Secretary’s note regarding the minute below from the 54th meeting of
the Medicines Classification Committee (MCC) held on Tuesday 24 November
2015:
Medsafe received a request from the Royal New Zealand College of General
Practitioners to amend the minutes of the 54th meeting of the MCC because
it inaccurately records that the Green Cross Healthcare Ltd alternative
proposal for the reclassification of oral contraceptives had been released
for public consultation.
The Chair of the MCC has decided that the minute in question stands as
an accurate reflection of the Committee’s deliberation.
At the 54th meeting the Committee did consider that the Green Cross Healthcare
Ltd proposal had been released for public consultation. The Committee drew
this conclusion because a number of comments had been presented that specifically
mentioned the alternative proposal.
It only became apparent after the meeting that the submitters had only
circulated the alternative proposal to a selected number of individuals
and organisations.
That the selected oral contraceptives (desogestrel, ethinylestradiol,
norethisterone and levonorgestrel) should be reclassified as restricted
medicines, when sold in the manufacturer's original pack containing not
more than six months' supply by a registered pharmacist who has successfully
completed a training programme (endorsed or accredited by an organisation
that is to be confirmed as stated in the following recommendation), when
indicated for oral contraception in women who have previously been prescribed
an oral contraceptive within the last 3 years from the date of an original
medical practitioner's prescription.
That Green Cross Healthcare Limited should provide Medsafe with details
of who will be responsible for accrediting the training programme and maintaining
and enforcing the provisions under which a pharmacist with additional competencies
could prescribe selected oral contraceptives.
That Green Cross Healthcare Limited should update Medsafe of the changes
required to the training and monitoring procedures to reflect the Committee's
recommendations.
That market sales should be collected and analysed to monitor the success
of the scheme in improving access to oral contraceptive pills. The Committee
is interested in being updated on the outcomes of this recommendation.
This item will therefore be added to the agenda of the next meeting as
a matter arising for further consideration
1
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Welcome
The Chair opened the 54th meeting at 9:37 am and welcomed
the new member, current members and guests.
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2
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Apologies
No apologies were received.
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3
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Confirmation of the minutes of the 53rd
meeting held on Tuesday 5 May 2015
The minutes of the 53rd meeting were accepted as a
true and accurate record. The minutes were signed and dated by the
Chair.
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4
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Declaration of conflicts of interest
The Chair explained the principles of a conflict of interest
declaration to new and existing members. The Chair emphasised that
members were selected as independent experts in their fields and
the importance of maintaining independent decision making especially
if members have multiple professional roles. He explained that for
these reasons, committee members needed to ensure transparency in
their decisions by declaring potential conflicts of interest. A
member raised a question about the confidentiality of the meeting
papers and discussions undertaken. The Chair advised all members
should read the spokespersons protocol in the Handbook.
The Conflict of Interest forms were returned to the Secretary.
The following conflicts of interest were declared:
- Dr K Baddock declared that she is the deputy chair of NZMA
and a member of the Medical Council of New Zealand. After discussion,
the Committee decided that Dr Baddock could fully participate
in the meeting as her offices are independent of her role as
a committee member.
- Mrs A Harwood declared that she is the director of Port
Chalmers Pharmacy and this may be a conflict of interest of
agenda item 5.1.1 oral contraceptives. After discussion, the
Committee decided that Mrs Harwood could participate in the
meeting as she was not involved in the objection.
All other members declared they had no additional interests which
would pose a conflict with any of the items on the agenda.
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5
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Matters arising
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5.1
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Objections to recommendations made at
the 53rd meeting
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5.1.1
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Oral contraceptives – proposed reclassification
from prescription medicine to restricted medicine (Green Cross Healthcare
Limited)
Purpose
This was a company objection to the recommendations made at the
previous meeting.
The objection (PDF 222 KB, 3 pages) was made on the grounds
that:
- the recommendation made was outside of the Committees guidelines.
- departure from aspects of the Members' Handbook, including
the expectation that members should have 'an interest in fostering
self-medication where safe and appropriate'.
- unstated conflicts of interest.
- the need to be evidence based.
- the inappropriate and unprecedented role given to the major
medical organisations in a reclassification.
Background
At the 7th meeting on 31 July and 1 August 1990, the
Committee confirmed that desogestrel, ethinylestradiol, levonorgestrel
and norethisterone were all classified as prescription medicines.
At the 14th meeting on 2 November 1994, the Committee considered
the safety issues related to the use of oral contraceptives and
decided to produce an extensive public consultation plan before
making any recommendation on the reclassification of oral contraceptives.
At the 15th meeting on 20 November 1995, the Committee
recommended that further consideration of the reclassification of
oral contraceptives should be deferred until the results of the
several ongoing studies had been published and analysed. At the
time several studies claimed that low dose oral contraceptive pills
containing desogestrel and gestodene presented an increased risk
of thromboembolism compared to other low dose oral contraceptive
pills.
At the 51st meeting on 8 April 2014, the Committee
recommended that desogestrel, ethinylestradiol, levonorgestrel,
and norethisterone should not be reclassified from their current
schedule entries.
At the 53rd meeting on 5 May 2015, Green Cross Healthcare
Limited made a submission to reclassify specific oral contraceptives
from prescription medicines to restricted medicines to allow pharmacists
who have completed a certified course approved by the Ministry of
Health to prescribe to women who meet specific criteria. The submission
included consideration of the specific points raised by the Committee
at the 51st meeting. Each concern raised by the Committee
was claimed to be addressed. The submission argued that the model
of care it proposed had now been reviewed by primary healthcare
professionals and a more conservative approach had been taken.
The Committee recommended that desogestrel, ethinylestradiol,
levonorgestrel, and norethisterone should not be reclassified from
their current schedule entries.
The major reason it was declined was that the submission was
not supported by a medical organisation.
Desogestrel, ethinylestradiol and norethisterone are currently
classified as prescription medicines. Levonorgestrel is currently
classified as:
- prescription medicine; except when specified elsewhere in
this Schedule; except in medicines for use as emergency post-coital
contraception when sold by nurses recognised by their professional
body as having competency in the field of sexual and reproductive
health
- restricted medicine; in medicines for use as emergency post-coital
contraception when in packs containing not more than 1.5 milligrams
except when sold by nurses recognised by their professional
body as having competency in the field of sexual and reproductive
health.
Green Cross Healthcare Limited has objected to the decision made
at the 53rd meeting. The original proposal has been documented
with the 53rd meeting minutes. The objection was based
on:
- Criteria for reclassification was not followed.
- Support from medical representative bodies is not a prerequisite.
- Fragmentation of care is not a classification criterion.
- Access via other medical visits is not a classification
criterion
- Committee had not fully captured the benefit of increased
access in preventing unintended pregnancy.
- Royal Australian New Zealand College of Obstetrics and Gynaecology
(RANZCOG) partially supported the proposal. They supported the
availability of oral contraceptives only to women who had previously
been prescribed i.e. oral contraceptive naïve patients were
excluded.
Green Cross Healthcare Limited submitted a revised proposal for
consideration if the objection was upheld. The alternative proposal
requested the reclassification of desogestrel, ethinylestradiol,
levonorgestrel, and norethisterone to restricted medicines when
indicated for women who had previously been prescribed an oral contraceptive
pill (OCP).
The alternative option proposed that oral contraceptives be available
from trained pharmacists for the following five scenarios:
- NZ woman runs out of her oral contraceptive
- Woman visiting from overseas who has run out of her oral
contraceptive
- Woman receiving the emergency contraceptive pill who is
a previous oral contraceptive user
- Woman wanting to restart contraception who is a previous
oral contraceptive user
- Woman wanting post-partum contraception who is a previous
oral contraception user
Comments
Thirteen comments regarding the proposed reclassification of
selected oral contraceptives were received. One submission commented
on why they did not support the proposal. Their reasons are as follows:
- Oral contraceptives as a prescription medicine do not constitute
a significant barrier to accessing them.
