One Year Post-Exclusivity Adverse Event Review: Imiquimod Pediatric Advisory Committee Meeting November 18, 2008 Amy M. Taylor, MD, MHS, FAAP Medical Officer Pediatric and Maternal Health Staff Office of New Drugs Food and Drug Administration Background Drug Information
• Drug: AldaraTM (Imiquimod) Topical Cream
• Therapeutic Category: immune response modifier
• Sponsor: Graceway Pharmaceuticals, LLC
• Original Market Approval: February 27, 1997
• Pediatric Exclusivity Granted: December 13, 2006 Background Drug Information
• Indications:
– Treatment of clinically typical, nonhyperkeratotic,
nonhypertrophic actinic keratoses on the face or scalp in immunocompetent adults
– Treatment of biopsy confirmed primary superficial
basal cell carcinoma in immunocompetent adults;
– Treatment of external genital and perianal
warts/condyloma acuminata in patients 12 years or older
– Limitations of Use: Studies in children ages 2 to 12
years with molluscum contagiosum (MC) failed to demonstrate efficacy
Background Drug Information
• Dosage:
– Actinic keratosis: 2 times per week x 16 weeks– Superficial basal cell carcinoma: 5 times per
– External genital warts: 3 times per week until
Background Drug Use Information
• Aldara™ prescriptions in the pediatric population
(ages 0-16 years) accounted for approximately 21% of total dispensed Aldara™ prescriptions*
• Of the prescriptions dispensed to pediatric patients,
40% were dispensed to patients aged 6-10 years and 38% dispensed to patients aged 11-16 years
• Top diagnoses** – viral warts and MC
*Source: SDI Vector One® National, Years 2005 – 2007. Data Extracted 6-2008.
**Source: SDI Physician Drug and Diagnosis Audit, Years 2005 – 2007. Data Extracted 6-2008
Exclusivity Studies
Pharmacokinetic study result:• Absorption of imiquimod following topical
application in pediatric patients was comparable to adults
Exclusivity Studies
Efficacy• Two double-blind, vehicle-controlled safety
and efficacy studies in 702 pediatric patients age 2 to 12 years with MC
– 470 patients exposed to Aldara™– Treatment was up to 16 weeks
Exclusivity Studies
Efficacy results:• Since the vehicle clearance rates were higher than
Aldara™, these studies failed to demonstrate
• No indication for molluscum contagiosum granted
– Study 1 –Aldara™ (24%); vehicle (26%) – Study 2 – Aldara™ (24%); vehicle (28%)
Exclusivity Studies
Safety results:• In general, adverse events in the Aldara™ group
resembled those seen in studies with adults
• The most frequently reported possibly or
probably related adverse event was application site reaction (31% in Aldara™ group and 20% in vehicle group)
• A decrease in WBC and absolute neutrophil
Exclusivity Studies
Safety results (continued):• Severe local reactions reported in Aldara™ group
– Erythema (28%)– Edema– Scabbing/crusting– Flaking/scaling– Erosion – Weeping/exudate
Labeling Sections ChangedHighlights Section
Section 1 Indications and Usage
– 1.4 Limitations of Use: Studies in children 2
to 12 years with MC failed to demonstrate efficacy
Details of Specific Labeling Changes continued Section 8 Use in Specific Populations 8.4 Pediatric Use
– A description of the two efficacy studies and
– Adverse events observed during the clinical
studies, including incidence of severe local
– A description of the pharmacokinetic study and
results including extent of systemic absorption and
decrease in median WBC/Absolute Neutrophil
Pediatric Adverse Events in 1 Year Post Exclusivity Period
Crude Counts1 of AERS Reports for All Sources from Date Pediatric
Exclusivity Was Granted (12/13/2006 to 1/13/2008)
1May include duplicates2Serious adverse drug experience per regulatory definition (CFR 314.80), which includes death, life threatening, hospitalization, disability, and congenital anomaly
Pediatric Adverse Events Since Marketing Approval
Crude Counts1 of AERS Reports for All Sources from
Marketing Approval Date to January 13, 2008 (US counts in parentheses)
1May include duplicates2Serious adverse drug experience per regulatory definition (CFR 314.80), which includes death, life threatening, hospitalization, disability, and congenital anomaly
Pediatric Uses Reported with Adverse Events Since Marketing Approval
Viral Warts (49%)Molluscum Contagiosum (24%)Warts and Common Warts (7%)Genital Warts (6%)Plantar Warts (3%)Alopecia (3%)Venereal Warts (1%)Herpes (1%)Actinic Keratosis (1%)Not Reported (5%)
