data'

ORDER of the Minister of Health No. 269/2017 of 14 March 2017 on mandatory provision of medicinal product adequate and continuous supplies

Overview of the Procedure and interactions between CAT and CHMP

COMPETENT AUTHORITY (UK) MEDICAL DEVICES DIRECTIVES GUIDANCE NOTES FOR MANUFACTURERS OF DENTAL APPLIANCES

INTERNATIONAL STANDARD ON ASSURANCE ENGAGEMENTS 3000 ASSURANCE ENGAGEMENTS OTHER THAN AUDITS OR REVIEWS OF HISTORICAL FINANCIAL INFORMATION CONTENTS

2008 Public Status Report on the Implementation of the European Risk Management Strategy. Executive Summary

The European Medicines Agency (EMA)

Procedural advice on the submission of variations for annual update of human influenza inactivated vaccines applications in the centralised procedure

COMMITTEE FOR MEDICINAL PRODUCTS FOR HUMAN USE (CHMP) CORE SPC FOR HUMAN TETANUS IMMUNOGLOBULIN FOR INTRAMUSCULAR USE (CPMP/BPWG/3730/02)

Draft Agreed by Immunologicals Working Party January Adoption by CVMP for release for consultation 12 March 2009

Pharmaceutical Trade Marks

Lessons learned on the review of the labelling of pandemic vaccines

COMMITTEE FOR MEDICINAL PRODUCTS FOR VETERINARY USE (CVMP)

COMMITTEE FOR VETERINARY MEDICINAL PRODUCTS (CVMP) GUIDELINE ON DECLARATION OF STORAGE CONDITIONS:

Draft Agreed by Biologics Working Party December Draft Agreed by Blood Products Working party December 2010

a practical guide ISO 13485:2016 Medical devices Advice from ISO/TC 210

CHAPTER 3. September 2007

DIRECTIVE 2004/24/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. of 31 March 2004

A GUIDELINE ON CHANGING THE CLASSIFICATION FOR THE SUPPLY OF A MEDICINAL PRODUCT FOR HUMAN USE

COMMITTEE FOR PROPRIETARY MEDICINAL PRODUCTS (CPMP)

Working Document prepared by the Commission services - does not prejudice the Commission's final decision 3/2/2014 COMMISSION STAFF WORKING DOCUMENT

Reflection paper on the demonstration of a possible impact of maternally derived antibodies on vaccine efficacy in young animals

Suspected Defective Product Report

The Committee for Medicinal Products for Human Use

REGULATION concerning Marketing Authorisations for Natural Medicinal Products and Registration of Traditional Herbal Medicinal Products, No. 142/2011.

Comments received from public consultation on good pharmacovigilance practices (GVP)

Guideline on good pharmacovigilance practices (GVP)

COMMITTEE ON HERBAL MEDICINAL PRODUCTS (HMPC)

Laura Beatriz Herrero Montarelo, Maria Dolores Gómez Vázquez and Victorio José Teruel Muñoz

VOLUME 6A Procedures for marketing authorisation

COMMITTEE FOR MEDICINAL PRODUCTS FOR HUMAN USE (CHMP)

Reflection paper on assessment of cardiovascular safety profile of medicinal products

Ref: E 007. PGEU Response. Consultation on measures for improving the recognition of medical prescriptions issued in another Member State

SCIENTIFIC DISCUSSION

COMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

PROVISIONAL TRANSLATION

ANNEX I NAME, PHARMACEUTICAL FORM, STRENGTH OF THE MEDICINAL PRODUCT, ANIMAL SPECIES, ROUTES OF ADMINISTRATION, AND MARKETING AUTHORISATION HOLDER

COMMITTEE ON HERBAL MEDICINAL PRODUCTS (HMPC) FINAL COMMUNITY HERBAL MONOGRAPH ON AVENA SATIVA L., HERBA

(Acts whose publication is obligatory) REGULATION (EC) No 726/2004 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. of 31 March 2004

The Committee for Medicinal Products for Human Use

This is an unofficial English translation of the Royal Decree 1344/2007 revised by the Spanish Agency for Medicines and Medical Devices

PRAC recommendations on signals

Additional monitoring of medicines and direct patient reporting impact on the package leaflet