- Any existing concerns about access can be addressed via
a delegated collaborative model of prescribing under the Medicines
Amendment Act 2013.
- An important aspect of prescribing oral contraceptives is
the advice and counselling about its use as well as general
sexual heath, particularly for young females. In some cases,
when females are requesting advice on contraception or sexually
transmitted infections (STI), opportunistic medical intervention
is appropriate and this will not be available in a pharmacy
setting.
- The importance of a thorough background check including
a physical examination where indicated (where there is a suspected
STI) to assess whether there is a risk.
- Concerned the proposed reclassification will further fragment
patient care with potentially serious consequences for patients,
including unintended pregnancy or life threatening adverse events.
Twelve comments supporting the proposed reclassification were
received. They were from a combination of individuals and organisations.
Comments made by the supporters include:
- The proposed reclassification would increase the accessibility
of selected oral contraceptives, particularly to young females,
those from a cultural background that consider the topic of
sexual health taboo, those living in a rural area and those
that come from a low income family.
- Green Cross Healthcare Limited have presented an alternative
option that is a collaborative approach between pharmacists
with additional competencies and Family Planning and/or General
Practitioners. Pharmacists will refer women to Family Planning
and/or GPs for ongoing contraceptive discussions, STI checks
and smear tests.
- There are successful models of pharmacists providing medicines
without a prescription. Family Planning and student health are
able to distribute contraception without knowledge of the patient's
medical history.
- This is in the interest of women's health and self-management
of contraception for the prevention of unintended pregnancies.
- Pharmacists are capable and this will allow GPs to see patients
with more complex needs.
- Oral contraceptives are safe and meet the criteria for reclassification.
- The previous decision made by the MCC was outside of their
guideline; in deciding that continuity of care and absence of
support from major bodies was the reason to decline the reclassification
of selected oral contraceptives.
- The concern of fragmented care is less important than the
risk associated with unintended pregnancies.
Discussion
The Committee reviewed the grounds of the objection made by Green
Cross Healthcare Limited. The Chair conducted a vote on the validity
of the objection; consensus was upheld and the objection by Green
Cross Healthcare Limited was deemed valid. The Committee discussed
the original proposal against the criteria of the terms of reference,
their comments are as follows:
- Patient access
- The Committee discussed whether patient access was ideal.
- The Committee discussed whether there is an unmet need
and whether the initial proposal would address them.
- One member commented that there should be an emphasis
on the unmet need; the proportion of women that aren't seeking
effective contraceptives and are relying on the emergency
contraceptive pill (ECP) or having an abortion to avoid
unintended pregnancy.
- The Committee discussed the proportion of women that
rely on regular use of the ECP or who have terminations
rather than seeking effective contraception such as the
OCP.
- The impact of the proposal on the group of women
not currentlyseeking oral contraception
was discussed. The Committee was concerned that the proposal
appears to be more of a convenience factor for current oral
contraceptive users.
- One member raised the possibility of promoting the use
of the 'Manage my health' portal to gain electronic access
to repeat prescriptions of selected oral contraception.
A member expressed the opinion that the benefit a consumer
would obtain from a pharmacist consultation would be greater
than that associated with receiving a repeat prescription
from an electronic portal.
- One member highlighted a public comment that the same
benefits can be delivered through standing orders.
- The Committee discussed the growing use of oral contraceptives
in a number of cultural groups where contraception appears
to be a topic of taboo. The Committee noted the growing
use of oral contraception in the Pacific Island and Chinese
communities where counselling increased awareness.
- After discussion, the Committee concluded that patient
access was not a barrier to accessing OCPs.
- Accuracy
- The Committee discussed the initiation of treatment
for oral contraceptive naïve patients during the proposed
consultation process by pharmacists with additional competencies.
- Two members were concerned that the training programme
would not be adequate and that oral contraceptive naïve
patients require a comprehensive assessment.
- One member was concerned that while oral contraceptives
are generally safe to use for majority of women there is
a small proportion of women where there is a risk and a
comprehensive assessment by a medical practitioner is required.
- Two members explained that a medical consultation focuses
on the establishment of what sort of contraception is suited
for the patient.
- Two members discussed pharmacists' capabilities to conduct
the proposed consultations.
- The Committee discussed the availability of oral contraceptives
by nurses and student health. One member commented that
nurses do not prescribe for oral contraceptive naïve patients
and that they perform cervical smears when necessary. The
protocol for Student Health is to prescribe a 3 month supply
of an oral contraceptive and to refer the student to her
general practitioner.
- Another member highlighted that pharmacists have an
in depth understanding of pharmacology and would expect
this knowledge to translate to acceptable skills to prescribe
oral contraceptives.
- The Committee discussed the prescribing of oral contraceptives
in the following jurisdictions: California, Europe, and
United Kingdom. The Committee noted that in the United Kingdom,
nurses and pharmacists are able to prescribe oral contraceptives
under certain circumstances but are required to notify the
patient's general practitioner.
- One member commented that a protocol would be a useful
tool to guide the process and also to ensure that patients
with higher risk contraindications do not get lost through
the system.
- One member commented that there is nothing in the submission
that states the protocol is the only tool that guides the
consultation.
- Efficacy
- No concerns.
- Precedent
- The Committee was aware that the emergency contraceptive
pill is classified as a restricted medicine.
- Therapeutic index
- No major concerns.
- Toxicity
- The Committee was not aware of anything new. They were
aware of all adverse reactions as they are well documented.
Safety of oral contraceptives can be established with family
history and asking the right questions.
- Abuse potential
- No concerns.
- Inappropriate use
- A member was concerned if patients with endometriosis
were seeking oral contraceptives for self-treatment without
disclosing their full medical history. They also expressed
concern for patients with undiagnosed endometriosis who
were using the pill, ceased use and presented with symptoms
that would not be recognised as endometriosis till much
later.
- Precautions
- No concerns.
- Communal harm and/or benefit
- Three members commented on the risk of fragmentation
of care in the absence of electronic records and lack of
communication between pharmacy and medical professionals.
- One member made the comment that the current manual
process of pharmacists forwarding on patients information
with patient consent to general practice was not ideal but
had value. The process could be improved with electronic
records.
- In their experience, the Committee discussed the group
of women who do not use effective birth control and are
increasingly relying on ECP and termination. Although there
is no evidence that access in pharmacy will address this,
the proposed options do not present a greater risk of harm.
- The Committee expressed interest in monitoring the proposed
change in classification.
- The Committee noted that the submission lacked detail
about the training programme. There was no detail regarding
who would be responsible for maintaining and enforcing the
provisions under which a pharmacist with additional competencies
could prescribe selected oral contraceptives. The Committee
discussed the requirements of the training programme and
indicated it must be an accredited training programme with
refresher courses.
After the Committee discussed the original proposal submitted
at the 53rd meeting, the Chair took the proposal to vote.
The proposal did not achieve consensus or majority support from
the Committee and the proposal was once again rejected.
The Committee considered that the proposed treatment protocol
did not manage the risks associated with oral contraceptives in
patients being prescribed these medicines for the first time.
Oral contraceptive naïve patients require a comprehensive assessment
and a degree of oversight.
The Committee then discussed whether to consider the alternative
proposal provided by Green Cross Healthcare Limited for this meeting.
The Committee noted that the alternative proposal included in the
submission was within the material released for public consultation
prior to the meeting and the Committee had received submissions
on the proposal from several organisations. The Committee therefore
agreed that it was appropriate to consider the alternate proposal
put forward by Green Cross Healthcare Limited.
The alternative proposal is a collaborative approach between
pharmacists with additional competencies and Family Planning and/or
GPs to limit the provision of oral contraceptives as restricted
medicines only to women who have previously been prescribed an oral
contraceptive.
- The Committee noted that the alternative proposal had partial
support from RANZCOG. The RANZCOG supported the repeat prescribing
of oral contraceptives by pharmacists with additional competencies
to woman who are a previous oral contraceptive user as set out
in scenarios 1-5 in their submission.
