Set of
Questions
for the Adverse Event PAC and Tamiflu Q & As
General Meeting Questions:
1. Why are certain drugs having their safety reports presented to the Pediatric Advisory Committee on November 18, 2005?
The eight products being reviewed are presently due for a public
discussion of their adverse events as required by Section 17 of the Best
Pharmaceuticals for Children Act (BPCA).
BPCA mandates the review of the adverse event reports received during
the one-year after a drug has been granted pediatric exclusivity. The FDA’s Office of Pediatric Therapeutics
(OPT) is authorized to carry out this mandate and is directed by law to refer
such adverse event reports to the Pediatric Advisory Committee (PAC) for their
review and recommendations regarding any regulatory actions.
2. What are the drugs being presented on November 18, 2005?
The following drugs, which received their
marketing exclusivity at least one year prior to this meeting, will be
discussed:
Anagrelide (Agrylin)
Carboplatin (Paraplatin)
Fluconazole (Diflucan)
Irinotecan (Camptosar)
Oseltamivir (Tamiflu).
Rofecoxib (Vioxx)
Sodium ferric gluconate complex (Ferrlecit)
Sumatriptan (Imitrex)
3. Why is there an in-depth presentation on Tamiflu
(oseltamivir)? What will the presentation include?
The PAC will hear several presentations
on oseltamivir (Tamiflu) including adverse event reports, a literature review,
and analysis of the clinical trials data. In addition, the sponsor will present
data from the clinical trials and safety assessments. A CDC presentation will also provide
background information on the United States Surveillance Data on Influenza and
their new pediatric influenza surveillance efforts. The review of the adverse event reports for Tamiflu will discuss
pediatric deaths, serious skin reactions, and neuropsychiatric events. These events were reported almost entirely
in children from Japan.
Specific Questions on Tamiflu:
4. What is Tamiflu and what is it approved for?
Tamiflu (oseltamivir phosphate) is an antiviral drug approved for
treatment of uncomplicated influenza A and B in patients 1 year of age or
older. It is also approved for
prophylaxis (prevention) of influenza in people 13 years or older after
household contact or at high risk for exposure during influenza season. Tamiflu is one of a group of anti-influenza
drugs called neuraminidase inhibitors that act by blocking the viral enzyme
neuraminidase which helps the influenza virus invade cells in the respiratory
tract.
5. Does this discussion have anything to do with the pandemic preparations?
The Pediatric Advisory Committee discussion is not directly addressing
any issues related to pandemic flu preparations. Indirectly, a better understanding of Tamiflu safety in children
will be useful should a pandemic occur and there is widespread use of Tamiflu.
6. Is Tamiflu approved for use in pediatric patients?
Tamiflu is available in both capsule and liquid formulations. It is approved for treatment of influenza in
children over 1 year of age. In the
U.S., Tamiflu is dosed according to body weight in younger children. Older children (over 40 kg or 88 lbs) and
adolescents receive the same dose as adults.
It is also approved for prophylaxis (prevention) of influenza in
children over 13 years of age.
7. What is useful about Tamiflu in pediatric patients? Who should use it?
When used as directed (twice daily for 5 days) Tamiflu can reduce the
duration of influenza symptoms in otherwise healthy children by 1 to 1 ½
days. It also appears to reduce the
severity of common flu symptoms.
Consequently, it may allow children to return to school or other normal
activities sooner. Tamiflu was also
shown to be similarly effective in children who had a history of asthma and did
not worsen the asthma symptoms.
Tamiflu is most effective when taken within 48 hours after the
beginning of flu symptoms and not likely to be effective if patients have
already had flu symptoms for several days.
Patients (and their parents) should be aware that some patients with
influenza may be at risk for secondary bacterial infections and should seek
medical care if they are not improving within a few days of beginning Tamiflu.
Tamiflu has not been studied in children with very severe or
complicated influenza who require hospitalization and it is not known whether
it will provide the same benefit to children with severe illness.
8. What are the important safety issues and adverse events?
When Tamiflu was studied in clinical trials as treatment for children
with influenza, children taking Tamiflu experienced similar side effects as
children not taking Tamiflu. Serious side effects were not identified. The most
common side effects observed in both the treatment and prophylaxis trials were
nausea and vomiting. In these trials, a
small number of children stopped taking their Tamiflu because of nausea and
vomiting or other adverse reactions.
In the safety review mandated by the BPCA, a number of adverse event
reports were identified associated with the use of Tamiflu in children 16 years
of age or younger. These adverse event
reports were primarily related to unusual neurologic or psychiatric events such
as delirium, hallucinations, confusion, abnormal behavior, convulsions, and
encephalitis. These events were
reported almost entirely in children from Japan who received Tamiflu according
to Japanese treatment guidelines (very similar but not identical to U.S.
treatment guidelines).
The review identified a total of 12 deaths in pediatric patients since
Tamiflu’s approval. All of the
pediatric deaths were reported in Japanese children. In many of these cases, a relationship to Tamiflu was difficult
to assess because of the use of other medications, presence of other medical
conditions, and/or lack of adequate detail in the reports.