Dagmar Roth-Behrendt Vice-President of the European Parliament

Auditing Standards and Practices Council

1 March 2010 EMA/131300/2010 Human Medicines Development and Evaluation. 7 Westferry Circus Canary Wharf London E14 4HB United Kingdom

Overview of comments received on the draft 'Information in the package leaflet for aspartame' (EMA/CHMP/134648/2015)

EUROPEAN COMMISSION HEALTH AND CONSUMERS DIRECTORATE-GENERAL. Health systems and products Medicinal products authorisations, EMA

REGULATION (EC) No.141/2000

European Medicines Agency decision

October 2003 Revision 1, February INTRODUCTION AND SCOPE

Assurance Engagements Other than Audits or Review of Historical Financial Statements

Overview of comments received on the draft 'Information in the package leaflet for fructose and sorbitol' (EMA/CHMP/460886/2014)

The legally binding text is the original French version TRANSPARENCY COMMITTEE OPINION. 5 January 2011

PRAC recommendations on signals

Withdrawal of Proposed Rule on Supplemental Applications Proposing Labeling Changes for

8 December Mr. Ken Siong Technical Director International Ethics Standards Board for Accountants 529 Fifth Avenue New York NY 10017, USA

OFFICIAL STATE BULLETIN

KEY DIFFERENCES BETWEEN THE NEW MEDICAL DEVICE AND THE OTC REGULATIONS IN EUROPE

Secretary-General of the European Commission, signed by Mr Jordi AYET PUIGARNAU, Director

COMMITTEE ON HERBAL MEDICINAL PRODUCTS (HMPC) FINAL PROCEDURE FOR THE PREPARATION OF COMMUNITY MONOGRAPHS FOR TRADITIONAL HERBAL MEDICINAL PRODUCTS

MEDICINAL PRODUCTS ACT. UNOFFICIAL CONSOLIDATED TEXT (ZZdr-1-NPB1) I. GENERAL PROVISIONS. Article 1 (scope of regulation and competence)

Adopted by CVMP 10 March Date for coming into effect 1 July Revised draft guideline agreed by Immunologicals Working Party 22 June 2017

Review of Medicines Act 1968: informal consultation on issues relating to the PLR regime and homeopathy

COMMISSION OF THE EUROPEAN COMMUNITIES. Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Pharmacovigilance Working Party (PhVWP)

EUROPEAN MEDICINES AGENCY DECISION. of 11 August 2009

COMMITTEE ON HERBAL MEDICINAL PRODUCTS (HMPC) FINAL COMMUNITY HERBAL MONOGRAPH ON PASSIFLORA INCARNATA L., HERBA

BACKGROUND + GENERAL COMMENTS

COMMISSION DELEGATED REGULATION (EU).../... of XXX

Guideline on the processing of renewals in the centralised procedure

Concept paper on a Guideline for allergen products development in moderate to low-sized study populations

London, 24 January 2000 EMEA/1952/00

CHAPTER 3. Union Referral Procedures MAY 2014

ICH Topic S1C(R2) Dose Selection for Carcinogenicity Studies of Pharmaceuticals. Step 5

COMMITTEE ON HERBAL MEDICINAL PRODUCTS (HMPC) DRAFT COMMUNITY HERBAL MONOGRAPH ON EQUISETUM ARVENSE L., HERBA

The Paediatric Regulation a perspective from the European Medicines Agency

TITLE: SAFE USE OF MEDICINES IN ZANZIBAR A

COMMITTEE ON HERBAL MEDICINAL PRODUCTS (HMPC) FINAL COMMUNITY HERBAL MONOGRAPH ON SOLIDAGO VIRGAUREA L., HERBA

EUROPEAN MEDICINES AGENCY DECISION. of 15 July 2009

European Medicines Agency decision

on the advertising of medicinal products for human use

COMMITTEE FOR MEDICINAL PRODUCTS FOR HUMAN USE (CHMP) CORE SPC FOR HUMAN PROTHROMBIN COMPLEX PRODUCTS (CPMP/BPWG/3735/02)

SUBMISSION OF COMMENTS ON DRAFT COMMISSION PAEDIATRICS GUIDELINE

COMMITTEE FOR PROPRIETARY MEDICINAL PRODUCTS (CPMP) NOTE FOR GUIDANCE ON EVALUATION OF ANTICANCER MEDICINAL PRODUCTS IN MAN

