Risk Management Planning
Industry Experience in Implementation
Val Simmons, MD FFPM
EU QPPV Executive, Eli Lilly
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Risk Management A Sense of Dj Vu?
I am convinced that .. the risk
management issue will increase,
not decrease, in importance.
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Risk Management A Sense of Dj Vu?
I am convinced that .. the risk
management issue will increase,
not decrease, in importance.
W.P. Von Wartburg
1990 (RAD AR)
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Date Regulatory Activity Safety Issue
1998 Seldane (terfenadine)
Posicor (mibefradil)
Duract (bromphenac)
Fen-phen
1999 FDA Task Force on Risk Management report to the FDA Hismanal (astemizole)
Commissioner :Managing the Risks from Medical Raxar (grepafloxacin
Product Use
2000 Prepulsid (cisapride)
Rezulin (troglitazone)
Lotronex (alosetron)
2001 EPPV introduced (Japan) Lipobay (cerivastatin)
Eudravigilance database implemented by EMEA (Baycol)
2002 FDA PDUFA III and Risk Management requirements
ICH V3 (Pharmacovigilance Planning) topic accepted
2003 FDA - Draft Risk Management guidances
- Proposed Rule (TOME)
Heads of Agencies European RM strategy paper
2004 ICH E2E Step 4 Vioxx (rofecoxib)
2005 FDA RM guidances finalized Tysabri (natalizumab)
ICH E2E Adoption by CHMP and incorporation into Bextra (valdecoxib)
Volume 9
New Medicines Legislation implementation in Europe
European RM Strategy & finalization of RM guidelines
2007
FDAAA passed; REMS requirement Avandia (rosiglitazone) 6
Risk Management A Shift in Emphasis
Old Model
Pre-marketing Safety ISS Approval See what happens in
Analysis real world use
Pre-clinical toxicology Integrated safety analysis Regulatory approval for Ongoing surveillance
Clinical trial safety data SADRs labelled use and signal
Laboratory data AEs
Risks included in label assessment of
(disclosure) serious/ unexpected
ECGs/other data Laboratory/other data ADRs
Targeted safety studies Post-marketing
safety studies
Update label
Ad hoc HCP
communications
(Dear Dr. letters)
Product restrictions/
withdrawal
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Risk Management A Shift in Emphasis
New Model
Modify in the light of new safety data
Pre-marketing ISS Safety Specification Approval Risk Management
Risk Assessment Implementation
Pharmacovigilance
Traditional analyses Plan Enhanced PMS/
plus Communication
Risk Minimization activities
Anticipated
conditions of use
Plan/ Risk Map Active influence on
Intrinsic/extrinsic safe use in the
risks (identified and market place
potential) Assessment of RM
Epidemiology of programme
disease effectiveness
Benefit : risk
assessment
New data
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Overall Objectives of Risk Management Planning
Benefit - Risk Optimization
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Optimizing Benefit Risk
High
Unacceptable Risk
i sk
l eR
Risk eab
n ag
Ma
Acceptable Risk
Low
Low Benefit High
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Risk Management Terminology
A Subject of Great Confusion
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Risk Management Planning
Understand the Terminology
Risk Management = Risk Assessment + Risk Minimization
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What Risk Management is Not ????
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..or is it ???
Generally, Risk Management is the process of
measuring, or assessing risk and then developing
strategies to manage the risk. In general, the
strategies employed include transferring the risk to
another party, avoiding the risk, reducing the negative
effect of the risk, and accepting some or all of the
consequences of a particular risk.
From Wikipedia, the free encyclopedia.
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Transatlantic Terminology Risk Management
FDA : Together, risk assessment and risk minimization form what FDA calls
risk management. Specifically, risk management is an iterative process of
(1) assessing a products benefit-risk balance, (2) developing and
implementing tools to minimize its risks while preserving its benefits, (3)
evaluating tool effectiveness and reassessing the benefit-risk balance, and
(4) making adjustments, as appropriate, to the risk minimization tools to
further improve the benefit-risk balance.