- One member commented on the reasoning behind RANZCOG's decision
and wanted to know how they reached this decision. RANZCOG's
decision indicated that a risk-benefit analysis had been completed
and this member wanted this information.
- Several members noted that concerns about fragmentation
of care also applied to the alternative proposal. However, the
alternate proposal's protocol which encourages communication
between pharmacy and medical professionals with regards to obtaining
patients consent for the sharing of patient information, especially
in the absence of electronic records, was seen as an appropriate
risk mitigation tool.
- One member raised the concern that the alternative proposal
did not address the proportion of women that do not present
to general practitioners (unmet need).
- The Committee noted that the alternative proposal did not
have a timeframe on the prescribing of selected oral contraceptives.
- The Committee considered that a pharmacist may prescribe
oral contraceptives within a three-year period from the date
of a previous medical practitioner prescription, providing that
there were mechanisms in place to ensure it was not dispensed
to women for whom it was now contraindicated.
- The Committee expressed concern with regards to the development
of a medical condition in the time since the initial medical
assessment. The Committee concluded that this risk could be
mitigated if the treatment protocol reminded Pharmacists to
ensure that women had not developed medical conditions since
their last medical consultation which would mean the OCP was
now contraindicated. The protocol should require Pharmacists
to seek information on a number of conditions, listed as contraindications
in the product data sheets, including:
- New or worsening headaches
- Changes in patterns of migraine
- New symptoms of cardiovascular disease
- Commenced smoking
- Women younger than 16 years in age
- Recently diagnosed (or close relative) with breast cancer,
heart or kidney problems, epilepsy, hypertension, depression
- Planning to undergo major surgery
- Immobilised
- Pregnant or likely to be pregnant
- Women with newly identified contraindications would then
be referred to their primary healthcare provider for further
assessment and discussion on optimum methods of contraception.
- The Committee discussed the supply of the selected OCPs
as restricted medicines. The Committee indicated that selected
oral contraceptives were to be supplied:
- in a pack approved as a restricted medicine
- with an explanation of possible side effects and encouragement
to seek medical advice as described in the patient information
leaflet and datasheet.
- encourage regular cervical screening and blood pressure
checks etc.
- in no more than a six months' supply
- The Committee considered that a pharmacist may prescribe
oral contraceptives within a three-year period from the date
of a previous medical practitioner prescription, providing that
there were mechanisms in place to ensure it was not dispensed
to women for whom it was now contraindicated.
Recommendation
That the selected oral contraceptives (desogestrel, ethinylestradiol,
norethisterone and levonorgestrel) should be reclassified as restricted
medicines, when sold in the manufacturer's original pack containing
not more than six months' supply by a registered pharmacist who
has successfully completed a training programme (endorsed or accredited
by an organisation that is to be confirmed as stated in the following
recommendation), when indicated for oral contraception in women
who have previously been prescribed an oral contraceptive within
the last 3 years from the date of an original medical practitioner's
prescription.
That Green Cross Healthcare Limited should provide Medsafe
with details of who will be responsible for accrediting the training
programme and maintaining and enforcing the provisions under which
a pharmacist with additional competencies could prescribe selected
oral contraceptives.
That Green Cross Healthcare Limited should update Medsafe
of the changes required to the training and monitoring procedures
to reflect the Committee's recommendations.
That market sales should be collected and analysed to monitor
the success of the scheme in improving access to oral contraceptive
pills. The Committee is interested in being updated on the outcomes
of this recommendation.
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5.2
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Matters arising for information
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5.2.1
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Update to the First Schedule to the Medicines
Regulations 1984
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6
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Submissions for reclassification
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6.1
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Influenza vaccine – extension of influenza
vaccination by pharmacists
(Green Cross Healthcare)
Two representatives of the sponsor observed the discussion but
left the meeting room before a final recommendation was made.
Purpose
This was a company submission to extend the prescription medicine
classification of Influenza vaccine for the treatment and prevention
of influenza to allow for the administration of the vaccine by pharmacists
who have completed an approved course, to children 13 years and
over.
Background
Green Cross Healthcare Limited have made a submission to extend
the classification of Influenza vaccine from
prescription medicine except when administered
to a person 18 years of age or over by a registered pharmacist who
has successfully completed a vaccinator training course approved
by the Ministry of Health and who is complying with the immunisation
standards of the Ministry of Health, to
prescription medicine except when administered
to a person 13 years of age or over by a registered pharmacist who
has successfully completed a vaccinator training course approved
by the Ministry of Health and who is complying with the immunisation
standards of the Ministry of Health.
The submission documentation provided by Green Cross Heathcare
Limited focused on the following points:
- Internationally growing acceptance and trend
- Convenience of getting family vaccinated without an appointment
- Vaccinating young teenagers reduces the spread of influenza
and the cost and time of a parent having to take time off work
- A summary of benefits of the proposed reclassification with
regards to the terms of reference.
The influenza vaccine was discussed at the 47thand
the 50th meeting. It was also discussed at the 43rd
meeting agenda item 5.3 Vaccines, and 49th meeting agenda
item 5.3 Further data to support the reclassification of diphtheria,
tetanus and pertussis (acellular, component) vaccine, and 5.6 Training
for pharmacist vaccinators.
Currently, the influenza vaccine is classified as a prescription
medicine except when administered to a person 18 years of age or
older by a registered pharmacist who has successfully completed
a vaccinator course approved by the Ministry of Health.
Comments
Two comments were received supporting the proposed extension
of the prescription medicine classification to allow the administration
of the vaccine to children 13 years of age and over by a pharmacist
that has completed a vaccinator course approved by the Ministry
of Health.
Discussion
The Committee assessed the proposal against the criteria under
the Terms of Reference.
- Patient Access
- The Committee discussed the impact of the proposal in
increasing access of the influenza vaccine to include adolescents.
Adolescents have been identified as the hardest age group
to vaccinate and it would be advantageous to target them
as they are main transmitters due to a longer period of
viral shedding.
- The proposal would increase the number of influenza
vaccinators during an outbreak or pandemic.
- The proposal would be in line with WHO guidance and
government policy.
- One member queried why the age of 13 years was chosen
and suggested enabling vaccination of even younger children
would be appropriate.
- Accuracy
- No concerns.
- Efficacy
- The Committee were aware that the influenza vaccine
is reasonably efficacious.
- Precedent
- Therapeutic Index
- No concerns.
- Toxicity
- One member was concerned of the risks of multiple vaccines
given to the same person.
- Abuse Potential
- Nothing significant.
- Inappropriate Use
- No concerns
- Precautions
- One member raised awareness to allergic reactions.
- Communal harm and/or benefit
- One member acknowledged good communal benefit.
Recommendation
That the classification of the influenza vaccine should be extended
to allow pharmacists with additional competencies, those that have
completed a vaccinator course approved by the Ministry of Health,
to administer the vaccine to children aged 13 years of age or over.
The Committee encouraged Green Cross Healthcare Limited to
make another submission to extend the administration of influenza
vaccine by a specially trained pharmacist who has completed a vaccinator
course that is approved by the Ministry of Health to younger aged
children.
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7
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New medicines for classification
The following new chemical entities were submitted to the Committee
for classification.
- Grazoprevir and Elbasvir
Merck Sharp and Dohme (MSD) are proposing to seek approval for
their new once-daily, single-tablet combination therapy for
the treatment of adult patients infected with chronic hepatitis
C virus (HCV) genotypes (GT) 1, 4 or 6.1.
The tablet is a combination of grazoprevir (NS3/4A protease
inhibitor) and elbasvir (NS5A inhibitor).
Both actives are New Chemical Entities and require classification.
Grazoprevir and Elbasvir are not classified in Australia.
Recommendation
That grazoprevir and elbasvir should be classified as prescription
medicines.
- Nivolumab
Nivolumab is a fully human anti-PD-1 monoclonal antibody which
is a highly specific programmed death-1 (PD-1) immune checkpoint
inhibitor and has been studied in treatment of melanoma, squamous
and non-squamous non small cell lung cancer (SQ NSCLC and NS
NSCLC), renal cell carcinoma (RCC) and other tumor types.