Transcription:

European Medicines Agency SUBMISSION OF COMMENTS ON GUIDELINE ON THE ACCEPTABILITY OF NAMES FOR HUMAN MEDICINAL PRODUCTS PROCESSED THROUGH THE CENTRALISED PROCEDURE CPMP/328/98, Revision 5-5 February 2007 COMMENTS FROM PRESCRIRE <CONTACT PERSON> GENERAL COMMENTS Prescrire is an independent drug bulletin supporting a healthcare practitionners continuing education programme, owned by an independent organisation aimed to achieve healthcare improvement in the interests of patients first, formally called Association Mieux Prescrire. The magnitude of the use of trademark names of medicinal products in European healthcare is mainly the consequence of the marketing pressure from the pharmaceutical companies, as private owners of these trademarks. Everyday medication errors are related to trademark names of medicinal products in Europe. As a consequence, European citizens are threatened by adverse drug effects, sometimes serious, which is an inacceptable situation and a public healthcare concern. The risks related to trademark names of medicinal products are not acceptable because they are preventable for several reasons: the use of trademark names of medicinal products is not mandatory; the international nonproprietary names (INN) should be systematically used as usual names and made proheminent at all stages of the medication use system, on the package leaflets, and both on the inner and on the outer packages of medicine products (a concern not enough taken in account in the Draft Guideline on the readability of the label and package leaflet of medicinal products for human use ). As the responsible public body for delivering the marketing authorisation through the centralised procedure, the European Medicines Agency is fully accountable of the safety of the trademark names of medicinal products in Europe. Therefore, as a part of the evaluation of the safety of medicinal products in the authorisation procedure, the Guideline on the acceptability of names for human medicinal products must guarantee that the health status of European citizen will not be threatened by medication errors related to trademark names. Prescrire wellcomes several improvement to the previous guidelines (Release 4), particularly the broadening of assessing criteria adressing safety concerns in proposed trademark names ( 2.1.1), and encourages the European Medicines Agency to learn from independent medication error reporting programmes in a complementary way with pharmacovigilance ( 4.2.6.2). Prescrire also specially urges the European Medicines Agency: - to respect its obligations regarding transparency ( 5); - to withdraw the new provisions concerning the umbrella trademark names for non-prescription medicinal products ( 2.4.4) and introducing the bypass, even exceptionally, of the Name Review Group ( 4.2.5/4); and not to change the current Guideline (Release 4) regarding the abbreviations and the suffixes ( 2.3.1) and the names of fixed combination medicinal products ( 2.3.5). SPECIFIC COMMENTS ON TEXT 7 Westferry Circus, Canary Wharf, London, E14 4HB, UK Tel. (44-20) 74 18 84 00 Fax (44-20) 74 18 85 95 E-mail: mail@emea.eu.int http://www.emea.eu.int EMEA 2005 Reproduction and/or distribution of this document is authorised for non-commercial purposes only provided the EMEA is acknowledged

2.1 Asking for safety reviews of proposed trademark names by pharmaceutical companies. According to the project, the EMEA expects from pharmaceutical compagnies that they review the proposed invented name, applying the criteria outlined in this guideline, before requesting that an invented name(s) be considered and provide detailed information addressing the above ( ) within the invented name application form(s) or as part of a justification for retaining the invented name. However, there is a variety of assessment methods that may be applied to identify if there are look- or sound-alike trademark or nonproprietary medicines names already registered which could be confused with a proposed trademark name, to take in account as well the contributing factors as the potential risk of health damage either due to the inadvertent administration of the medicine or the lack of administration of the intended medicine to a patient. No indication for selecting assessment methods is provided by the Guideline, even if methods are not yet scientifically validated and it is unclear which assessment method or which combination of methods will be the most relevant to predicting risks of look-alike and sound-alike medicines names. To provide better background regarding assessment methods for predicting risks of look-alike and sound-alike trademark names. With a view to transparency, as a reference for auditing, and in order to help pharmaceutical companies, European healthcare practitionners and citizens, to anticipate the risk of confusing the names of medicinal products, the EMEA should: - ensure scientific validation and reproducibility of assessment methods for predicting the risks of confusion between trademark names of medicinal products, in order to further standardise them; - explicitly indicate the recommended assessment methods for this purpose, - return public those assessment methods which are employed by the Name Review Group. These assessment methods should comprise end-users tests by experts, healthcare practitionners and patients, in real world caring situations. 2.2. Addressing international nonproprietary names' concerns. Release 4 of the Guideline stated: The EMEA will be monitoring outcome of the above policy very closely and review it as appropriate on a yearly basis. The reasons of the abandonment of the principle of an annual review of the problems related to the similarities with DCI or their stems are not clarified.

