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❻ ADR surveillance serves as a means to primarily provide early signals about possible problems, according to Gerald A. Faich, MD, MPH, Former Director, Office of Epidemiology and Biostatistics, Center for Drugs and Biologics, of the FDA. He goes on to explain that “neither industry nor the FDA should consider its scientific job complete when a new drug is approved.”59 Faich is referring to the importance of postmarketing surveillance, or the process of continually monitoring and reviewing suspected adverse reactions associated with medications once they reach the market and are available to the public (see Chapter 22 for more about postmarketing surveillance). In order to detect an ADR that occurs once in every 10,000 patients exposed to the drug, at least 30,000 people would need to be treated with the medication.12 Clinical trials that are required to approve a new drug may not enroll a sufficient number of patients, and often exclude special groups such as children, pregnant women, and the elderly. Due to the limited sample size and populations included in these trials, the FDA relies on postmarketing information to establish a better understanding of adverse events. In addition, the short duration of most clinical trials means that they will not detect ADRs with a delayed onset.60 Pharmaceutical companies are required by the FDA to submit quarterly reports of all ADRs for the first 3 years that a drug is on the market, followed by annual reports thereafter, as part of the postmarketing surveillance system. However, the success of postmarketing surveillance is directly dependent on the active involvement of health care practitioners.14 Postmarketing ADR reports from health care providers have led to changes in prescribing habits, changes to drug labeling, and the withdrawal of various drugs from the market.
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REPORTING ADRS TO THE FDA
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With the passage of the Kefauver–Harris Amendment of 1962, the FDA was required to maintain a Spontaneous Reporting System (SRS). The SRS allows for a relatively inexpensive monitoring system of ADRs for all drugs marketed in the United States, throughout their entire life cycle.53,61 All health care professionals and consumers can use this program to report ADRs and participate in the postmarketing surveillance process.
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In the past, however, the problem with the SRS has been the lack of voluntary reporting by the medical community. In 1988, for example, a survey demonstrated that only 57% of community-based physicians were aware of the voluntary system of reporting, which used FDA Form 1639 to allow anyone to report an adverse event through the SRS.62 In June 1993, the FDA switched to a new program called MedWatch: The FDA Medical Products Reporting Program. With MedWatch, the FDA receives reports via mailings, phone calls, faxes, and the Internet. From 2000 to 2010, the number of reports submitted annually through MedWatch to the FDA’s Adverse Event Reporting System (AERS) database grew from 266,866 to 758,890.63
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The current MedWatch system allows health care providers to report suspected ADRs using FDA Form 3500 (Appendix 15–4), which can be submitted by mail, fax, phone, or online.64 The MedWatch form asks for information related to the suspected ADR, the patient’s relevant medical history and medication regimen, and pertinent laboratory tests, although this information does not need to be complete in order for an ADR report to be submitted. From start to finish, the FDA estimates that it takes 36 minutes to complete a MedWatch form, including gathering the patient’s data, reviewing the instructions, and submitting the report.
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Once submitted through the MedWatch system, ADR reports are received by a unit of the FDA called the Central Triage Unit. The Central Triage Unit screens reports and forwards them to the appropriate FDA program within 24 hours of receipt. The report becomes part of a database used by the FDA to identify signals or warnings related to drug safety that require further study or regulatory action (see the section Future Approaches to Pharmacovigilance). As a reminder, MedWatch is interested in capturing reports of serious ADRs, which the FDA defines as death, life-threatening events, hospitalization, disability, congenital anomaly, or requiring intervention to prevent permanent impairment or damage, as well as unexpected ADRs. The MedWatch program asks individuals to report an event even if they are not certain that the drug product was the cause.65
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The MedWatch program does not overcome the traditional lack of reporting seen with voluntary systems. It is important to recall that pharmaceutical manufacturers are required to report all adverse events to the FDA, whereas individual health care practitioners do so only voluntarily. Various explanations can account for the failure of practitioners to participate in the FDA program. Hoffman elucidates several reasons that physicians do not voluntarily report ADRs, which are as follows:
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Failure to detect the reaction due to a low level of suspicion.
Fear of potential legal implications.
Lack of training about drug therapy.
Uncertainty about whether the drug causes the reaction.
Lack of clear responsibility for reporting.
Paperwork and time involved.
No financial incentive to report.
Unaware of reporting procedure or little understanding of it.
Lack of readily available reporting forms.
Desire to publish the report.
Fear that a useful drug will be removed from the market or given a bad name.
Complacency and lethargy.
Guilty feelings because of patient harm.