Europe : A set of pharmacovigilance activities and interventions designed to
identify, characterize, prevent or minimize risks relating to medicinal
products, including the assessment of the effectiveness of those
interventions
..but then along came REMS
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Risk Management and International
Harmonization
International harmonization is wonderful in
theory
.but everyone is harmonizing differently
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Global Risk Management Planning
The Challenge of Reconciling the Differences
Europe
ICH E2E +/- Risk Minimization Plans
US Japan
RM Guidelines ICH E2E + EPPV(?)
including RiskMAP/REMs
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Basic Components of a Risk Management Plan
Risk Management Plan
Safety Specification
Summary of important identified risks, important
potential risks and missing information
(ICH E2E)
Pharmacovigilance Plan
b
Based on safety specification; Routine PV practices and
action plan to investigate specific safety concerns
(ICH E2E)
Risk Minimization
Activities to be taken to minimize the impact of
specific safety concerns on the benefit-risk
balance
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Risk Management in Industry
General Considerations
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Risk Management and Planning
In preparing for battle I have always found that
plans are useless, but planning is indispensable."
Dwight D. Eisenhower
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RM Planning in Industry - Critical Success Factors
Safety governance support from the top
Comprehensive change management plan
Defined process and roles/responsibilities
Tools and skills to support the process
Partnership, education and training
Early planning in development
Financial planning
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RM Planning - Financial Implications
Authorship costs
in house staff or outsourcing
Cost of special expertise
Risk minimization activities . it is essential that appropriate
specialized experts should be consulted at all stages
Because of the importance of risk communication it is
recommended that appropriate experts are consulted
Epidemiological expertise
Cost of implementing proposed measures
Post marketing studies, educational programmes,
registries, drug utilization studies, etc.
Cost of delays to marketing approval
If the RMP is considered inadequate
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Risk Management in Industry
General Considerations
Communicating Change
An Essential Foundation to Implementing Risk Management
Planning Activities
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Risk Management in Industry - Stakeholder Groups
Corporate Senior Management
GRA Senior Management
Regional Medical and Regulatory
Global Product Teams/Medical
Central and Affiliate Product Safety
Licensing partners
Legal
Financial and marketing
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Risk Management in Industry
Key Messages
Good Risk Management Planning = Good Business; the
advantages of getting it right
Trade-off between investment and delay in authorization or
future product withdrawal..the risks of getting it wrong
Risk Management is not just a RiskMAP or REMS.or a
bureaucratic box to be ticked !
Global standards are critical
Additional PM studies are likely to be the rule, not the exception
Need to think beyond routine practice and the label
Risk Management is not going to go away.
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Risk Management Planning in Industry
Other Practical Considerations
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RM Planning - Practical Considerations
When to start RM Planning CIOMS VI Principles
Early in development; based on non clinical data & information on
closely related compounds
Establish a procedure & Multi Disciplinary Team; advisory bodies
Determine background data
Ready accessibility of all safety data
Develop a proactive approach
Establish time frames and milestones
Decision making : focus on safety reviews
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Generic Life-cycle Risk Management Planning Model
Development Risk Management Plan created
First Time in Humans
Candidate
PoC-Commit file and
selection - FTIH - PoC Phase 3 lifecycle .
to Ph3 launch
FTIH
Candidate FTIH PoC Commit Commit Approval Post-
Selection to Ph3 to file and launch launch
reviews
DRMP updated with significant new data at least RMP continues to be updated at
annually and before key development milestones agreed milestones; coordination
Evolves into the Risk Management Plan submitted with PSUR, labelling etc
with the Marketing Application 28
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RM Planning - Practical Considerations
The Role of Epidemiology
Important early in development and throughout the RM process
Critical for the Safety Specification and PV Planbridging the
knowledge gap
Defines demographics & expected characteristics of the target patient
population
co morbidities
anticipated AE profile in usual clinical practice
Design of post marketing safety studies/registries
Identification of existing databases
Design of drug utilization studies
Assess effectiveness of risk minimization measures
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RM Planning - Practical Considerations
What format to use
European template now in use since October 2006; why reinvent the
wheel???
Aim for a globalized document; concept of a Core RMP based on
ICH E2E and the European template with adaptation as required to
meet local needs e.g. EPPV in Japan ( risk assessment)
Getting the safety specification right is critical
Use tabulations and graphical presentation of data vs extensive
verbiage
Strategic risk minimization plan should be the same globally;
implementation can be tailored to local medical practice
Regulatory feedback and early discussion are useful to optimize
content
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Pharmacovigilance Plan
When is routine pharmacovigilance practice sufficient?