2.3.1 Dangerous retreat on the abbreviations and the suffixes! The version in force of the Guideline disapproves the use of abbreviations and suffixes deprived of univocal significance, and regards them as unacceptable (See Release 4 2.3.1). Possible exceptions, such as the description of the route of administration (for example: IV, IM, SC), must currently be the subject of a precise motivation from the applicant. At the opposite, the project considers that the use of qualifiers/abbreviations by letters as part of the invented name should in principle be acceptable. Related to the duration of action, devices, patient population, such abbreviations and suffixes are officially intended to help the professionals of health and/or the patients to prescribe/select the drug. In fact they offer new forms of publicity to the pharmaceutical companies who urged for this change. The example list of the acceptable abbreviations and suffixes is not yet established by the Name Review Group. Therefore, it is difficult to appreciate up to which point the European Medicine Agency intends to satisfy the recurring requests of the firms. Because the abbreviations and the suffixes are likely to cause medication errors, this change of position proves very dangerous for European patients. To control more strictly the abbreviations and the suffixes as part of the trademark names of medicinal products. The EMEA should control more strictly the abbreviations and the suffixes as part of the trademark names of medicinal products because they are a frequent cause of medication errors. Have regard to the risks induced by this too important arrangement of the former Guideline, it is necessary to return to a more restrictive approach of the abbreviations and suffixes, to make the exception rather again than the rule, and to limit strictly their possible use. At least, not change should be introduced to the current Guideline (Release 4) because it is less dangerous.

2.3.5 Still more errors in prospect with the trademark names of fixed combination medicinal products! Because EMEA has been reported medication errors on these type of medicinal products, the trademark names of fixed combination medicinal products were asked in Release 4 to be completely different from the combination of the trademark name borne by the individual active substances of the fixed combination. Surprisingly, this concern has been removed from the Release 5 with the result that from now it will be enough that they are sufficiently different from these trademark names or those of other associations comprising them. In the absence of evaluation by end-users in situations of care, this arrangement is extremely likely to lead the firms to propose only commercial names strongly evoking those already memorized by the prescribers. Whereas fixed associations are not often of clinical interest, it would be detrimental for the patients whom they provoke the additional risks of medication errors. To control more strictly the trademark names of fixed combination medicinal products. The EMEA should control more strictly the trademark names of fixed combination medicinal products because they are a frequent cause of medication errors. At least, not change should be introduced to the current Guideline (Release 4), less permissive.

2.4.4 Surreptitious recognition of umbrella trademark names for nonprescription medicinal products Not only, the trademarks names directly advertising to general public have more facilities to derogate from the constraints regardind the use of abbreviations and suffixes (see also our comment 2.3.1) or the names of fixed combination medicinal products (see also our comment 2.3.5), but especially the addition of complementary terms in the trademark name is allowed, alleging that it should be considered as instructions of employment to be introduced in the commercial name. However, these instructions of employment constitute only one of the labelling mentions to be made on the outer packaging in this precise case,according to Article 54(n) of Directive 2004/27/EC. Nothing authorizes the applicant to incorporate them in the commercial name. Over this specious reason formally disguished as a misunderstanding of Article 54(n) of Directive 2004/27/EC, the European Medicines Agency provides an implicit official recognition to umbrella names for non-prescription medicinal products. Prescrire is strongly opposed to umbrella names which, under the same name, expose the patients to medicinal products of different compositions and do not allow them any more to identify clearly the substances that they use. To withdrawn rules overmeasure for umbrella trademark names and restrict their use for non-prescription medicinal products The European Medicine Agency should consider that an umbrella trademark name for a different combination of medicines with several active pharmaceutical ingredients may lead to confusion. Patients and professionals may not be aware of the difference, which may give rise to errors that can lead to unexpected consequences. Therefore, the European Medicine Agency is urged: - to withdraw these exemptions, not consistent with Directive 2004/27/EC, for non-prescription medicinal products from the standard evaluation of the trademark names of medicinal products, due to the medication errors which they would involve; - to launch an indeepth evaluation of the risks related to umbrella names of non-prescription medicinal products within the European Union, for better appreciating the opportunity for measures of restriction, even of prohibition, which the consumer protection should require.