Medsafe has not yet received any products containing nivolumab.
However, Medsafe does expect an application for Opdivo which
contains the active ingredient nivolumub, and expects the indications
to be as follows:
Nivolumab is indicated for the treatment of unresectable or
metastatic melanoma as a single agent in patients with disease
progression following ipilimumab and, if BRAF V600 mutation
positive, a BRAF inhibitor, or in combination with ipilimumab
in patients with wild-type melanoma. Nivolumab is also indicated
for the treatment of metastatic non-small cell lung cancer in
patients with progression on or after platinum-based chemotherapy.
Nivolumab is not classified in Australia.
Recommendation
That nivolumab should be classified as a prescription medicine.
- Lesinurad
Lesinurad is a selective uric reabsorption inhibitor (SURI)
of the urate transporters, URAT1 and OAT4. The urate transporter
URAT1 is responsible for most of the uric acid reabsorption
in the kidneys.
Lesinurad is indicated for the treatment of hyperuricemia associated
with gout, in combination with a xanthine oxidase inhibitor.
Lesinurad is not classified in Australia.
Recommendation
That lesinurad should be classified as a prescription medicine.
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7.1
|
Section 29 new medicines for classification
The following section 29 new chemical entities were submitted
to the Committee for classification.
- Alectinib
Alectinib is an investigational medicine by Roche. Alectinib
is an oral investigational anaplastic lymphoma kinase inhibitor
(ALKi), indicated for patients with advanced ALK-positive (ALK+)
non-small cell lung cancer (NSCLC) whose disease had progressed
following treatment with crizotinib. Submitted to FDA for approval
in June 2013 and supplied in Japan from September 2014 (http://www.roche.com/media/store/releases/med-cor-2015-05-14.htm)
Currently undergoing phase 3 studies (https://clinicaltrials.gov/ct2/show/NCT02271139)
Recommendation
That alectinib should be classified as a prescription medicine.
- Amifampridine
Amifampridine is marketed in the EU by BioMarin Pharmaceutical
under the trade name Firdapse. It is designated as an orphan
drug in the EU and it is used to treat the symptoms of Lambert-Eaton
myasthenic syndrome (LEMS) in adults.
Amifampridine is a potassium channel blocker, which prevents
charged potassium particles from leaving the nerve cells. It
is designated as a prescription medicine in Europe (http://www.drugs.com/uk/firdapse.html)
Recommendation
That amifampridine should be classified as a prescription
medicine.
- Artesunate
Artesunate is marketed as Artsun by Guilin Pharmaceutical Co.
Ltd. It has been approved by the WHO via the pre-qualification
programme for the treatment of severe falciparum malaria.
http://apps.who.int/prequal/whopar/whoparproducts/MA051part3v1.pdf
http://apps.who.int/prequal/
Artesun solution for injection has been imported regularly into
New Zealand during the last 2 years.
The WHO recommends the medicine is administered by qualified
medical personnel which is equivalent to a prescription medicine
classification in New Zealand.
Recommendation
That artesunate should be classified as a prescription medicine.
- Benzbromarone
Benzbromarone, a potent uricosuric drug, was introduced in the
1970s and was viewed as having few associated serious adverse
reactions. It was registered in about 20 countries throughout
Asia, South America and Europe. In 2003, the drug was withdrawn
by Sanofi-Synthélabo, after reports of serious hepatotoxicity.
Benzbromarone is currently used for treating selected cases
of gout particularly for patients in whom allopurinol produces
insufficient response or toxicity. (http://www.ncbi.nlm.nih.gov/pubmed/18636784)
Benzbromarone is regularly supplied in New Zealand (http://www.rheumatology.org.nz/downloads/BENZBROMARONE-patient-Nov-2014.pdf).
Recommendation
That benzbromarone should be classified as a prescription
medicine.
- Defibrotide
In Europe defibrotide is approved as Defitelio by Gentium SpA.
It is is indicated for the treatment of severe hepatic veno-occlusive
disease (VOD) also known as sinusoidal obstruction syndrome
(SOS) in haematopoietic stem-cell transplantation (HSCT) therapy
in adults and in adolescents, children and infants over 1 month
of age .
It is a prescription medicine in Europe.
Recommendation
That defibrotide should be classified as a prescription
medicine.
- Felbamate
Felbamate is an anticonvulsant. It works by controlling nerve
impulses in the brain, which prevents or reduces some types
of seizures.
An application to distribute a medicine containing felbamate
(Taloxa) was received by Medsafe in 1993. After consideration
by the MAAC and several requests for information, the application
was withdrawn in 2000. The medicine was proposed as a prescription
medicine but was not formally classified.
Felbamate has a significant risk profile which means it should
only be prescribed (https://www.nlm.nih.gov/medlineplus/druginfo/meds/a606011.html).
Recommendation
That felbamate should be classified as a prescription medicine.
- Flunarizine
Flunarizine is a calcium channel blocker, prescribed for migraine
occlusive peripheral vascular disease, vertigo of central and
peripheral origin and as an adjuvant in the therapy of epilepsy.
It is classified internationally as a prescription medicine.
(http://www.medindia.net/doctors/drug_information/flunarizine.htm)
Recommendation
That flunarizine should be classified as a prescription
medicine.
- Idebenone
Idebenone, a synthetic short-chain benzoquinone and a cofactor
for the enzyme NAD(P)H: quinone oxidoreductase (NQO1). It was
first developed by Takeda Pharmaceuticals for use in Alzheimer's
disease but may not have been commercialised. It is currently
being studied by Santhera Pharmaceuticals for use in a number
of orphan mitochondrial and neuromuscular indications.
The reasons for import under section 29 in New Zealand are unknown.
There is also some evidence that idebenone is promoted internationally
as a skin rejuvenating product
(http://www.prioriskincare.com/idebenone-about/)
As there is very little information available about the risk
profile of idebenone, it is prudent to consider a prescription
classification.
Recommendation
That idebenone should be classified as a prescription medicine.
- Nitazoxanide
Nitazoxanide is an antiprotozoal agent used to treat diarrhoea
in children and adults caused by Cryptosporidium or Giardia.
The brand imported is Alinia, an FDA approved medicine
(http://www.alinia.com/)
and distributed in the USA as a prescription medicine.
It is covered by the class entry 'antibiotic substances' but
enquiries from one of the current importers suggests that they
consider it to be unscheduled. For convenience a separate entry
should be added for nitazoxanide given the regular imports.
Recommendation
That nitazoxanide should be classified as a prescription
medicine.
- Pentostatin
Pentostatin is an antibiotic that is only used in chemotherapy
to treat hairy cell leukemia. It is marketed internationally
by Hospira under the trade name 'Nipent'. In Europe it is a
prescription only medicine
(https://www.medicines.org.uk/emc/medicine/20604).
This substance is included in the class entry 'antibiotic substances'
but given its specialist use in chemotherapy this may not be
immediately obvious to stakeholders (e.g. NZ Customs). For convenience
a separate entry should be added for pentostatin given the regular
imports.
Recommendation
That pentostatin should be classified as prescription medicine.
- Picibanil
Picibanil is a lyophilised mixture of group A Streptococcus
pyogenes with antineoplastic activity. It has been approved
by in Japan since 1995 for the treatment of lymphangiomas.
A short internet search failed to identify commercialisation
of this medicine outside of Japan. Its uses appear to be mainly
experimental
(http://www.ncbi.nlm.nih.gov/pubmed/19029851)
The risk profile of this medicine is unknown and hence should
be classified as a prescription medicine.
Recommendation
That picibanil should be classified as a prescription medicine.
- Rufinamide
Rufinamide is an anticonvulsant used with other medication(s)
to control seizures in people who have Lennox-Gastaut syndrome.
The brand imported to New Zealand is Inovelon. This brand is
approved in Europe as a prescription medicine and distributed
by Eisai.