Probably not often and unlikely for NCEs (in Europe at least)
Initial experience indicates that US and Europe may request
different risk assessment activities; regionally focussed
Need to focus additional risk assessment activities on:
issues according to level of evidence & public health impact vs
theoretical considerations
clinically important risks
those which are practical, feasible and likely to yield meaningful,
timely results
Need for coordinated activities and consistent standards
(globally and across Europe)
Importance of well defined milestones
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Risk Minimization Plan
When is a specific Risk Minimization Plan needed ?
Not invariably but requires justification in the EU (approx 18% of RMPs)
Likely to be the most significant divergence between EU and US RMPs
Additional measures to mitigate known risks need to be :
Appropriate to the level of risk
Feasible in practice
Effectively communicated
Principles set at a global level but implementation according to local regulations/medical
culture etc
Multi functional input and close coordination with affiliates important
Current toolkit is limited
Need to be able to provide example (s) of proposed tools etc
Need to propose how effectiveness will be monitored; impact on spontaneous reporting
unlikely to be acceptable
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Risk Management Planning - Implementation
Experience
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..from both sides of the fence
EU Regulatory Authority Experience
Important Note:
The following slides from the EU authorities have
been obtained from the original author and with
their permission
The points made were from a previous external
presentation
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EMEA Experience with RMPs
01 September 2005 31 March 2008
Additional
Positive RMP Risk
Opinions Minimization
Activities
New Marketing 134 113 20
Authorisations
Post- 80 6
authorisation
Procedures
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European Regulatory Experience with RMPs
Review & Learning Project - Phase 1
RMP Assessment Number(%)
N=12
Satisfactory quality 3 ( 25%)
Non-compliance with EU RMP guidelines 9 ( 75%)
Missing parts
Specification, PhV Plan, Risk Minimization Plan, 8 (67%)
Summary etc
Protocol/outline
SPC not attached Several
Deviating Structure 5 ( 41%)
Non-relevance/redundancy (Safety Specification) 5 (41%)
Following the structure and contents of the EU guidelines and template
was considered sufficient to address most issues
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European Regulatory Experience with RMPs
Overall, XXX offers significant advantage in overall survival
and is an alternative to YYY for patients with ( Z disease)
that prolongs survival and has a positive benefit- risk profile
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Evaluation of the Need for Risk Minimization
Activities
none of the safety concerns was serious
and they can be managed by the means
of the proposals in the pharmacovigilance
plan. Therefore there is no need for a risk
minimisation plan.
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Potential for Medication Errors
There were medication errors identified in clinical trials
presumably due to misunderstanding of, or non-compliance
with, drug administration instructions.
Dose 10 mg 20 mg 40 mg
Shape Round Round Round
Size mm 6.2 x 2.8 7.9 x 3.3 9.8 x 4.3
Colour Pink Lightbeige Beige
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European Regulatory Experience with RMPs
There are no safety concerns with XXX, therefore there is no
need for a pharmacovigilance plan or risk minimization
activities
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Limitations of human safety
database
Table x: Exposure by baseline disease
No of patients
Total ( male/female )
Diabetic nephropathy 65 (39/26)
Hypertensive nephropathy 71 ( 47/24)
Glomerulonephritis 207 (143/64)
Other 246 (140/106)
Table y: Special population exposure
Population Number of patients
Children (<12 years) None
Elderly (>75 years) 14
Pregnant or lactating women None
Relevant co-morbidities
Hepatic impairment 57
Cardiac disease 243
.
Genetic polymorphism Not applicable
Ethnic origin
Caucasian 584
other 5 42
Risk Management Plans in Europe
Industry Experience
Increasing trend to request EU specific RMP vs global document
e.g.wish to see specific reference to SPC sections vs generic
statements relating to the CCSI
For submissions of a new indication/formulation with a mature product,
need to produce an RMP for the whole molecule
Strong emphasis on paediatric use
May require a paediatric RMP if evidence of significant off label use
Requests for :
studies in individual countries based on theoretical concerns
country specific PV activities/local RMPs where an EU RMP has been
agreed with CHMP
country specific drug utilization studies by pricing authorities
Variable interpretation of what constitutes an
important risk
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Is the Event Serious CIOMS V Survey
Adverse Event Term Yes No
Total blindness for 30 minutes 70% 30%
Suicide threat 17% 83%
Mild anaphylaxis 61% 39%
Spontaneous abortion 95% 5%
Most discrepancies related to disability, life-threatening condition or medical
significance
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Toxic Epidermal
Necrolysis
(TEN)
Clearly a serious and
important risk
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Flatulence
An important risk????