Reaction not worth reporting.65
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In a systematic review of available evidence, Lopez-Gonzalez and colleagues identified additional reasons why ADRs are underreported, including the beliefs that a single ADR report cannot meaningfully contribute to medical knowledge and only safe drugs are allowed on the market.66 Another potential explanation for the lack of reporting is that medical record personnel, whose job might be to categorize and report data, are not familiar with ADRs and/or their method of documentation.65
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Many of the reasons noted above also explain pharmacists’ barriers to ADR reporting. A recent survey of Texas pharmacists investigated attitudes about voluntary reporting of serious ADEs in both community and hospital settings. While nearly 90% of respondents felt reporting could improve patient safety, 72.6% noted that the reporting process was time consuming. Furthermore, 55.5% of respondents felt the reporting process disrupted their normal workflow. Some of the pharmacists in this survey also mentioned the reporting would increase the risk of malpractice, compromise relationships with physicians, and potentially break trust with their patients.67 Ultimately, the benefit of increased patient safety should be enough to overcome the barriers to reporting faced by health care practitioners.
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Historically, consumer reporting of adverse events has provided little data to MedWatch in comparison to the number of reports submitted by health care professionals. With the passage of the Food and Drug Administration Amendments Act (FDAAA) in 2007, however, consumer reports have been increasing. The FDAAA called for increased measures to ensure the safety of marketed drugs. In an effort to increase consumer reporting of adverse events to the FDA, the act requires direct-to-consumer advertisements of prescription drugs to include the following statement: “You are encouraged to report negative side effects of prescription drugs to the FDA. Visit http://www.fda.gov/medwatch, or call 1-800-FDA-1088.”68
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In fact, in 2006, before the FDAAA was passed, consumers reported only 127,475 adverse event reports to MedWatch. In 2010, consumers were responsible for reporting 403,746 adverse event reports, nearing the total provided by all health care providers that year.69 While this trend is encouraging, there is still room for an increased rate of reporting by consumers. Efforts to educate the public on its role in ADR reporting could significantly impact public health.76
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Although consumers have the option of submitting ADR reports directly to the MedWatch program, FDA Form 3500 may be difficult for patients to navigate and complete. For example, they may not have ready access to their medical records, laboratory test results, and so on. Fortunately, a simplified, consumer-focused Form 3500B is available for patients to report ADRs to the FDA. A reporting mechanism is available for these individuals through the FDA’s Consumer Complaint Coordinators. Available by telephone, these coordinators listen to consumer complaints, document the suspected problem, and follow up when needed. In the past, the FDA has recalled nonprescription products after just two or three reports of serious problems were received through the Consumer Complaint Coordinators.70
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DIETARY SUPPLEMENT ADR REPORTING
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Dietary supplements, including herbs, vitamins, minerals, and other so-called “nutraceuticals,” can and do cause ADRs. Many of these products have powerful pharmacological effects and, therefore, can cause ADRs. The medical literature contains many case reports that describe ADRs related to dietary supplements. However, the exact incidence of ADRs with dietary supplements is not known. In one survey of 2743 adults, 4% who took a dietary supplement reported an adverse event in the previous 12 months.71
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Dietary supplements are regulated much differently than pharmaceuticals. The most striking difference is that these supplements can reach pharmacies and grocery store shelves without FDA approval and without any proof of safety or effectiveness. Until recently, manufacturers of these products were not required to monitor safety of their products through postmarketing surveillance, nor were they required to share information about safety with the FDA. However, the Dietary Supplement and Nonprescription Drug Consumer Protection Act of 2006 changed this. This legislation now requires that any manufacturer, packager, or distributor of a dietary supplement whose name appears on a product label must collect and report ADR information related to their product(s). Manufacturers or marketers of dietary supplements who receive reports or information about severe adverse reactions related to their products are now required to share these reports with the FDA.72 Retailers who sell these products may report events upstream to the manufacturer, packer, or distributor.
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An interesting case related to dietary supplements and ADRs involves the herb ephedra, also known as ma huang. This herb was marketed as a dietary supplement and promoted primarily for weight loss and enhancing athletic performance. It received lots of negative media attention when a Minnesota football player died of heat exhaustion during a training session. It turned out that the football player was using ephedra for weight loss. Over a period of several years, there were well over 100 reports to the FDA of life-threatening ADRs linked to ephedra, including heart attacks, strokes, seizures, and death. In March 2004, the FDA banned the sale of dietary supplements containing ephedra,73 although this ban was lifted by a judge in 2010.74 Still, the FDA could not prove that ephedra was the cause of these numerous ADRs. Because there were no reporting standards or requirements for manufacturers to collect data on their products’ safety at this time, it would be unlikely that the FDA would ever have enough data to scientifically prove causality; they had to act based on the best available evidence. The FDA’s actions on ephedra will have long-lasting effects, and has ultimately set the precedent by which other cases against dietary supplements will be decided.