(http://www.medicines.org.uk/emc/medicine/20165/SPC/)
Recommendation
That rufinamide should be classified as a prescription medicine.
- Sargarmostim
Sargramostim is marketed in the US by Sanofi under the trade
name Leukine. It has been an FDA approved medicine since 1991.
Sargramostim is a recombinant granulocyte macrophage colony-stimulating
factor (GM-CSF).
Leukine is used to help increase the number and function of
white blood cells after bone marrow transplantation, in cases
of bone marrow transplantation failure or engraftment delay,
before and after peripheral blood stem cell transplantation,
and following induction chemotherapy in older patients with
acute myelogenous leukemia
(http://www.leukine.com/patient-index)
It is regarded as a prescription medicine in the USA.
Recommendation
That sargarmostim should be classified as a prescription
medicine.
- Stiripentol
Stiripentol is approved as an orphan drug in Europe under the
brand name Diacomit.
According to the company website Diacomit is an original anti-epileptic
drug resulting from BIOCODEX's research programme. Its chemical
structure is not related to any other known anticonvulsant and
its active substance is stiripentol.
DIACOMIT® was designated as an orphan drug by the European Medicines
Agency (EMA) on December 5th 2001 for its use in Severe Myoclonic
Epilepsy in Infancy (SMEI).
(http://www.diacomit.eu/).
Diacomit is currently approved for use in Europe as a prescription
medicine
(http://www.ema.europa.eu/ema/index.jsp?curl=pages/medicines/human/medicines/000664/human_med_000742.jsp&mid=WC0b01ac058001d124)
Recommendation
That stiripentol should be classified as a prescription
medicine.
- Streptozocin
Streptozocin is an alkylating agent used to treat pancreatic
cancers
(http://www.drugs.com/cdi/streptozocin.html)
It is marketed internationally as a prescription medicine.
Recommendation
That streptozocin should be classified as a prescription
medicine.
- Tizanidine
The product, Sirdalud, containing the active ingredient tizanidine
is imported into New Zealand. Tizanidine is used to treat spasticity
by temporarily relaxing muscle tone. It is regulated internationally
as a prescription medicine.
Recommendation
That tizanidine should be classified as a prescription medicine.
- Trientine hydrochloride
The product, Trientine, containing the active ingredient trientine
hydrochloride is imported into New Zealand by Univar.
Trientine dihydrochloride, is a chelating agent indicated for
the treatment of Wilson Disease in patients who are intolerant
of D-Penicillamine therapy or have clinical features indication
potential intolerance.
It has been approved in Europe since 1985
(http://www.trientine.com/sites/www.trientine.com/uploads/files/Trientine_SPC_Jan_2014.pdf
). It has been designated as an orphan drug by the EMA in 2003.
Trientine is a prescription medicine internationally.
Recommendation
That trientine hydrochloride should be classified as a prescription
medicine.
|
7.2
|
1,3-dimethylamylamine (DMAA) – proposed
classification as a prescription medicine (Medsafe)
This is a Medsafe submission that requests classification of
1,3-dimehtylamyamine (DMAA) as a prescription medicine; except when
present as an unmodified, naturally occurring substance.
DMAA is a straight chain aliphatic amine with sympathomimetic
physiological effects. DMAA was first synthesised and patented in
1944 by pharmaceutical company Eli Lilly. It was originally patented
as a nasal decongestant.
DMAA is currently commonly sold in dietary supplements (usually
for weight loss by appetite suppression), pre-workout supplements
(due to its stimulant properties) and in a range of over-the-counter
party pills. DMAA is not found in any food stuff that is considered
a normal part of the human diet. Therefore, it was Medsafe’s view
prior to 2008 that DMAA did not meet the definition of a dietary
supplement and should not be regulated under the Dietary Supplement
Regulations 1985.
One comment was received supporting the proposed reclassification
of DMAA to prescription medicine.
Recommendation
That 1,3-dimethylamylamine (DMAA) should be classified as
a prescription medicine; except when present as an unmodified, naturally
occurring substance.
|
7.3
|
Sunifiram (1-benzoyl-4-propanolypiperazine)
– proposed classification as a prescription medicine (Medsafe)
This is a Medsafe submission that requests classification of
sunifiram, a racetam-like substance, as a prescription medicine.
Background
At the 53rd meeting held on 5 May 2015, it was agreed
to individually classify racetam and racetam-like structures as
prescription medicines as there was no suitable class entry that
would describe all concerned structures.
Sunifiram (1-benzoyl-4-propanoylpiperazine) is described as a
racetam-like compound. It is a piperazine derived synthetic chemical.
Sunifiram does not contain the common 2-pyrolidone nucleus, but
is similar to scheduled compound molracetam in that it contains
a benzoyl piperazine core. Sunifiram is structurally similar to
1-benzylpiperazine (BZP), but is not captured under the Misuse of
Drugs Act 1975.
Sunifiram (1-benzoyl-4 propanoylpiperazine)
An internet search of sunifiram leads to articles1, 2
that describe this compound as having nootropic effects in animal
studies with significantly higher potency than piracetam.
Recommendation
That sunifiram should be classified as a prescription medicine.
|
8
|
Harmonisation of the New Zealand and
Australian schedules
|
8.1
|
New chemical entities which are not yet
classified in New Zealand
|
|
- Asunaprevir
Asunaprevir is an inhibitor of the NS3 serine protease of HCV,
and subsequent viral RNA replication. Asunaprevir competitively
inhibits the binding of substrate to NS3/4A protease complex,
binding directly and reversibly to the protease, with Ki 0.24
to 1.0 nM, depending on the genotype strain employed.
Asunaprevir is indicated for the treatment of chronic hepatitis
C virus (HCV) infection in adults with compensated liver disease
(including cirrhosis) in combination with:
- daclatasvir, an NS5A replication complex inhibitor,
for patients with HCV genotype 1b infection.
- daclatasvir, peginterferon alfa, and ribavirin for patients
with HCV genotype 1 or 4 infection.
In March 2015, the delegate made a final decision to include
asunaprevir in Schedule 4 (prescription medicine), with an implementation
date of 1 June 2015 for the following reasons:
- It is a new chemical entity with no clinical and marketing
experience in Australia.
- asunaprevir is indicated for the treatment of chronic
hepatitis C virus infection in adults with compensated liver
disease (including cirrhosis) in combination with:
- daclatasvir, an NS5A replication complex inhibitor,
for patients with HCV genotype 1b.
- daclatasvir, peginterferon alfa, and ribavirin for
patients with HCV genotype 1 or 4 infection.
- asunaprevir may cause liver toxicity. As asunaprevir
is to be used in combination with other medicines, there
could be adverse events caused by the concomitant medicines.
Drug-drug interactions can occur when asunaprevir is
co-administered with other medicines.
- Pregnancy category B1 is acceptable for asunaprevir.
When used in combination with daclatasvir (B3), or daclatasvir
and peginterferon alfa and ribavirin (category X), the most
restrictive category is applicable.
- asunaprevir should be prescribed by medical professionals
who are familiar with the management of chronic liver diseases.
The patients need to be instructed to follow the recommended
dosing regimens.
The Committee considered harmonising with the above classification.
Recommendation
That asunaprevir should be classified as a prescription
medicine.
- Daclatasvir
Daclatasvir is an inhibitor of the hepatitis C virus nonstructural
protein 5a (NS5A) replication complex. NS5A is a multifunctional
protein with key functions in both HCV replication and modulation
of cellular signalling pathways.
Daclatasvir is indicated, when in combination with other agents,
for the treatment of chronic hepatitis C virus (HCV) infection
in adults with compensated liver disease (including cirrhosis).
In March 2015, the delegate made a final decision to include
daclatasvir in Schedule 4 (prescription medicine), with an implementation
date of 1 June 2015, for the following reasons:
- It is a new chemical entity with no clinical and marketing
experience in Australia.
- Daclatasvir is indicated, in combination with other
medicinal products, for the treatment of chronic hepatitis
C virus (HCV) infection in adults with compensated liver
disease (including cirrhosis).