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Risk Management Plans in Europe
Industry Experience
Previous advice to produce one RMP per active chemical entity now
superceded by one RMP per medicinal product i.e by licence
May receive requests to split existing RMPs into multiple
documents
Level of detail required for PASS protocols may be unrealistic at submission
EU template very duplicative and unsuited to mature products
Overly long and repetitious document (industry view)
Based on EMEA experience : currently undergoing revision
Public access to RMPs is happening and will be
A key focus of future legislation
Adherence to milestone commitments a focus in PV inspections
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Risk Management Plans in the US
Early Industry Experience
Too early to determine practical impact of FDAAA and REMS
Circa 25% RMPs submitted to FDA are in the EU Template format and
accepted
Initial experience indicates that a very conservative approach is being taken
E.g. an extensive REMS requested for a product on the market for over
10 years in a new indication based on preclinical toxicology findings
thus far not substantiated in clinical use
Clear that the tools for risk minimization are still being thought through
Recent FDA inspections have focussed very strongly on compliance with
RMP commitments
Clear indication that FDA have specific expectations for REMS
i.e.the risk minimization section of the RMP
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Global Plan and US RMP Relationships
Global
Risk Management Plan
Safety Specification
ICH E2E
Pharmacovigilance Plan
ICH E2E
Determine if risk minimization
beyond label is warranted
Global Risk
Minimization Strategy
US Risk Minimization Activities
(RiskMap = Risk Minimization Action Plan)
REMS
(Risk Evaluation & Mitigation Strategies)
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Global Plan and EU RMP Relationships
Global
Risk Management Plan
Safety Specification
ICH E2E
Pharmacovigilance Plan
ICH E2E
Determine if risk minimization
beyond label is warranted
Global Risk
Minimization Strategy
EU Risk
Minimization Activities
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RMP Regional Variations
Global
Risk Management Plan
Safety Specification
Regional Safety
ICH E2E Specification Req
Pharmacovigilance Plan
Regional PV
ICH E2E Requirements
Determine if risk minimization
beyond label is warranted
Global Risk
Minimization Strategy
Regional Risk
Minimization Activities
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Risk Management Planning - Some Outstanding Issues
Intelligent risk management planning is clearly the right way forward; the
devil will be in the detail
Global RMPs are feasible at the time of submission...maintaining the global
status of the document is likely to be be a challenge
Everyone is still on the steep part of the learning curve !
RMPs are and will continue to be an increasing focus in PV inspections..but
do not forget that much of the content involves medical judgement
Public access to RMPS is a reality we have to deal with it !
Need to investigate more effective risk minimization( including
communication) methods . and how to assess their impact
Need to develop more transparent and objective benefit risk models;
emphasis on benefit risk and not just risk !
Need for involvement and intelligent communication with patients/public
what do the public actually wish to see ?
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Better Patient Focus
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Safety Communications - A Patient Perspective
Wonder Pills
Sir, My wife has been prescribed pills. According to the accompanying
leaflet, possible side-effects are: sickness, diarrhoea, indigestion, loss of
appetite, belching, vertigo, abdominal cramps, dizziness, stomach ulcers,
bleeding from intestine or blood diarrhoea, ulcerative colitis, sore mouth
and tongue, constipation, back pains, inflammation of pancreas, mouth
ulcers, skin rashes, hair loss, sensitivity to sunlight, drowsiness, tiredness,
impaired hearing, difficulty with sleeping, seizures, irritability, anxiety,
depression, mood changes, tremor, memory disturbances, disorientation,
changes in vision, ringing in ears, bad dreams, taste alteration, allergic
reactions, swelling due to water retention, palpitations, impotence or
tightness of the chest.
Should she take them?
Yours faithfully,
A D. O, Information withheld due to
data privacy
Hertfordshire. Letter to the Editor,1996
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Risk Management - Conclusion
Embracing Change
It is not the strongest of the species that survive, nor
the most intelligent, but the one most responsive to
change.
Charles Darwin, 1859
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