Warning and NOV Summary – 4th Quarter 2012

To gain insight into the most recent thinking at FDA’s Office of Prescription Drug Promotion (OPDP), Eye on FDA regularly reviews the number of letters and types of violations that were cited by the agency each quarter in Warning Letters and Notice of Violation (NOV) – also known as Untitled Letters.  I usually aim to get these out about 4 weeks after the end of the quarter, but here it is – a bit late.

This quarter there were a total of six letters issued, for a  grand total for 2012 of 28 letters, two fewer than last year.

For this quarter, the 6 letters carried a total of 15 different violations involving 9 different communications vehicles.  There were NO warning letters issued, 6 letters were Notice of Violation (NOV) or Untitled letters.   Of the 9 communications vehicles, 5 were digital while the balance were non-digital.  These included 2 visual aids, 1 sales aid, 4 involving Website copy, 1 video and 1 pitch letter.  Here is a breakdown of the violations incurred:

As usual the most common violation was the omission or minimization of risk.  It is also, however, noteworthy that there were two violations for the relatively less common promotion of an unapproved drug.

Every so often, OPDP carves out “new territory” with its regulatory action letters.  It is, after all, one of the few means by which FDA/OPDP enunciates policy – the other being through the painstakingly slow and laborious process of developing draft guidances.  For example, in 2009, the agency issued a slew of letters that cited a common and long-standing practice to use sponsored links in the context of product promotion.

The last quarter of 2012 involved an instance where another common practice – using a pitch letter to transmit a press release – was defined as part of material that is considered promotional. Therefore the fact that the pitch letter contained information about the product that included the indication and efficacy claims but did not include risk information within the letter (only within the press release) was deemed a risk violation.  That means one of two things for communicators.  Either do not mention information about a drug’s in a the text of the transmittal letter for a press release, or if you do, include risk information and run it through MedReg.

As for the first quarter of 2013, sequester at FDA may have kicked in a little early. So far there have been only two letters issued (none in January).

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Job Hunting? – Social Media Career Resources in Pharma

As I mentioned last week, I have put together a data base – a constant work in progress – of pharma activities in social media.

One of the fields on which I can perform sort on is one where I have assigned each social media effort with a classification of its functional purpose.  So, I can sort to see which of the social media assets are product-based, which are disease-specific, which are corporate. One of the assigned categories is Career.

To that end, I thought it might be handy to provide potential job seekers with an overview of what kinds of social media career resources that have been provided by industry.

There are bound to be some missing here, so please email me with any pharma-sponsored resources that should be added.

Here are the ones I know of:

Facebook -

Twitter – While there appear to be a fair number of these, it should be noted that some of the feeds have not had entries in several months, some have sporadic entries, and still others are quite active.  Also if you care to follow just pharma career twitter feeds, a Pharma Jobs twitter list is available on the Eye on FDA Twitter feed.

Two other resources that may be useful, but are not pharma sponsored are

Pinterest

YouTube

Good hunting!

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Offshore Tweets and Pharma

A Database of Pharma and Social Media!

I have lately had a hankering to be putting together more data bases that let me see more of what is going on in the world.  I like databases.  I like asking questions and getting answers.  Data bases are, I think, like looking in a microscope.  You see something very differently when you look at it up close than you can from far away.

One of the databases I have been working on is one that will be an on-going work in progress that focuses on the activities of pharma and social media.  Accordingly I have entered into a data base every pharma Twitter feed, Facebook page, YouTube channel and Pintrest page of which I am aware.  I have not yet entered into it every blog or Google+ page.  But so far, I have identified over 200 pharma Twitter feeds, over 150 pharma sponsored or funded YouTube channels, and over 100 Facebook pages.

The fields that I am tracking in the data base include a number of characteristics – what type of page is it – corporate, product, disease/conditions specific (and if so, what disease?) and things like that.  This can be very handy for assessing the social media landscape in a variety of ways.  And one of the fields tracked for the Twitter feeds is the country of origin for the feed – which gets me to my point – but in a minute.

On my own Eye on FDA twitter feed, one thing that I have noticed when looking at my statistics is that (1) there have been some growth spurts in the number of my followers lately, and (2) that much of the growth seems to be happening from outside the U.S.  I know this because I have watched the country of origin profile of followers who end up clicking on a link in one of my tweets and noticed that the proportionate number of those from the U.S. has been shrinking over time.  While it used to be that around three-fourths of my clickers were U.S., it is now just over half.

As state above, I have identified over 200 pharma Twitter feeds and I assumed that most of them would be U.S.-based.  On doing a sort on country-of-origin, however, I found that while the U.S. had a plurality of the feeds (89), it did not have the majority of feeds.  The country with the second largest number of pharma-sponsored Twitter feeds was Germany (20).

Even though the database is probably lacking many existing social media efforts, there are enough to give me a good lay of the land.