- Daclatasvir is to be used for a medical condition (chronic
hepatitis C virus infection) that requires careful diagnosis
and management by medical professionals. Drug-drug interactions
can occur when daclatasvir is coadministered with other
medicines.
- Pregnancy Category B3 is proposed.
- There are side effects associated with the use of Daclatasvir,
such as diarrhoea, nausea and headache, hypersensitivity
reactions, drug-induced liver toxicity, etc.
- Daclatasvir should be prescribed by medical professionals
who are familiar with the management of chronic liver diseases.
The patients need to be instructed to follow the dosing
regimens.
The Committee considered harmonising with the above classification.
Recommendation
That daclatasvir should be classified as a prescription
medicine.
- Netupitant
Netupitant is a neurokinin1 receptor antagonist.
Netupitant is indicated in adult patients, in combination with
palonosetron (as part of a fixed dose combination product),
for the:
- Prevention of acute and delayed nausea and vomiting
associated with initial and repeat courses of highly emetogenic
cancer chemotherapy; and
- Prevention of acute and delayed nausea and vomiting
associated with initial and repeat courses of moderately
emetogenic cancer chemotherapy.
In March 2015, the delegate made a final decision to include
netupitant in Schedule 4 (prescription medicine), with an implementation
date of 1 October 2015, for the following reasons:
- It is a new chemical entity with no marketing experience
in Australia.
- The benefits are considered to outweigh the risks at
a population level.
- It is also noted that netupitant is currently proposed
for use in a fixed dose combination with palonosetron, and
benefit / risk has been assessed in this context.
- The purpose and extent of use is reflected in the indication,
i.e. use in adults for:
- Prevention of acute and delayed nausea and vomiting
associated with initial and repeat courses of highly
emetogenic cancer chemotherapy; and
- Prevention of acute and delayed nausea and vomiting
associated with initial and repeat courses of moderately
emetogenic cancer chemotherapy.
- The potential for abuse of netupitant is unlikely.
The Committee considered harmonising with the above classification.
Recommendation
That netupitant should be classified as a prescription medicine.
- Cholic acid
Cholic acid is a bile acid and used in patients with bile acid
synthesis disorders due to single enzyme defects, and for patients
with peroxisomal disorders.
Cholic acid is indicated for the treatment of inborn errors
of bile acid synthesis responsive to treatment with cholic acid.
In March 2015, the delegate made a final decision to include
cholic acid
in Schedule 4 (prescription medicine), with an implementation
date of 1 October 2015, for the following reasons:
- It is a new chemical entity with no [clinical/marketing]
experience in Australia.
- This cholic acid is a synthetic version of a naturally
occurring bile acid. It has a relatively good safety profile.
- Cholic acid is intended to be used in the management
of certain inborn errors of bile acid synthesis that, if
untreated, result in liver failure. Its use will be in the
context of long-term management of patients with a serious
medical condition that requires ongoing assessment.
The Committee considered harmonising with the above classification.
Recommendation
That cholic acid should be classified as a prescription
medicine.
- Levomilnacipran
Levomilnacipran is a selective serotonin and noradrenaline reuptake
inhibitor (SNRI). It is reported to inhibit both the norepinephrine
(NE) and 5hydroxytryptamine (5HT, serotonin) reuptake with an
approximate two fold more potent inhibition of NE reuptake than
5HT reuptake transporters. It is the more active enantiomer
of the racemate milnacipran.
Levomilnacipran is indicated for the treatment of Major Depressive
Disorder (MDD) in adults.
In March 2015, the delegate made a final decision to include
levomilnacipran in Schedule 4 (prescription medicine), with
an implementation date of 1 October 2015, for the following
reasons:
- It is a new chemical entity with no [clinical/marketing]
experience in Australia.
- This active may cause increases in heart rate and blood
pressure as well as nausea, vomiting and dizziness. Less
frequent adverse effects may also occur that may require
assessment and management by a medical doctor.
- It is intended for the treatment of depression, a medical
condition that requires management by a healthcare professional.
- It has side effects that may require management by a
doctor.
The Committee considered harmonising with the above classification.
Recommendation
That levomilnacipran should be classified as a prescription
medicine.
- Naloxegol
Naloxegol is a PEGylated derivative of the mu-opioid receptor
antagonist naloxone.
Naloxegol is indicated for the treatment of opioid-induced constipation
(OIC).
In March 2015, the delegate made a final decision to include
Naloxegol in Schedule 4 (prescription medicine), with an implementation
date of 1 October 2015, for the following reasons:
- It is a new chemical entity with no clinical/marketing
experience in Australia.
- This active can cross the blood brain barrier in certain
medical conditions and interacts with many other medications
via CYP metabolism pathways
- Naloxegol is intended for the treatment of opioid induced
constipation. It is a new chemical entity.
- While naloxegol when used as intended has a good safety
profile it can interfere with the action of other medicines
and must not be given where there is a possibility of bowel
obstruction. A medical assessment should be performed prior
to its initial use and where there is significant abdominal
pain.
The Committee considered harmonising with the above classification.
Recommendation
That naloxegol should be classified as a prescription medicine.
- Milnacipran
Milnacipran is a balanced, specific, dual reuptake inhibitor
of noradrenaline (NA) and serotonin (5hydroxytryptamine [5 HT]),
inhibiting noradrenaline uptake with greater potency than serotonin.
Milnacipran is indicated for the treatment of fibromyalgia.
In March 2015, the delegate made a final decision to include
milnacipran in Schedule 4 (prescription medicine), with an implementation
date of 1 October 2015, for the following reasons:
- It is a new chemical entity.
- This active may cause increases in heart rate and blood
pressure as well as nausea, vomiting and dizziness. Less
frequent adverse effects may also occur that may require
assessment and management by a medical doctor. It is intended
for the treatment of depression, a medical condition that
requires management by a healthcare professional.
- It is intended for the treatment of a chronic pain condition
that requires management by a healthcare professional.
- It has side effects that may require management by a
doctor
The Committee considered harmonising with the above classification.
Recommendation
That milnacipran should be classified as a prescription
medicine.
- Ponatinib
Ponatinib is the active substance in an anticancer medicine.
It is used to treat adults with the following types of leukaemia:
- chronic myeloid leukaemia (CML);
- acute lymphoblastic leukaemia (ALL) in patients who
are 'Philadelphia' chromosome positive (Ph+).
Ponatinib is a BCRABL tyrosine kinase inhibitor that is used
for the treatment of chronic, accelerated, or blast phase chronic
myeloid leukaemia, or Philadelphia chromosome-positive acute
lymphoblastic leukaemia, that is resistant to, or in patients
who are intolerant of, prior tyrosine kinase inhibitor therapy.
Ponatinib is used in patients who do not respond to dasatinib
or nilotinib (other medicines of the same class); or who cannot
tolerate dasatinib or nilotinib and for whom subsequent treatment
with imatinib (a third such medicine) is not considered appropriate.
It is also used in patients who have a genetic mutation called
'T315I mutation' which makes them resistant to treatment with
imatinib, dasatinib or nilotinib.
In March 2015, the ACMS recommended that Ponatinib not be listed
in Appendix D, Item 1, for the following reasons:
- Benefits: Treatment of chronic myeloid leukaemia and
Philadelphia chromosome positive acute lymphoblastic leukaemia.
- Risks: Life threatening blood clots, severe occlusion
of blood vessels, cardiac failure, pancreatitis and hepatotoxicity.
Possible fetotoxicity.
- Purposes as above. Use is limited by the incidence of
the diseases, adverse effects and cost.
- Attracts a FDA "black box" warning and a "risk evaluation
and mitigation strategy" in view of the above risks.
- Oral tablets.
- The specialised nature of this drug is such that only
haematologists are likely to use it.
The Committee considered harmonising with the above classification.
Recommendation
That Ponatinib should be classified as a prescription medicine.
