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7.9 PRODUCT EXPERIENCE

Patients experience symptoms, manifest signs or develop diseases or syndromes while exposed to medical devices and/or drugs. Evidence suggests that some of these symptoms, signs, diseases or syndromes may develop as a consequence of the products used. Examples include the development of clear cell adenocarcinoma of the vagina in the daughters of mothers treated with diethylstilbestrol during pregnancy and gastrointestinal bleeding in patients treated with non-steroidal anti-inflammatory drugs. While it is difficult to prove causality, strong evidence exists in many cases.

It is important to document such experiences during the development and testing of products to identify potential adverse effects but also during routine use of the product to identify serious adverse effects which occur infrequently. The latter is the realm of pharmacoepidemiology and post-marketing surveillance.

Adverse events are important for product manufacturers as signal generating hypotheses concerning drug kinetics or dynamics, often in special populations of patients. Adverse events are important for regulators in ensuring that manufacturers protect the public health in assessments of risk and benefits, including special populations, and that they promptly and thoroughly investigate individual events and clusters of events. Adverse events are especially important for practitioners and patients who always deal with a special population of one individual who may be having an event and a practitioner seeking information about related events seen with the same or similar products.

Reporting has usually focused on serious and unexpected events. Serious, if defined unambiguously, focuses attention on those events of most importance to the patient and practitioner. Expected events are those which prior experience has demonstrated to be probabilistically linked to the product and are generally included in product labeling.

Because of the risks associated with the uses of drugs and medical devices, a system of surveillance has been established in most developed countries. With globalization of the marketplace, the need to share this information across national boundaries has increased. Currently most reporting is performed using a series of forms, including CIOMS, yellow cards, the FDA’s 1639 and MedWatch forms and the Japanese form, which are sent:

• from identified reporting sources to regulatory bodies

• from identified reporting sources to product manufacturers

• between regulatory bodies

• within product manufacturers

• within regulatory bodies

• from product manufacturers to regulatory bodies

• from regulatory bodies to the WHO Collaborative Drug Surveillance Center

Figure 7-18. - Flow of product experience information

Undisplayed Graphic

Regardless of who originates a drug experience report, documentation of the experience eventually reaches the regulatory agencies. The manufacturer is mandated to alert the regulatory agency.

Electronic interchange of these data would reduce errors, decrease costs and speed communications.

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