Pediatric Adverse Events Since Marketing Approval
Crude Counts1 of AERS Reports for All Sources from
Marketing Approval Date to January 13, 2008 (US counts in parentheses)
1May include duplicates2Serious adverse drug experience per regulatory definition (CFR 314.80), which includes death, life threatening, hospitalization, disability, and congenital anomaly
Pediatric Deaths Since Market Approval
gunshot while on 3rd month of second course of imiquimod (12.5 mg) three times weekly for viral warts. Total treatment duration 31 weeks. No known history of depression. This is a labeled event. Pediatric Adverse Events Since Marketing Approval
Crude Counts1 of AERS Reports for All Sources from
Marketing Approval Date to January 13, 2008 (US counts in parentheses)
1May include duplicates2Serious adverse drug experience per regulatory definition (CFR 314.80), which includes death, life threatening, hospitalization, disability, and congenital anomaly
Serious Pediatric Adverse Events Since Market Approval (N=12)
Neurologic (n=3) • Seizures (n=2); labeled• Temporary paralysis (n=1); labeledCongenital Anomaly (n=2)• Undecended testicles, GU reflux, ASD, VSD;
• Hirschsprung’s disease; unlabeledHematologic (n=1)• Thrombocytopenia purpura; labeled
Serious Pediatric Adverse Events Since Market Approval
Localized reactions (n=6) labeled• 7 year old female with a history of cerebral palsy after two applications
for genital warts developed extreme swelling and inability to void necessitating catheterization in the emergency room. Patient also diagnosed with viral infection after developing a sore throat and low grade fever.
• 15 year old female with burning blisters, swelling and inability to void
after one application for genital warts. Treated with topical lidocaine.
• 4 year old female with burning pain and inability to void, fever, and
flu-like symptoms after 3 days of treatment (daily application) for herpes. Patient was hospitalized 2 days later. Serious Pediatric Adverse Events Since Market Approval
Localized reactions (n=6) labeled• 15 year old female with skin burns, blisters, pain upon urination, fever
and fatigue after 5 days of treatment (1/2 packet 3 times/week) for genital warts. Patient was hospitalized and treated with antibiotics for the skin burns and blisters
• 16 year old female with burning, erosions, and ulcerations after 3 days
of treatment (1 packet daily) for genital warts. Patient was hospitalized after developing fever, increase WBC (14,000), and flu-like symptoms.
• 10 year old male with an application site abscess requiring incision and
drainage and antibiotics after 1 month of treatment (unknown dosage every other day for 2 weeks and daily for 2 weeks) for MC.
17.6 Patients Being Treated for External Genital Warts
– Female patients should take special care if
applying the cream at the opening of the vagina because local skin reactions on the delicate moist surfaces can result in pain or swelling and may cause difficulty in passing urine. Summary: Imiquimod
• Pediatrics accounts for 21% of Aldara ™ use*• Despite studies showing lack of efficacy, off-
label use is common including treatment of MC
• Pediatric female patients have reported inability
to void secondary to severe local reactions during
– The Review Division is planning to update this
*Source: SDI Vector One® National, Years 2005 – 2007. Data Extracted 6-2008. Question for the Committee
• In addition to planning to update the
labeling related to severe local reactions in
females with use in the genital area, FDA
will continue its standard, ongoing safety
Acknowledgements
• Judith Cope, M.D., M.P.H. • Dianne Murphy, M.D.
CONFIDENTIAL: PSYCHOEDUCATIONAL EVALUATION City Community Schools Name: Sam * Date(s) of Evaluation: 11/18/2010 Date of Birth: Age: 2 years, 10 months Grade: Preschool Parent: Mrs. Mother Telephone: Address: Examiner: Sarah Connolly, M.A. Supervisor: Dr. Psychologist, Ph.D. * Name and other information have been changed to protect the identity of
Clinical Toxicology, 37(6), 731–751 (1999) Position Statement and Practice Guidelines on the Use of Multi-Dose Activated Charcoal in the Treatment of Acute Poisoning American Academy of Clinical Toxicology;European Association of Poisons Centresand Clinical Toxicologists ABSTRACT In preparing this Position Statement, all relevant scientific literature was identi- fied and reviewed critica