4.2.5/4 Rejection by NRG/CHMP of a proposed invented name. And when the pharmaceutical companies do not have their proposed trademark names accepted by the Name Review Group, they will have the ability to ask to the CHMP to slice. This new provision, although presented like exceptional, withdraws any authority with the decisions of the Name Review Group. To reinforce authority of the Name Review Group Paragraph 4.2.5/4 must be withdrawn because it distort the whole name review procedure integrity. 4.2.6.2 Report of medication errors due to the trademark names of medicinal products. The pharmacovigilance system and Periodic Safety Update Reports (PSUR), are the current sources of the European Medicine Agency on medication errors due to the trademark names of medicinal products. However, as specified in the guide of recommendations, medication errors due to the trademark names do not necessarily result in adverse effects (ADR), therefore not permit reporting into the pharmacovigilance system. Since the current project introduces particular rules regarding the trademark names of non-prescription medicinal products directly advertised to general public (see 2.4.4), the patients should be authorized to report medication errors due to the trademark names directly to the European Medicine Agency. In order to promote Europe-wide standards for safe medication practices, the Council of Europe recommends to share and disseminate data and strategies for prevention and risk reduction * and to ensure that all medication error reports related to its relevant missions, such as naming, labelling, packaging, advertising of medicinal products, are shared with the European Medicine Agency by European medication error reporting system**. To facilitate reporting of medication errors due to the trademark names of medicinal products. Healthcare practitionners and patients should be encouraged to report medication errors due to the trademark names of medicinal products, even whithout occurrence of an adverse effect. Procedures and specific reporting forms should be established by the European Medicine Agencies in order to provide a better insight on this type of medication error. In this field, the particular knowledge from volontary and independent medication error reporting programmes deserves to be taken into account by the European Medicine Agency, as recommended by the Council of Europe. The learning resulting from thorough analysis of the medication errors reported to these safe medication practices centres, and their proposals for prevention, should receive a particularly interest from the Name Review Group. * Council of Europe Recommendation Rec(2006)7 of the Committee of Ministers to member states on management of patient safety and prevention of adverse events in health care adopted 24 May 2006. ** Council of Europe Expert Group on Safe Medication Practices Creation of a better medication safety culture in Europe: Building up safe medication practices Preliminarily version available as from 19 March 2007: 257 pages.

5 Transparency is too weakly adressed, in contradiction with Article 126(c) of Directive 2004/27/EC. Except statistical information on the outcome of the NRG review on proposed names, the minutes of the meetings of the CHMP are dumb on the trademark names of medicines prone to confusion. However, if one can understand that the names suggested by the companies are not revealed for reasons of protection of the patent rights, it does not have no reason there to hold secret the known medication errors due to confusions between trademark names of medicines. Not only it is about the strict application of the rules of transparency endicted by Article 126(c) of Directive 2004/27/EC (7), but any retention of information regarding a known risk of confusion between trademark names of medicines is harmful with the health of the European citizens. It means deliberately exposing them at these known risks while preventing their looking after from self protection. The current attitude is shocking, because contrary with the public healthcare mission of safety alarm entrusted to the European Medicine Agency. To make public the known risks of confusion between trademark names of medicinal products. As a postmarketing surveillance regular working process, the basic precautions as regards the public health protection and the respect of Article 126(c) of Directive 2004/27/EC posted transparency, require: - to mention the medication errors due to confusion between trademark names of medicines reported to the EMEA in the minutes of the meetings of the CHMP; - to permanently hold up to date a list of the pairs of trademark names having been the subject of medication errors in the all European Union countries; - to make this list accessible on the EMEA web site; - and to broadcast safety alarms when adverse effects result from medication errors due to confusion between trademark names. Please feel free to add more rows if needed. These comments and the identity of the sender will be published on the EMEA website unless a specific justified objection was received by EMEA.