|
Introduction to Cefquinome (CEQ) and Overview of Microbial Safety Assessment
Veterinary Medicine Advisory Committee
Public Hearing, 25 September 2006
Carl K. Johnson, D.V.M.
Director, Product Development and Regulatory Affairs
Intervet Inc.
|
 |
|
Slide 2
Agenda
- An introduction to cefquinome, a 4th generation cephalosporin for use in
veterinary medicine
- Overview of the Microbial Safety Assessment of cefquinome (CEQ), following
FDA/CVM Guidance for Industry #152
- Experience with 4th generation cephalosporin use in human and veterinary
medicine in Europe since 1993 (Prof. André Bryskier)
|
 |
|
Slide 3
Cephalosporins Used in Veterinary Medicine
Cefapirin, 1st Generation
Ceftiofur, 3rd Generation
Cefquinome, 4th Generation
|
 |
|
Slide 4
Cefquinome
- Molecular structure of 4GC: zwitter-ionic
- beta-lactam nucleus
- quaternary ammonium
- aminothiazolyl moeity
- zwitter-ionic
|
 |
|
Slide 5
Description of Cefquinome (CEQ)
- Innovative ß-lactam antimicrobial (4th generation cephalosporin, 4GC):
- Characterized by zwitter-ionic molecular structure
- faster penetration of outer cell membrane (gram-negatives)
- lower affinity to ß-lactamases
- higher affinity to target penicillin binding proteins
? Enhanced antimicrobial activity
|
 |
|
Slide 6
Description of Cefquinome (CEQ)
- Exclusively for veterinary medicine:
- Europe (EU): since 1994 for prescription only use in cattle, followed
by swine (1999), and horses (2005)
- US: pending applications for treatment of bovine respiratory disease
with two injectable formulations (by prescription only)
- Not for use in feed and water
|
 |
|
Slide 7
Mode of Action (4GC)
Binding of CEQ to PBP disrupts synthesis of peptidoglycan layer
Integrity of cell wall is compromised
Net result: cell death (bactericidal)
|
 |
|
Slide 8
Overview of Microbial Safety Assessment for Cefquinome
(Guidance for Industry #152)
| |
HAZARD CHARACTERIZATION |
Description of hazard and conditions that influence its occurrence |
| RELEASE |
Probability of emergence of resistance
- resulting from use of the drug in animals
|
| EXPOSURE |
Probability of human exposure to bacteria of concern
- via food-borne transmission
|
| CONSEQUENCE |
Potential that human exposure to resistant bacteria results in adverse health consequence
- estimated by medical importance of the drug class
|
| RISK ESTIMATE |
Integration of the above assessments to estimate the relative potential of an adverse human health impact
- resulting from the proposed veterinary use
|
|
 |
|
Slide 9
Food-borne Pathogens of Concern
- GI #152: “…antimicrobial-resistant bacteria attributable to an animal-derived food
commodity and treated with the human antimicrobial drug of interest”
- Non-typhoidal Salmonella spp. are the relevant food-borne pathogens of interest
- NARMS survey data
- Enteric salmonellae are susceptible to CEQ
- E. coli is also considered in the release assessment
- E. coli is usually not associated with food-borne infections, except E. coli
O157:H7 (for which there is zero tolerance in food)
- Other food-borne pathogens - Campylobacter spp., and Enterococcus spp. - are
not considered
- CEQ is not active against these pathogens
|
 |
|
Slide 10
Hazard Characterization
Risk Assessment Hypotheses
- The use of CEQ may cause resistance in Salmonella spp. (E. coli) present in the
intestinal tract of the target animal, and
- Resistant Salmonella spp. may contaminate the carcass at slaughter and may
transfer to humans via food, and
- Resistant Salmonella spp. may cause infections in humans, and when treated
with a 4 GC, effectiveness may be compromised
|
 |
|
Slide 11
Outcome of CEQ Microbial Risk Assessment
Using Guidance for Industry #152 (“Evaluating the Safety of Antimicrobial New
Animal Drugs with Regard to Their Microbiological Effects on Bacteria of Human
Health Concern”), it is shown that :
- The overall risk estimate is MEDIUM for the proposed veterinary therapeutic use
of CEQ in cattle