The review also identified severe skin reactions (like allergic
reactions) in some pediatric patients.
These events were not all reported in Japanese children and have also
been reported in adults. Severe skin
reactions in all age groups are currently being reviewed in more detail.
9. Why are many of the adverse events being reported from Japan?
Initially, it was not clear why the neuropsychiatric adverse events and
deaths were reported almost entirely in Japanese children. The FDA receives adverse event reports from
all over the world and usually adverse events are roughly the same from
different reporting countries. The reports
of death and neuropsychiatric events associated with Tamiflu, almost entirely
from Japan, was unusual enough to prompt further evaluation.
The FDA requested additional information from both Hoffman-La Roche,
the pharmaceutical company which produces Tamiflu, and the Japanese Ministry of
Health, Labor, and Welfare. FDA then evaluated several possible explanations
for the neuropsychiatric adverse events.
Was it possible that Japanese patients metabolize Tamiflu differently
than American or European patients or have higher levels of the drug in their
bodies? There is no scientific evidence
that this is true and Japanese dosing recommendations are very similar to U.S.
and European recommendations.
Was it possible that these events were an unusual manifestation of
influenza infection? There is good
evidence that neuropsychiatric events can occur with influenza, in the absence
of Tamiflu or other treatment.
Beginning in the mid-1990s, there have been many reports in the
pediatric scientific literature describing a syndrome of influenza-associated
encephalitis (inflammation of the brain) or encephalopathy. These reports originated primarily from Japan
where pediatricians described a pattern of rapid onset of fever, accompanied by
convulsions and altered level of consciousness, progressing to coma within a
few days of the onset of flu symptoms.
This syndrome frequently resulted in death or significant neurologic
sequelae. These reports prompted
nationwide surveillance of influenza-associated encephalopathy in Japan. This syndrome was described and the
surveillance in Japan was in progress before Tamiflu was approved for the
treatment of influenza.
Was it possible that the large number of adverse events from Japan was
because the Japanese use more Tamiflu? Is it possible that we may see more U.S.
cases as use of Tamiflu increases in this country? Partly because of the
awareness in Japan of influenza-associated encephalopathy, the Japanese health
service will pay for rapid diagnostic testing for influenza in children and
subsequent treatment. Japan currently
uses the majority of the world’s supply of Tamiflu distributed for seasonal
influenza. It is possible that some of
these events might be observed in the U.S. population if the use of Tamiflu
increases substantially.
Finally, was it possible that the neuropsychiatric events reported from
Japan reflect different methods and requirements for adverse event
reporting? Both the Japanese Ministry
of Health, Labor and Welfare and Roche confirmed that Japanese regulators
require an intensive period of active adverse event reporting for 6 months
after a product is approved. When
Tamiflu was approved for prophylaxis of influenza in Japan, Roche and its
Japanese pharmaceutical affiliate actively solicited adverse event reports from
70,000 institutions and physicians in Japan.
These adverse event reports included the 2003-04 flu season and were
subsequently reported to the FDA and are included in the BPCA safety
review.
It is particularly difficult to assess the relationship of Tamiflu to
the reported pediatric deaths. It is
known that young children (less than 2 years of age) are hospitalized more often
for influenza-associated illness than older children and young adults. Infants and the elderly are known to have
higher influenza-associated death rates than other age groups. However, in the U.S., influenza deaths in
children were not among the events requiring reporting to public health
departments and the CDC until the 2004-05 flu season.
Review of the available information on the safety of Tamiflu in
pediatric patients suggests that the increased reports of neuropsychiatric
events in Japanese children are most likely related to an increased awareness
of influenza-associated encephalopathy, increased access to Tamiflu in that
population, and a coincident period of intensive monitoring adverse
events. Based on the information
available to us, we can not conclude that there is a causal relationship
between Tamiflu and the reported pediatric deaths.
10. What are FDAs next steps?
The evaluation of the pediatric adverse events will be discussed in
more detail at the Pediatric Advisory Committee on November 18, 2005; FDA looks
forward to comments from the Advisory Committee members. FDA anticipates it will continue to monitor
the adverse event profile, including neuropsychiatric adverse events, in all
ages including pediatric patients, and will report back to the Pediatric
Advisory Committee within 2 years. Through
these activities we expect to further refine our understanding of the adverse
event profile of Tamilfu. As we did
last flu season, we will continue to collaborate with the Centers for Disease Control
and Prevention to share information regarding influenza surveillance in the
U.S. population and the use of antivirals, including Tamiflu, for treatment.
11. What should I do about this information?
If you or your child is receiving Tamflu for the treatment of influenza
and you are concerned that you may be experiencing a drug-related adverse
event, you should contact your physician for advice and management. Adverse events should be reported to the FDA
through the on-line MedWatch system or by phone.
Keep in mind that the most effective way to prevent influenza and its
complications is by getting the annual influenza vaccine. Children younger than or equal to 8 years of
age receiving their first influenza vaccine should receive the vaccine split into
2 doses given one month apart. Children
from 6 months to 2 years of age and those with certain underlying medical
conditions are considered at high risk for developing complications of
influenza and are strongly encouraged to get the vaccine.