- Ulipristal
Ulipristal is an orally active synthetic selective progesterone
receptor modulator that acts via high affinity binding to the
human progesterone receptor. When used for emergency contraception
the mechanism of action is inhibition or delay of ovulation
via suppression of the luteinising hormone (LH) surge.
Ulipristal is indicated for emergency contraception within 120
hours (5 days) of unprotected sexual intercourse or contraceptive
failure.
In May 2015, the delegate made a final decision to include ulipristal
in Schedule 4 (prescription medicine), with an implementation
date of 1 June 2015, for the following reason:
- It is a new chemical entity with no clinical or marketing
experience in Australia.
The Committee considered harmonising with the above classification.
The Committee noted that the safety of ulipristal is unknown.
Recommendation
That ulipristal should be classified as a prescription only
medicine.
The Committee encourage healthcare professionals to put forward
a submission for reclassification once there is useful information
suggesting it should be reclassified.
|
8.2
|
Decisions by the Secretary to the Department
of Health and Aging in Australia (or the Secretary's Delegate)
The Committee noted that the Delegate had also made the following
amendments to the Standard for the Uniform Scheduling of Medicines
and Poisons:
|
8.2.1
|
Decisions by the Delegate – November
2014
|
|
- Performance and image enhancing drugs
In March 2015, the Delegate made a decision to include the performance
and image enhancing drugs listed below to schedule 4 (prescription
medicine), with an implementation date of 1 June 2015, for the
following reasons:
- There is limited information on the risks and benefits
of the substances as there has been minimal use under appropriate
medical supervision. Risks from misuse are considered to
be similar to those associated with the misuse of growth
hormone.
- There is increasing evidence that the PIEDs are being
advertised to attract a number of user markets including:
- Strength enhancement/muscle enhancement
- Anti-ageing
- Fat loss
- Injury rehabilitation
- Libido enhancement
- Growth hormone deficiency
- There is the potential for the side effects associated
with use of growth hormone when growth hormone secretagogues
are used, particularly if the use is not under medical supervision.
There are limited data on the safety of intravenous and
subcutaneous use of AOD9604 and on the long-term oral use
of AOD9604 in doses in excess of those used in clinical
trials.
- Many of the substances are injected. This carries additional
risks compared with other routes of administration. Injections
need to be administered by persons who use appropriate infection
control procedures.
- There is misuse of the substances in sport and by body
builders.
- There is evidence of involvement of organised crime
in supply of the substances. The substances are offered
for sale via the internet. Many of the substances are promoted
as safe alternatives to traditional performance enhancing
substances such as the anabolic steroids. Suppliers are
making unproven assertions about the efficacy and safety
of the substances.
Performance and image enhancing drugs that were added to schedule
4 include:
- AOD-9604 (CAS No. 221231-10-3)
- CJC-1295 (CAS No. 863288-34-0)
- Pralmorelin ((Growth Hormone Releasing Peptide-2) (GHRP-2))
- Growth Hormone Releasing Peptide-6 (GHRP-6)
- Growth Hormone Releasing Hormones *(GHRHs)
- Growth Hormone Releasing Peptides *(GHRPs)
- Growth Hormone Secretagogues *(GHSs)
- Hexarelin
- Ipamorelin
The Committee considered harmonising with the above classification.
At the 49th meeting held on the 17 June 2013, the
Committee recommended to individually add growth hormone secretagogues
to the schedule. At that meeting hexarelin and ipamorelin were
recommended to be scheduled as prescription medicines.
Recommendation
That the following performance and image enhancing drugs
should be classified as prescription medicines:
- AOD-9604 (CAS No. 221231-10-3)
- CJC-1295 (CAS No. 863288-34-0)
- Pralmorelin ((Growth Hormone Releasing Peptide-2) (GHRP-2))
- Growth Hormone Releasing Peptide-6 (GHRP-6)
- Growth Hormone Releasing Hormones *(GHRHs)
- Growth Hormone Releasing Peptides *(GHRPs)
- Growth Hormone Secretagogues *(GHSs)
That new performance and image enhancement drugs should
be classified by their INN name.
- Benzydamine
In February 2015, the ACMS recommended that benzydamine be exempt
from Schedule 2 (pharmacy medicine) in preparations for topical
use containing 3 mg or less of benzydamine in divided oral preparations
and 3 mg/mL (0.3%) or less in undivided oral preparations in
a pack containing 50 mL or less, with an implementation date
of 1 June 2015.
The ACMS also recommended that the TGA should consider whether
the Required Advisory Statements for Medicine Labels
(RASML) should include any requirements for benzydamine.
The reasons for the recommendation comprised the following:
- Minimal risk of masking a condition with short-term
use. Risk of substance is such that unscheduled status is
acceptable and there is a potential benefit in wider access.
- Surgery and radiation therapy are managed interventions
and under clinical supervision.
- Established safety profile of benzydamine in preparations
for topical oral use.
- Limited potential for abuse/misuse.
The Committee considered harmonising with the above classification.
Recommendation
That benzydamine for topical and external use should be
classified as general sale medicines.
- Pantoprazole
In February 2015, the ACMS recommended that a new entry in Schedule
2 (pharmacy medicine) for pantoprazole when supplied in oral
preparations containing 20 mg or less of pantoprazole per dosage
unit for the relief of heartburn and other symptoms of gastro-oesophageal
reflux disease, in packs containing not more than 7 days of
supply, with an implementation date of 1 June 2015.
The reasons for the recommendation comprised the following:
- Short term use of pantoprazole for the treatment of
heartburn and other symptoms of gastro-oesophageal reflux
disease is likely to be safe and effective.
- Heartburn and other symptoms of gastro-oesophageal reflux
disease are common. Other agents for the same indication
are available as Schedule 2 medicines or are exempt from
scheduling.
- The proposed labelling and provision of Consumer Medicine
Information would help ensure appropriate use of the product.
- Pantoprazole may be more effective in treatment of gastro-oesophageal
reflux disease than ranitidine which is currently available
as an unscheduled medicine in a 7 day pack and as a Schedule
2 medicine in a 14 day pack.
The Committee considered harmonising with the above classification.
Recommendation
That pantoprazole should remain classified as a pharmacy
only medicine in divided solid dosage forms for oral use containing
20 milligrams or less with a maximum daily dose of 20 milligrams
for the short-term symptomatic relief of gastric reflux-like
symptoms in sufferers aged 18 years and over when sold in the
manufacturer's original pack containing not more than 28 dosage
units.
- Cyclizine
In February 2015, the ACMS recommended that the Schedule 3 (pharmacist
only medicine) entry for cyclizine be amended to specify divided
preparations with a pack size limit of six dosage units, with
an implementation date of 1 June 2015.
The ACMS recommended an implementation date of 1 June 2015.
The reasons for the recommendation comprised the following:
- A maximum pack size of six dosage units is proposed
for cyclizine in Schedule 3, due to the potential for abuse
(and the recommended dosage and short-term duration of use).
A six tablet pack is sufficient for the agreed dose for
cyclizine HCl 50 mg tablets and the short term treatment
of motion sickness. Inclusion of a pack size limit is consistent
with requirements for pack size limits in the SUSMP for
other OTC antihistamines for use for motion sickness, and
in ARGOM for other OTC antihistamine products with abuse
potential (Schedule 3 antihistamines indicated for use in
insomnia). All these products are intended for short term
use only.
- There are currently no registered Schedule 3 cyclizine
preparations. The only cyclizine product currently on the
ARTG is a Schedule 4 injection (for prevention of nausea
and vomiting, post-operatively).
- Potential for adverse effects as a result of accumulation
of cyclizine on repeated dosing (due to long half-life).
- Cyclizine in oral preparations is currently Schedule
3 (rather than Schedule 2, as for other antihistamines with
antiemetic indications) due to its abuse potential. No history
of abuse is noted in Australia (no oral cyclizine products
are registered), but there have been reports of abuse of
OTC cyclizine products by opiate users in New Zealand (tablets
are dissolved in water and injected, usually with methadone),
and reports of abuse of cyclizine by methadone users in
the UK.