- The proposed risk management measures minimize this risk and are consistent
with antimicrobial prudent use guidelines
- There is reasonable certainty of no harm to public health with regard to the
proposed use
|
 |
|
Slide 12
RELEASE: Emergence of
CEQ resistance in Salmonella and E. coli |
Probability is MEDIUM as determined by: |
- Conditions of use are limited (therapeutic, parenteral, individual animal use only,
for short duration)
- 4GCs are active against bacteria carrying the AmpC-type ß-lactamase resistance
mechanism
- 4GC resistance is very rare (must have either non-transferable Outer Membrane
Protein mutation plus enhanced ß-lactamase activity or Extended Spectrum
ß-Lactamases [ESBLs] that confer resistance to 4GCs); furthermore, ESBLs
have not been identified in isolates from US livestock
- Susceptibility surveillance data for 4GCs for both human and veterinary 4GCs
indicates no change in resistance patterns of relevant food-borne
pathogens (ongoing surveillance in the US and EU since late 1990’s:
sustained high level of susceptibility)
|
 |
|
Slide 13
RELEASE: Emergence of
CEQ resistance
in Salmonella
and E. coli |
1. Conditions of use of the two injectable formulations: |
- Individual parenteral therapy of bovine respiratory disease data on CEQ-related residues demonstrate that
- only very small amounts present in the intestinal tract of treated cattle, and
- gastro-intestinal inactivation of CEQ
- Short duration of treatment (daily injection for <1 week; single injection)
- Use controlled by prescription only status
Only limited exposure of enteric pathogens to CEQ possible
|
 |
|
Slide 14
RELEASE:
Emergence of CEQ resistance
in Salmonella
and E. coli |
2. 4GC activity against existing ß-lactam resistance mechanisms |
- The plasmid-encoded AmpC-like ß-lactamase CMY-2 is the most important ß-lactamase in Salmonella spp. and E. coli isolated from food-producing animals
- CMY-2 confers resistance to most ß-lactams (including 3GCs), but not for carbapenems and 4GCs
- CEQ does not induce Amp C-type ß-lactamases in Salmonella spp., or E. coli
- Extended Spectrum ß-Lactamases (ESBLs) have not been found in
Salmonella spp. and E. coli isolated from US livestock
4GCs (incl. CEQ) do not select for most common ß-lactam resistance
mechanisms
|
 |
|
Slide 15
RELEASE: Emergence of
CEQ resistance
in Salmonella
and E. coli |
3. Resistance mechanism relevant for 4GCs |
- High level 4GC resistance requires:
- A combination of both
- changes in outer membrane protein (non-transferable chromosomal
mutation) which decreases permeability and/or increases efflux, and
- simultaneous enhanced ß-lactamase activity
- Specific ESBLs that confer resistance to 4GC
Low risk of emergence of resistance to 4GCs (as confirmed by susceptibility
surveillance data)
|
 |
|
Slide 16
RELEASE: Emergence
of CEQ resistance
in Salmonella
and E. coli |
4. Surveillance data (animal isolates) |
- Sustained high level of susceptibility to CEQ post- approval (EU):
- in Salmonella and E. coli (EASSA survey, 1999-01)
- Sustained high susceptibility to CEQ pre-approval (US):
- in bovine Salmonella (NARMS slaughter isolates, since 2000)
- in bovine E. coli (Intervet feedlot survey, 2002)
No change observed in high level of susceptibility to CEQ
|
 |
|
Slide 17
RELEASE:Emergence of
CEQ resistance
in Salmonella
and E. coli |
Susceptibility surveillance data (animal isolates)
|
Sustained high susceptibility to CEQ pre-approval
(US) in bovine Salmonella (NARMS
slaughter isolates, 2000-2003)
| Year |
2000 |
2001 |
2002 |
2003 |
| Number of isolates |
1,720 |
897 |
702 |
671 |
| MIC50 (µg/ml) |
0.06 |
0.06 |
0.12 |
0.06 |
| MIC90 (µg/ml) |
0.25 |
0.5 |
1.0 |
0.5 |
|
 |
|
Slide 18
RELEASE: Emergence of
CEQ resistance
in Salmonella
and E. coli |
Susceptibility surveillance data (human isolates) |
- Susceptibility to the 4GC cefepime:
- nearly 100% in US isolates of Salmonella spp. and E. coli (SENTRY,
1997-1999).
