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Letters to the Editor
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Thalidomide
Managing the risks of thalidomide
From Mr F. G. Astbury
As president of Thalidomide UK, which represents the interests of thalidomide
victims in the UK, I wish to respond to the article by David Thomson
and Toby Capstick (PJ, 14 February, p190).
Thalidomide UK has provided the European Agency for the Evaluation of
Medicinal Products with a detailed and confidential consultation on Pharmion’s
application for a product licence. For the benefit of PJ readers, this
letter presents an overview of some of our concerns.
Thalidomide UK firmly recognises that thalidomide is of major benefit
in the treatment of multiple myeloma. It is not opposed to a risk management
programme in principle. However, it has severe reservations as to the
programme adopted by Pharmion — the Pharmion Risk Management Programme
(PRMP) based on Celgene’s STEPS programme used in the US.
· In the first instance, PRMP is ill-suited to UK prescribing practice.
From our discussions with oncologists and pharmacists, it is clear that
the time-consuming and laborious inputs required by Pharmion from prescriber,
patient and pharmacist could deter these groups from using thalidomide.
We have particular concern over the intrusive nature of the disclosures
that patients are required to give, not least of all in view of data
protection considerations and concerns over patient confidentiality.
· Secondly, Thalidomide UK questions the ability of Pharmion to manage
the PRMP at all. As reported in the national press, in December 2003
we were able to obtain thalidomide over the internet from Pharmion by
registering as a bogus pharmacy in the PRMP. We understand that Pharmion
claims to have since amended its procedures to close this loophole. Nonetheless,
we strongly believe that such a major lapse severely compromises the
company’s ability to control thalidomide distribution.
· Thirdly, we have had adverse comments from several pharmacists at
children’s hospitals that, whereas the previous suppliers Penn
Pharmaceuticals had a 25mg capsule available, Pharmion only markets a
50mg presentation, which is not appropriate for younger children and
increases the administration risk.
· Our final concern is over the price currently being charged by Pharmion,
which has increased 400 per cent since it took over supply from Penn
Pharmaceuticals in July 2003. This clearly places an extra burden on
the NHS and, once again from our discussions with oncologists and hospital
pharmacists, could well prove a deterrent to it being prescribed for
patients suffering from multiple myeloma.
In light of these and other concerns, Thalidomide UK does not support
the PRMP nor does it support Pharmion’s current application for
a product licence for thalidomide.
Freddie Astbury
President,
Thalidomide UK
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Patrick J. Mahaffy, president and chief executive officer, Pharmion
Corporation, replies:
Pharmion is pleased that Thalidomide UK acknowledges
the benefit that thalidomide can bring to patients with serious
diseases and that it also endorses the need for a stringent safety system.
However
its letter raises a number of points that Pharmion would like to
address.
In response to the first point pertaining to the suitability of
the Pharmion Risk Management Programme (PRMP), Mr Astbury is correct
that
the PRMP is based
on Celgene’s STEPS programme in the US. Pharmion wishes to point out that
this system has proved highly effective and was a critical factor in the FDA
approving Celgene’s licence application. Furthermore, Thalidomide Pharmion
has now been licensed in Australia and New Zealand. In all cases the licence
was granted on the condition that the Pharmion PRMP system was in place.
Although local health care systems vary between countries the aims of the
PRMP remain the same — to protect patients and health care professionals
and to ensure that the risks of a thalidomide baby being born are as minimal
as
possible. Pharmion acknowledges that the PRMP system is detailed and requires
a high level
of commitment by health care workers and by Pharmion. Health professionals
accept the importance of a strict programme to ensure that a vital medical
treatment
is used safely and the terrible events of the 1960s are never repeated. The
system has been in use in Europe for over eight months, many thousands of
patients and
health care professionals have registered and the system has been accepted
and successfully implemented in many hospitals through out Europe.
In response to Mr Astbury’s comment regarding the management of the
PRMP system, Pharmion acknowledges there have been several attempts by Thalidomide
UK to register on the PRMP fraudulently and obtain thalidomide. In one instance
thalidomide was successfully obtained and this has resulted in increased
security
around the PRMP system. The programme has been designed as a safeguard and
information system for patients receiving thalidomide; it was not designed
with the thought
that individuals would try to break into the system fraudulently for the
purposes of obtaining thalidomide. Pharmion has regularly involved Thalidomide
UK in
plans regarding licensing and risk management. As thalidomide is still easily
obtainable
from other sources which are selling the drug without any safety procedures,
Pharmion is surprised that Thalidomide UK has decided to target the only
company seeking to license and monitor the use of thalidomide.
Thirdly Mr Astbury mentioned that Pharmion does not currently offer a 25mg
capsule of Thalidomide Pharmion. The company would like to point out that
this presentation
is not currently available because it is still awaiting EMEA approval.
It is normal procedure for a limited range of doses to be developed before
approval
due to associated manufacturing costs. It is the company’s intention
to extend the product range should a marketing authorisation be granted.
Finally, the company would like to respond to Mr Astbury’s concerns
about the cost of Thalidomide Pharmion. At present thalidomide is unlicensed
in Europe
and is being provided by numerous companies with hugely varying degrees of
quality control and safety systems. Pharmion is the only company that has
applied for
a formal marketing authorisation to distribute thalidomide and this licensing
application is associated with many benefits for patients and professionals.
These benefits are not possible, however, without investment from the company.
With licensed thalidomide, patients can be confident that the product they
are taking is manufactured to the highest level and there is no risk of variability
between batches. All pack details, package inserts and information for Thalidomide
Pharmion will comply with current EU regulations and are provided to each
market in local language. The manufacturing of Thalidomide Pharmion is also
audited
by the regulator to ensure full compliance with Good Manufacturing Practice.
Under the PRMP all reported side effects are recorded and compiled. Furthermore,
Pharmion is committed to providing education to clinicians treating myeloma
patients
about the merits of thalidomide. Patients themselves will be able to get
a full information pack on the product in all EU countries and in their local
language.
The company is also funding a succession of clinical trials to expand understanding
of how the product works, moderate its side effects and look at new indications.
No other supplier in Europe is currently investing in thalidomide safety
and
research to this extent.
Since the early stages of its plan to license Thalidomide Pharmion, Pharmion
has maintained transparent and two way communications with the EMEA, patients’ associations,
nursing groups and thalidomide victim groups throughout Europe to ensure
the correct information is being provided to patients and all the necessary
precautions
to avoid pregnancy are in place. It is determined to ensure that Pharmion
achieves a balance between the need to control safe access to thalidomide
and the requirements
of medical practitioners treating genuine patients.
With thalidomide still readily available throughout Europe from many unlicensed
suppliers and even over the internet, it is unfortunate that Thalidomide
UK is focusing its attention on Pharmion and the PRMP when the company
fully welcomes
its support and has made every effort to ensure it is informed about Pharmion’s
activities. Pharmion believes that thalidomide should be a licensed and regulated
product in Europe, as it is elsewhere in the world and that all interested
parties should work together to bring this product under control as soon
as possible. |
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