- The Schedule 3 entry should specify divided dose cyclizine
preparations (for oral use). This would result in oral liquids
being rescheduled to Schedule 4 – this is appropriate, as
liquid cyclizine preparations present a greater risk of
abuse than solid dose preparations, it would not affect
any current products, and TGA has not considered any oral
cyclizine product for use in children under 12 years.
The Committee considered harmonising with the above classification.
Recommendation
That the restricted medicine entry of cyclizine should be
amended to specify divided preparations sold in the manufacturer's
original pack containing not more than with a pack size limit
of six dosage units for oral use other than in medicines used
for the treatment of anxiety or insomnia; for oral use for the
treatment of anxiety or insomnia.
- Cannabidiol
In March 2015, the ACMS recommended that cannabidiol, including
extracts of Cannabis sativa, and including preparations of up
to 2% of cannabinoids, including cannabidivarin (CBDV), for
therapeutic use, be included in Schedule 4 (prescription medicine),
with an implementation date of 1 June 2015.
The reasons for the recommendation comprised the following:
- The condition that cannabidiol treats (the therapeutic
use) requires diagnosis, management and monitoring under
an appropriate medical practitioner.
- Cannabidiol has a safety profile which is consistent
with a Schedule 4 listing.
- There is low risk of misuse or abuse as cannabidiol
does not possess psychoactive properties.
The Committee considered harmonising with the above classification.
Recommendation
That cannabidiol should be referred to the Expert Committee
on Drugs as cannabidiol is classified as a class C1 controlled
drug under the Misuse of Drugs Act 1975.
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8.2.2
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Decisions by the Delegate – March 2014
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- Hydrocortisone
In March 2015, the ACMS recommended that the Schedule 3 (pharmacist
only medicine) entry for hydrocortisone be amended to allow
for 1 per cent or less of hydrocortisone when compounded with
aciclovir 5% w/w or less in primary packs of not more than 2
g for dermal use in adults and adolescents (12 years of age
and older) with an implementation date of 1 October 2015.
The reasons for the recommendation comprised the following:
- Both hydrocortisone and aciclovir at the proposed topical
concentrations have been individually available at Schedule
3 or exempt from scheduling for many years without any significant
public health concerns. Data indicate a risk:benefit ratio
consistent with a Schedule 3 listing for combination preparations
for topical treatment of herpes labialis.
- Early access for consumers to this combination product
from a pharmacist for recurrent cold sores is likely to
be beneficial in reducing progression of symptoms and safe.
Inclusion in Schedule 3 will mean that the product is accessed
in consultation with a pharmacist for advice, education
and checking appropriate use.
- Herpes labialis can be identified by the consumer. Topical
aciclovir has been exempt from scheduling for over a decade
without signals indicating significant risk at this scheduling
level. Mandatory pharmacist assessment at the time of sale
will reduce risk where hydrocortisone is combined with aciclovir
for the same indication and ensures the patient will have
sufficient information about the recommended duration of
use.
- Toxicity is minimal at the proposed strength and duration
of use.
- Both ingredients have been available without prescription
(at the same strengths) for more than 10 years as dermal
preparations with good safety profiles and large consumer
experience. It is likely that risks would be similarly low
in the combination product.
- Risks are minimised by the small pack size (2 g tube)
and dermal application.
- Combination aciclovir 5% and hydrocortisone 1% dermal
cream in packs of 2 g will be used for same indication and
same route of administration, dose and timing (frequency,
duration) as aciclovir 5% cream.
- The applicant's proposed labelling and Consumer Medicine
Information promote appropriate use and health education.
- Very limited abuse potential - there is the same potential
for possible off-label misuse (genital herpes) as for aciclovir
5% available on general sale.
- The combination product may be more effective in early
treatment of cold sores, reducing progression rates and
lesion area. Improving access to early treatment via a pharmacist
reduces consumer treatment burden, and has the potential
to improve self-management health outcomes. Allowing advertising
to consumers would improve consumer awareness of timely
access to the combination.
One comment was received that supports the proposal to amend
the restricted medicine classification of hydrocortisone.
The Committee considered harmonising with the above classification.
Recommendation
That the Committee should defer making a decision to harmonise.
The Committee requests evidence to support harmonisation.
- Ranitidine
In March 2015, the ACMS recommended that ranitidine be exempted
from Schedule 2 (pharmacy medicine) when in divided preparations
for oral use containing 300 mg or less of ranitidine per dosage
unit in the manufacturer's original pack containing not more
than seven dosage units, with an implementation date of 1 October
2015.
The reasons for the recommendation comprised the following:
- Both the 300 mg and 150 mg ranitidine products are indicated
for relief of symptoms of gastro-oesophageal reflux. The
7 x 300 mg tablet packs and 14 x 150 mg tablet packs each
contain the same total quantity of ranitidine - both packs
would provide seven days' supply at the maximum daily dose.
Once daily dosing (with 300 mg tablets) could be seen as
a benefit over the twice daily dosing which may be required
for efficacy with the 150 mg tablets.
- Consumers are more likely to seek medical aid due to
perceived inefficacy of a product marketed as being stronger.
- The 300 mg dosage unit provides an easier to access
dosage form of a dose that is also possible with the currently
unscheduled medication, albeit one that is not recommended
(for all users) by the pack instructions.
The Committee considered harmonising with the above classification.
One comment was received with regards to ranitidine and the
supply of medicines in manufacturer's original pack.
The Committee noted the comment. As stated in the Medicines
Act 1981, medicines are to be supplied in the manufacturer's
original pack as required by specific labelling guidelines.
Recommendation
That the general sale classification of ranitidine should
be amended to include 300 milligrams or less per dose unit when
sold in the manufacturer's original pack containing not more
than seven dose units.
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8.2.3
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Decisions by the Delegate – May 2014
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- Allergens
In March 2015, the Delegate made the final decision to amend
the Schedule 4 (prescription medicine) entry for allergens to
include "for therapeutic use", with an implementation date of
1 June 2015.
The reason for the decision is that it clarifies that the Schedule
4 entry only applies to allergens used in therapeutic circumstances.
The Committee considered harmonising with the above classification.
The Committee noted that allergens only for therapeutic use
are classified under the Medicines Act 1981.
Recommendation
That the prescription medicine entry for allergens remains.
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9
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Agenda items for the next meeting
The following items will be added to the agenda of the next meeting:
- Pack size of paracetamol
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10
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General Business
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10.1
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Article by Nadia Freeman and Paul Quigley
The Committee discussed the article by Nadia Freeman and Paul
Quigley:
Freeman N and Quigley P. 2015. Care versus convenience: Examining
paracetamol overdose in New Zealand and harm reduction strategies
through sale and supply. The New Zealand Medical Journal. URL
https://www.nzma.org.nz/journal/read-the-journal/all-issues/2010-2019/2015/vol-128-no-1424-30-october-2015/6708
(accessed 30 October 2015)
The Committee made the recommendation that Medsafe should review
the pack size of paracetamol and report back to the Committee at
a future meeting.
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10.2
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Australian Delegate's Interim decision
on Codeine and letter from New Zealand Self-Medication Industry
The Committee noted the Australian Delegate's interim decision
on codeine. The Committee will defer making a decision until more
information becomes available.
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10.3
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Barriers to Accessing Prescription Medicines
The Committee noted several recent submissions alluded to barriers
to accessing prescription medicines (cost, time, and convenience).
Submitters indicate that an over-the-counter (OTC) classification
would address access issues even though OTC medicines tend to be
more expensive than subsidised prescription medicines. However,
evidence was anecdotal.
The Committee considered it would be useful to see data from
a comprehensive study to support the claim that reclassification
would improve access rather than other options such as extending
prescribing rights. The Committee deliberated and indicated that
it would be useful to have a long-term strategic review of the provisions
of healthcare and the role of reclassification with it.
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11
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Date of next meeting
The next meeting will be held on a Tuesday in April 2016.
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