- consistently above 98% from 1997 to 2003 in E. coli and Salmonella spp.
obtained from US hospitals (TSN, Focus Bio-Inova)
Sustained high level of susceptibility to 4GC
|
 |
|
Slide 19
RELEASE: Emergence
of CEQ resistance
in Salmonella
and E. coli |
Release Assessment Summary |
- Exposure of Salmonella spp. and E. coli to CEQ is limited
- CEQ does not select for the most prevalent beta-lactam resistance mechanisms
(Amp C); ESBLs have not been found in food producing animals
- Selective pressure leading to resistance emergence to 4GCs (incl. CEQ)
is minimal
- No change observed in high level of susceptibility to 4GCs (incl. CEQ)
The probability of the emergence of CEQ-resistant Salmonella (and E. coli)
in cattle is MEDIUM
|
 |
|
Slide 20
RELEASE: Emergence of CEQ resistantSalmonella,
E. coli MEDIUM
|
Probability of human exposure to Salmonella spp. via food-borne transmission |
EXPOSURE: Human
exposure
to Salmonella spp. |
- Contamination of beef (USDA/FSIS) and milk (pasteurization)
with Salmonella spp. is low:
| Commodity |
% prevalence Salmonella |
Qualitative ranking |
| Cows / bulls |
2.4 Low
|
(<5%)
|
| Steers / heifers |
0.6 Low
|
(<5%)
|
| Ground beef |
2.8 Low
|
(<5%)
|
- However, US per capita beef consumption is high
|
 |
|
Slide 21
RELEASE: Emergence of
CEQ-resistant
Salmonella
MEDIUM |
Exposure Assessment Summary |
EXPOSURE:
Human exposure to Salmonella
MEDIUM |
Probability of human exposure to Salmonella spp. from applicable food animal source |
| |
Amount of food commodity being consumed |
| Commodity contamination |
High |
Medium |
Low |
| High (> 25%) |
H |
H |
M |
| Medium (5-25%) |
H |
M |
L |
| Low (< 5 %) |
M |
L |
L |
| Default values provided in FDA/CVM GI #152 for beef result in MEDIUM human exposure |
|
 |
|
Slide 22
RELEASE: Emergence of
CEQ-resistant
Salmonella
MEDIUM |
Consequence Assessment Summary
|
EXPOSURE:
Human exposure to Salmonella
MEDIUM |
CONSEQUENCE:
Human health
consequences
of R-salmonella
infection |
Qualitative estimate of human medical importance of drug class |
- Potential human health consequences are assessed according to the relative
importance of 4GCs in human medicine (Appendix A, GI #152)
- Only 4GC approved in US for human use is Maxipime® (cefepime HCl)
- Cefepime’s primary use in human medicine
- sole agent approved for empiric monotherapy for neutropenic fever
- used to treat enteric pathogens of non-food-borne disease
|
 |
|
Slide 23
Rationale for ranking 4GCs as HIGHLY IMPORTANT (from
Appendix A, GI #152)
| Criteria |
4GCs
|
| Antimicrobial used to treat enteric pathogens that cause food-borne disease |
-
|
| Sole therapy or one of few alternatives to treat serious human disease or drug is essential component among many antimicrobials in treatment of human disease |
+
(only for neutropenic fever associated with nosocomial infection)
|
| Antimicrobials used to treat enteric pathogens in non-food-borne disease |
+
|
| No cross resistance within drug class and no linked cross-resistance with other drug classes |
-
|
| Limited risk in transmission of resistance elements within/across genera and species of organisms |
-
|
4GCs are classified as HIGHLY IMPORTANT
|
 |
|
Slide 24
RELEASE: Emergence of
CEQ-resistant
Salmonella
MEDIUM |
|
|
EXPOSURE:
Human exposure to Salmonella
MEDIUM |
Ranking may be conservative when noting the range of alternatives to 4GCs for treating infections associated with Salmonella spp. and E. coli as indicated by the Sanford Guide (2003) |
CONSEQUENCE:
Human health
consequences
of R-salmonella
infection
HIGH |
Salmonella spp.