Another of the fields being tracked is the number of followers each feed has – a time consuming field as it changes and needs to be updated to be accurate.  The last numbers were tracked in the summer of 2012, but reveal that of the five largest pharma/device sponsored Twitter feeds, only the top two are U.S. based, followed by one in Korea, one in Switzerland and one in the U.K.

And so, you see, this is why I like data bases.  They open my eyes and challenge my suppositions with real data….and I did not realize that pharma and tweets were so much a foreign affair.

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Upcoming AdComm Topics

Earlier this month, I put up the schedule for the dates that FDA has scheduled for advisory committees for the year to give some limited as it provides a little insight into what can be expected in the way of approvals, though this year there were so many dates “TBD” that it may be a slightly more uncertain exercise than in years gone by.

In 2012, FDA approved 39 new drugs – the most in 16 years.  For this year, there are already a large number of meetings scheduled to consider new NDAs as well as some policy matters.  Here is an overview of what is to come for the rest of the first quarter 2013:

  • January 29-30 – Pulmonary-Allergy Drugs Advisory Committee - On the 29th, meeting to discuss NDA for olodaterol (proposed name Striverdi Respimat) for proposed indication to treat COPD, sponsor Boehringer-Ingelheim.  On the 30th, the committee will meet to discuss NDA for mannitol inhalation powder (proposed name BRONCHITOL) for the management of cystic fibrosis.
  • February 12 – Risk Communications Advisory Committee - The committee will meet to discuss a very interesting topic – general factors in risk communication about FDA approved products, including approaches to avoid message fatigue and related communications barriers such as prevention or warning fatigue or inaccurate risk perception.
  • February 12 – Blood Products Advisory Committee – Meeting at Fishers Lane, this Blood Products AdComm will meet to discuss a BLA for proposed indication as a botulism antitoxin heptavalent (A, B, C, D, E, F) -(Equine), sponsor Cangene, seeking licensure under FDA’s authority to approve a product based on evidence of safety in humans and efficacy in animals when human efficacy studies are not feasible or ethical.
  • February 14 – Medical Imaging Drugs Advisory Committee – This meeting will be to consider NDA for gadoterate meglumine injection (proposed tradename DOTAREM), sponsor Guerbet, LLC, proposed for use as MRI in the brain and spine to detect areas with disruption of the blood brain barrier and/or abnormal vascularity.
  • February 22 – Neurological Devices Panel of the Medical Devices Advisory Committee – This committee will meet on the 22nd to discuss, make recommendations and vote on information regarding the premarket approval application (PMA) for the NeuroPace RNS System proposed as adjunctive therapy in reducing frequency of seizures in adults with partial onset of seizures from no more than two foci that are refractory to two or more anti-epileptic medications.
  • March 4 – Reproductive Health Drugs Advisory Committee – The committee will meet to discuss 2 NDAs in one day – the first being for Depomed’s gabapentin 600 milligram tablets for the proposed indication for the treatment of moderate to severe vasomotor symptoms due to menopause; the second slated for the afternoon discussion will be to consider Noven Therapeutics’ NDA for paroxetine meylate 7.5 mg capsules also for the proposed indication of treatment of moderate to severe vasomotor symptoms due to menopause.
  • March 5 – Joint Meeting of the Reproductive Drugs Advisory Committee with the Drug Safety and Risk Management Advisory Committee – The Committees will meet jointly to discuss whether the benefit of cacitronin salmon for the treatment of postmenopausal osteoporosis outweighs any risk.
  • March 7 – Pulmonary-Allergy Drugs Advisory CommitteeThis meeting will be to consider another proposed COPD treatment.   Submitted by GlaxoSmithKline, the NDA for fluticasone furoate and vilanterol dry powder inhaler (proposed tradename BREAO ELLIPTA) seeks approval for the treatment of airlfow obstruction and for reducing exacerbations in COPD patients.


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Election Impact – The New Class

Around elections, I have usually tried to provide some insight into where candidates stood on health care related issues, particularly affecting the development and marketing of medical products.  I wasn’t able to do that through this election cycle, but now that the dust has settled, new members to Congress elected and sworn in, it is a good time to assess where we are.

Fortunately, friends over at TogoRun - a health care public affairs agency with offices here in Washington, New York and in London – produced a handy guide to the newly elected. THE FRESHMAN HEALTHBOOK is a downloadable handbook looks at the new members of the 113th Congress through a lens of positioning on key health care issues including the Patient Protection and Affordable Care Act (ACA), medical innovation, children’s health, and Medicare among other issues.  It is a concise yet comprehensive overview of the new members and their positions.

One can quickly see that this new class offers more diversity and breaks new ground in many ways.  Ironically, despite that increased diversity, it is also reported in the media that the prospects for this Congress be able to overcome some of the partisan obstacles of the past is not likely.  THE FRESHMAN HEALTHBOOK is a resource that helps you decide for yourself, as well as to get a lay of the land with respect to issues that are of importance to you.

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Posted in Current Affairs, Legislation | 1 Comment