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Vol 273 No 7318 p416
25 September 2004

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Why the current situation doubly disadvantages children with cancer

By Jane Buckham, Tasneem Khalid, Nigel Ballantine, Vicky Holden and Julie Mycroft

Jane Buckham, Tasneem Khalid, Nigel Ballantine, Vicky Holden and Julie Mycroft, of the Paediatric Oncology Pharmacists Group steering committee

The current trend to develop cancer chemotherapy drugs that can be administered orally at home is commendable in terms of improving patients’ quality of life. With effective safeguards in place to ensure compliance with therapeutic regimens and prevent toxicity, as proposed by the British Oncology Pharmacy Association, this has to be the way forward.

Unfortunately oral cytotoxic preparations rarely provide suitable denominations of dose, or appropriate formulations such as mixtures, melts or soluble tablets, for paediatric use. This leaves paediatric oncologists and pharmacists with the predicament of having to expose children and their carers to manipulation of adult cytotoxic preparations or have pharmaceutical “specials” manufactured locally. These “specials” have only limited quality control validation, because they are supplied at the request of the prescriber on his or her liability.

“ Special” liquid formulations are often made in a variety of strengths and although, on the advice of the Paediatric Oncology Pharmacists Group, standard strengths are recommended for use in current children’s cancer trials, there is no way of ensuring that hospitals that provide “shared care” for these children use the standard preparation.

Specials also have not had the benefit of the rigorous testing to satisfy licensing criteria in a clinical setting.

The alternative of cutting or crushing tablets, or opening capsules and dispersing the resulting powder in water, exposes both the carers and the home environment to cytotoxic contamination. In a percentage of families this may include exposure of the fetus of an unborn sibling to contamination.

Since 90 per cent of children with cancer in the UK are treated at UK Children’s Cancer Study Group centres, the majority on UKCCSG or Medical Research Council clinical trials, both options have the potential to reduce the validity of the trial because variable bioavailability can affect patient outcomes. This can be accentuated because of the narrow therapeutic index of cytotoxic agents. It also contravenes the EU clinical trials directive. The alternative is to develop, with the pharmaceutical industry, paediatric oral chemotherapy preparations. The proposed EU directive on patent extension for licensing of preparations with paediatric studies and exclusivity rights for generic paediatric preparations may help. However, experience suggests that minority patient groups, such as children with cancer, do not make such products economically viable to the pharmaceutical industry.

The Paediatric Oncology Pharmacists group has tried for the past two years to find a UK manufacturer to take over the production of an unlicensed small dose tablet of mercaptopurine used in the treatment of paediatric acute lymphoblastic leuk-aemia. This preparation, available in the UK for over 30 years, has been with withdrawn because of its unlicensed status and new regulatory requirements for manufacturing facilities. The previous manufacturer was not prepared to “sell” the product to a third party to continue production. Despite the support of the Department of Health, the combined obstacles of a confined paediatric market, which is too large for a single “specials” manufacturer but too small for major commercial gain, plus the necessity for production in a cytotoxic facility with its additional health and safety requirements, has meant that we have been unable to source an alternative product in the UK. Increasing health and safety legislation in the manufacture and handling of cytotoxic preparations ensures that production costs for such hazardous substances are high and few pharmaceutical manufacturers are prepared to enter into this market.

We have therefore been working with a German group to enable it to facilitate the commercial expansion of a “child friendly” soluble tablet developed at the University of Münster. Despite the evidence of a potential Europe-wide market for a drug with an established track record and potential eligibility for fast-track licensing under “orphan product” status, the German group has found it difficult to make the transition into commercial production. As a result, a less “child friendly” generic non-soluble tablet has been produced, which, it is hoped, will be licensed in the future. This can then be licensed in other EU countries by reciprocal agreement, at least improving the availability of a product to provide suitable dose increments for children outside the UK.

This, so far, has been a successful co-operation between the trial co-ordinators for the current children’s leukaemia trials and a pharmaceutical manufacturer. However, concern was raised again earlier this year at the suggestion of the withdrawal of the liposomal formulation of daunorubicin. Although this product is used by both children and adults, it is currently used predominantly for relapse therapy, so has a small market of vulnerable patients who have previously had anthracycline therapy and will, therefore, be unable to tolerate the cardiotoxicity of repeated native anthracycline. In this case the manufacturer has agreed to continue production.

It is becoming apparent that the UK needs a facility which is able to take over the production of existing products when commercial or other considerations would result in them being withdrawn from the market. This particularly applies to cytotoxic, biological and non-hazardous low-volume formulations, many of which will be paediatric preparations by virtue of the restricted paediatric market.

At present only a voluntary DoH code of conduct exists to protect essential medicines from discontinuation. This area of “discontinuation of medicines” has been highlighted again in the recent DoH/Medicines and healthcare Products Regulatory Agency strategy document on medicines for children as being ineffectively protected by current legislation. This will continue to happen until legislation is enacted to ensure that the intellectual rights to a product are made available to a new manufacturer.

We understand that an NHS facility in London has recently been granted development funds which may enable it to move into the area of cytotoxic production, but without the original development and production information development of a replacement product is both more time consuming and costly and will slow the licensing process of a replacement product further.

These recent EU proposals and investment are to be welcomed but they need to be taken further to protect existing preparations and ensure the future development of effective treatment for children with cancer and other rare diseases.

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