|
E. coli
|
| Fluoroquinolones |
Beta-lactams combined with beta-lactamase inhibitors |
| |
Ceftriaxone |
Fluoroquinolones |
| |
Chloramphenicol |
Trimethoprim/sulfonamide combination |
| |
Trimethoprim / sulfonamide |
Nitrofurantoin |
| |
Azithromycin |
Carbapenems |
|
 |
|
Slide 25
RELEASE: Emergence of
CEQ-resistant
Salmonella
MEDIUM |
Overall Risk Estimation
|
EXPOSURE:
Human exposure to Salmonella
MEDIUM |
- Consistent with GI #152 the overall risk estimate is MEDIUM (Category 2)
- This estimate is conservative:
- Design of GI #152 is conservative
|
CONSEQUENCE:
Human health
consequences
of R-salmonella
infection
HIGH |
- Release Assessment ranking of MEDIUM is related to resistance mechanism that is not prevalent
|
Overall Risk Estimate
MEDIUM
(Category 2)
|
- While 4GCs are important for human medicine, there is a range of treatment alternatives to 4GCs
|
|
 |
|
Slide 26
RISK
Management
Considerations
|
Approval conditions
|
Category 1 (High)
|
Category 2 (Medium)
|
Category 3 (Low)
|
|
Marketing statusa
|
Rx
|
Rx/VFD
|
Rx/VFD/OTC
|
|
Extra-label use (ELU)
|
ELU Restrictions
|
Restricted in some casesb
|
ELU permitted
|
|
Extent of use
|
Low
|
Low, medium
|
Low, medium, high
|
|
Post-approval monitoring (e.g. NARMS)
|
Yes
|
Yes
|
In certain cases
|
|
VMAC review considered
|
Yes
|
In certain casesb
|
No
|
| a Prescription (Rx), Veterinary Feed Directive (VFD), over-the-counter (OTC) |
| b These risk management steps may be appropriate for certain Category 2 drugs that were ranked critically important for consequence assessment and ranked “high” for release or exposure assessment. |
|
 |
|
Slide 27
RISK
Management
Considerations |
Conditions of use for the two injectable formulations of CEQ
limit the risk of the emergence of resistance
|
- Both parenterally administered products will be used in individual animals for
short duration, by prescription only
- The extent of use is ranked LOW in accordance with FDA/CVM GI #152
- CEQ will continue to be tested against isolates from the NARMS susceptibility
surveillance program
- The microbial safety of CEQ has been reviewed by FDA/CVM and by VMAC
- Consistent with GI #152 no extra-label use limitations are deemed appropriate
|
 |
|
Slide 28
Conclusions
- The overall microbial food safety risk estimate is MEDIUM
- The conditions of use and proposed risk management measures are
appropriate to minimize this risk and are consistent with prudent use guidelines
- There is reasonable certainty of no harm to public health with regard to
microbial food safety for the proposed veterinary therapeutic use of CEQ
|
 |