CBER had concerns over Octagam from the start:
(Like my colleague says: Last one out, turn off the lights.)
CBER's Office of Compliance and Biologics Quality reviewed a card file and dosage guide for Octagam 5% [Immune Globulin Intravenous (Human)], which were disseminated at the Octapharma booth at the American Academy of Allergy, Asthma and Immunology meeting in San Antonio March 18-22.
The agency also reviewed the company's website and determined the file card, dosage guide and website were misleading because they failed to reveal the risks and contained unsubstantiated safety, effectiveness and/or superiority claims.
According to the FDA-approved PI, Octagam is a solvent/detergent treated, sterile, 5% liquid preparation of highly purified, immunoglobulin G (1gG) de rived from large pools of human plasma. Octagam is indicated for treatment of primary immune deficient disease, such as congenial agammaglobulinemia agammaglobulinemia /agam·ma·glob·u·lin·emia/ (a-gam?ah-glob?u-li-ne´me-ah) absence of all classes of immunoglobulins in the blood. See also hypogammaglobulinemia. and hypogamma globulin globulin, any of a large family of proteins of a spherical or globular shape that are widely distributed throughout the plant and animal kingdoms. Many of them have been prepared in pure crystalline form. common variable immunodeficiency Common Variable Immunodeficiency Definition
Common variable immunodeficiency is an immunodeficiency disorder characterized by a low level of antibodies. Patients with this disease are subject to recurring infections. .
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The PI included a black box warning regarding reports of renal dysfunction, acute renal failure acute renal failure Acute kidney failure Nephrology An abrupt decline in renal function, triggered by various processes–eg, sepsis, shock, trauma, kidney stones, drug toxicity-aspirin, lithium, substances of abuse, toxins, iodinated radiocontrast. , osmotic nephrosis nephrosis (nəfrō`səs), kidney disease characterized by lesions of the epithelial lining of the renal tubules, resulting in marked disturbance in the filtration function and the consequent appearance of large amounts of protein (albumin) and death associated with the use of this product. But, although the website mentioned adverse drug reactions, there was no additional information on contraindications, black box warnings or other warnings.
Moreover, the file card contained text stating, "Unsurpassed viral safety." FDA FDA
abbr.
Food and Drug Administration
FDA,
n.pr the abbreviation for the Food and Drug Administration. said it was unaware of data consisting of substantial evidence or clinical experience supporting this claim.
Finally, Octapharma USA failed to submit its promotional material to FDA at the time of initial dissemination. AE, F-B, PMA; Doc. 13579W