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Currently, ADRs related to dietary supplements can be submitted through the FDA MedWatch program using the same approach that is used for prescription drugs. There are also third-party systems for collecting adverse event data such as Natural Medicines Watch. Natural Medicines Watch allows consumers or health care professionals to complete an electronic form reporting an adverse event related to any dietary supplement. This system uses a database of around 90,000 commercially available dietary supplements that allows the user to select the specific commercial product used by the patient. Since many commercially available dietary supplements contain multiple ingredients, this system may improve the reliability of adverse reaction reporting for supplements. Natural Medicines Watch is integrated with the drug information resource Natural Medicines Comprehensive Database (http://www.naturaldatabase.com), which increases its accessibility for health care practitioners. Natural Medicines Watch asks similar questions to those on the FDA MedWatch Form 3500, and all reports submitted through this system are also simultaneously shared with the FDA’s MedWatch program.75
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Just as with conventional drugs, reporting ADRs related to dietary supplements is voluntary for health care professionals. Practitioners and consumers have many options for reporting dietary supplement ADRs. As described above, they may submit them directly to the FDA, through a third-party system such as Natural Medicines Watch, or to the manufacturer or product distributor. Each of these avenues ultimately results in the information being provided to the FDA for evaluation and analysis. Within the FDA, these reports are sent to the Center for Food Safety and Applied Nutrition (CFSAN), which maintains a special group charged with evaluating these adverse events. The CFSAN Adverse Event Reporting System (CAERS) allows for a more efficient evaluation of reports specifically related to dietary supplements.76
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Despite the availability of this reporting infrastructure, the number of adverse events submitted by health professionals is minimal. From 2007 to 2010, an average of only 440 voluntary reports related to dietary supplement ADRs were submitted to the FDA each year.77 During the same time frame, about 790 per year were reported through mandatory mechanisms, such as manufacturer or distributor reporting. Most of these reports originate from consumers rather than health professionals.76
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There may be a variety of reasons why few health professionals submit reports on dietary supplements to the FDA. Some of these may include:
Patients often do not tell their providers about supplements use, or about the adverse effects they experience.
Health professionals often do not ask about the use of dietary supplements.
Consumers do not believe health professionals are able to answer questions about dietary supplements.
Health professionals do not know where or how to submit reports of adverse reactions.
There is a lack of information available to assess dietary supplement adverse reactions.
Health care professionals may face a lack of time or support from management.
Practitioners may have a fear of litigation.
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ADRs related to dietary supplements can be assessed in much the same way as conventional drugs. However, there are some unique considerations. For example, when it comes to supplements, there is no such thing as generic equivalency. In other words, two supplement products made by different manufacturers cannot be considered equivalent. Different manufacturing practices and different extraction methods can dramatically change how a substance acts in the body, and this is especially true when it comes to herbal extracts. Because herbal extracts are made from plant material, variables such as extraction method, time of harvest, growing conditions, and so on can affect the chemical makeup of the extract. Therefore, two supplements containing Echinacea should not necessarily be considered equivalent. This may also mean that an ADR caused by one version of a supplement may not occur with another version.
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VACCINE ADR REPORTING
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While MedWatch accepts adverse event reports for all FDA-regulated drugs, biologics, and medical devices, as well as dietary supplements, a separate process has been established for the reporting of adverse reactions related to vaccinations. The VAERS is a postmarketing surveillance program supported by the FDA and the Centers for Disease Control and Prevention (CDC). It was established after the passage of the National Childhood Vaccine Injury Act in 1986. This act requires health care providers to report specific adverse events that follow vaccination. These events include those listed by the vaccine manufacturer as a contraindication to subsequent doses of the vaccine, as well as certain other reactions defined by the FDA and CDC. A list of these reportable reactions is available on the VAERS Web site (http://vaers.hhs.gov).78 Around 30,000 reports are submitted to VAERS annually. Of these, approximately 13% are considered serious.79 Similar to the MedWatch program, patients and practitioners can submit reports of adverse reactions to VAERS online, by fax, or by mail. Detailed instructions regarding this process are also available on the VAERS Web site.
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Case Study 15–2
A patient approaches you at the community pharmacy. She explains that she began taking a dietary supplement called ZygoControl Weight Loss about 6 weeks ago. Every time she takes the product, she feels like her heart is racing, she becomes lightheaded, and her mouth feels dry. These symptoms last about 3 hours and then go away. After interviewing the patient and evaluating the available information, you decide that ZygoControl Weight Loss is causing these side effects.
• As a health care professional, how can you report this suspected ADR to the FDA?
• Your patient decides she would like to take responsibility for reporting this ADR on her own. How can she accomplish this task?