Posts Tagged ‘safety’
Wednesday, August 12th, 2009
Your company wouldn’t launch a new product and wait for the end-of-year results before assessing whether the launch strategy was effective, correct? In fact, the process most pharmaceutical product managers employ includes weekly measurement of prescription volume, tracking product inventory, assessing distribution patterns of promotional materials, measuring knowledge/attitude/practices of prescribers, and adjusting marketing activities to achieve success.
So why would tracking and adjusting risk management activities be any different? FDA requires an assessment of REMS performance at intervals no less frequently than 18 months, 3 years, and 7 years post launch. What are you doing before and between formal assessments to actively manage and maximize the effectiveness of the REMS? (more…)
Tags: benefit-risk, EASU, FDA Guidance, patient safety, REMS, REMS document, REMS effectiveness, REMS elements, REMS program, risk management, safety
Posted in Pharmaceuticals, REMS | No Comments »
Thursday, July 30th, 2009
One of the more challenging aspects of the new FDA world of REMS is the tension it can create among various functional groups such as Marketing, Risk Management, Safety and Medical within a Pharma or Biotech company. Rules are unclear. Territories are vaguely defined. New objectives seem similar to the old but may not be in reality. And it involves many players, across most internal disciplines. Maybe it’s time that we all think of this as a cross-disciplinary sport that no one really knows how to play well, yet.
The urgency of the new regulatory environment is simply demanding some quick innovative thinking and action.
Some of our clients and others are addressing this new “X-Disciplinary Sport” to good advantage. There are a number of principles that, if kept at the forefront of thinking, can help you re-organize and align your teams around this new REMS-driven world. (more…)
Tags: approval, FDA Guidance, medication, medications, NDA, patient safety, regulatory, REMS, REMS design, risk management, safety
Posted in Appropriate Use, Pharmaceuticals, REMS | No Comments »
Wednesday, April 8th, 2009
What a difference a year makes…
In early 2008, the topic of risk management was greeted with aversion by most pharmaceutical managers responsible for commercial activities. “If I encounter a drug with genuine safety concerns, I’ll call you” was a frequent response.
Today, everyone is talking about risk management… and for good reason. The FDA Amendment Act (FDAAA) of 2007 granted FDA sweeping new authority to require Risk Evaluation and Mitigation Strategies (REMS) of any product at any stage of lifecycle. In response to FDAAA, industry had three immediate questions:
- What determines if REMS will be necessary?
- How actively will FDA implement the REMS provisions?
- Who should be thinking about risk management?
(more…)
Tags: benefit-risk, contingency plan, evidence-based, FDA Guidance, FDAAA, FMEA, medication, ParagonRx, patient safety, pharmaceutical safety, REMS, REMS elements, REMS program, risk assessment, risk evaluation, risk management, safety
Posted in Pharmaceuticals, REMS | No Comments »
Thursday, February 19th, 2009
REMS programs for opioid drugs? A worthy approach but many questions remain to be answered.
Developing an effective REMS program – one designed to preserve access for every person who would benefit from a medication while avoiding exposure in situations and individuals with excessive risk factors – is a challenge. The difficulty increases when the risks expand beyond inadvertent misuse to also include intentional abuse.
Recently the FDA signaled its intent to tackle risks involving opioids that have both significant benefits for certain segments of patients and also the potential for misuse and abuse. On March 3, the FDA will sit down with 15 manufacturers of 24 opioid medications to begin the process of outfitting them with REMS.
(more…)
Tags: appropriate use, FDA Guidance, guidance, Jeff Fetterman, medication, medications, NDA, ParagonRx, pharmaceutical risk management, REMS, REMS program, risk management, risk mitigation, safety
Posted in Pharmaceuticals, REMS | No Comments »
Friday, February 6th, 2009
REMS planning is not only good for safety, it can also help increase product adoption.
If you’re interested in REMS because you’re in the Regulatory, Legal, Medical or R&D departments of a pharmaceutical, device or biotech manufacturing company, you might want to forward this post to your colleagues in Marketing, especially if they are working on product launches. Many Marketing people intuitively suspect any attempt to guide appropriate use of their fledgling product – such as a REMS or other risk management program – is going to negatively affect sales and reputation.
And that does make sense, doesn’t it? But the facts don’t support the belief.
(more…)
Tags: appropriate use, approval, FDA Guidance, Jeff Fetterman, medication, medications, ParagonRx, regulatory, REMS, REMS program, risk management, safety
Posted in Pharmaceuticals, REMS | No Comments »