## Report on Diclofenac Injection Package Insert Amendment
**1. Executive Summary:**
This report analyzes a directive from the Central Drugs Standard Control Organization (CDSCO) regarding Diclofenac injection. The directive mandates the inclusion of Nicolaus Syndrome as an adverse drug reaction (ADR) in the package insert and promotional literature for Diclofenac injection marketed in India. This change is based on recommendations from the Pharmacovigilance Programme of India (PvPI) and subsequent deliberation by a Subject Expert Committee. The core purpose is to enhance patient safety by providing more comprehensive information about potential risks associated with the drug.
**2. Introduction:**
This report aims to provide an informative overview of a directive issued by the CDSCO concerning the prescribing information for Diclofenac injection, based solely on the provided document. The report outlines the background, key changes mandated, affected parties, and potential impact of this regulatory update.
**3. Policy Overview:**
* This directive constitutes an *amendment* to the existing regulatory framework governing the labeling and marketing of Diclofenac injection in India.
* **Core Objective(s):** Based on the text, the primary objective is to enhance patient safety by ensuring that healthcare professionals and patients are informed about the potential risk of Nicolaus Syndrome associated with Diclofenac injection.
**4. Background and Rationale:**
* This amendment addresses the need to update the prescribing information for Diclofenac injection to include Nicolaus Syndrome as a known adverse drug reaction. The rationale stems from ADR reports analyzed by the National Coordination Centre for Pharmacovigilance Programme of India (NCCPvPI), indicating a potential link between Diclofenac and the occurrence of Nicolaus Syndrome. The amendment aims to ensure accurate and comprehensive risk communication.
**5. Key Provisions / Changes:**
* The amendment *specifically* focuses on updating the package insert/promotional material of Diclofenac injection.
* The *new* rule/provision requires manufacturers of Diclofenac injection to include Nicolaus Syndrome as an adverse drug reaction in the package insert and promotional literature.
* The *effect* of this change is to provide healthcare professionals and patients with more complete information about the potential risks associated with the drug. This allows for better informed decisions regarding treatment options and potentially reduces the risk of misdiagnosis or delayed intervention in cases of Nicolaus Syndrome.
**6. Target Audience and Stakeholders:**
The primary target audience and stakeholders directly affected by this amendment are:
* Manufacturers of Diclofenac injection in India.
* State/UT Drugs Controllers who regulate these manufacturers.
* Healthcare professionals prescribing Diclofenac injection.
* Patients receiving Diclofenac injection.
**7. Implementation Aspects (Inferred):**
* **Responsible Agency/Bodies:** The CDSCO is the primary responsible agency. The State/UT Drugs Controllers are responsible for directing manufacturers within their jurisdiction. The PvPI plays an advisory role.
* **Timelines/Procedures:** The text requests State/UT Drugs Controllers to direct manufacturers to update their package inserts and promotional materials. It also requests that action taken be reported back to the CDSCO. Specific timelines for implementation are not provided within this document.
* This amendment focuses implementation on the manufacturers' updates to product labeling and promotional materials.
**8. Expected Outcomes / Impact of Changes:**
The likely intended outcome of this amendment is improved patient safety through:
* Increased awareness among healthcare professionals about the potential association between Diclofenac injection and Nicolaus Syndrome.
* Better-informed prescribing decisions by healthcare professionals.
* Increased vigilance among patients and healthcare professionals for the signs and symptoms of Nicolaus Syndrome in patients receiving Diclofenac injection.
* Potentially earlier diagnosis and management of Nicolaus Syndrome in affected individuals.
**9. Conclusion:**
The CDSCO directive mandating the inclusion of Nicolaus Syndrome as an ADR in the package insert for Diclofenac injection represents a significant step towards enhancing patient safety. By ensuring that healthcare professionals and patients have access to comprehensive information about the potential risks associated with the drug, this amendment is likely to contribute to more informed decision-making and potentially improve outcomes for individuals receiving Diclofenac injection. The directive's success hinges on the prompt and effective implementation by manufacturers and the diligent enforcement by regulatory bodies.
Key Entities Referenced
Diclofenac: A drug approved by CDSCO and marketed in the country in various dosage forms, associated with Nicolaus Syndrome.
Nicolaus Syndrome: An adverse drug reaction to be incorporated into the prescribing information leaflet (PIL) of Diclofenac injection.
Central Drugs Standard Control Organization (CDSCO): The national regulatory body for pharmaceuticals and medical devices in India.
Pharmacovigilance Programme of India (PvPI): A national program for monitoring drug safety, functioning at IPC Ghaziabad, that recommended incorporating Nicolaus Syndrome information.
Indian Pharmacopoeia Commission (IPC) Ghaziabad, Uttar Pradesh: Location of the National Coordination Centre for PvPI.
Signal Review Panel (SRP): A panel under the Pharmacovigilance Programme of India (PvPI) that discussed ADR reports, including those related to Diclofenac.
Sublet Expert Committee (SEC)-Analgesic Rheumatology: A committee that deliberated on the PvPI recommendation and recommended incorporating Nicolaus Syndrome in the package insert of Diclofenac injection.
Drugs Controller General India: The head of the Central Drugs Standard Control Organization (CDSCO).
New Delhi, Delhi: Location of CDSCO HQR and JSR, Nirman Bhawan, MoHFW.
Ministry of Health and Family Welfare (MoHFW): A government ministry to which JSR, Nirman Bhawan reports.
F. No. 12-01/18-DC (Pt-337)
Government of India
Directorate General of Health Services
Central Drugs Standard Control Organization
FDA Bhawan, Kotla Road, New Delhi
(New Drugs Division)
FDA Bhawan, Kotla Road,
New Delhi.
Dated: 2h-o F- 20/9
To,
All State/UT Drugs Controllers,
Sir/Madam,
Sub: Diclofenac associated Nicolau’s Syndrome -Reg.
KKRKEKEK SE
The drug Diclofenac is approved by CDSCO and marketed in the country in
various dosage form.
The National Co-ordination Centre for Pharmacovigilance Programme of India
(NCC-PvPI), functioning at IPC Ghaziabad has sent their recommendation based
on ADR reports on certain medicinal products including Diclofenac, which were
discussed by them in the 12" Signal Review Panel (SRP) under the programme
meeting held on 27" March, 2018, with an objective to detect Signal/Prescribing
Information Leaflet change from indian database and promote patient safety.
In the meeting, the PvPI has evaluated the drug Diclofenac -ADR on the basis of
Individual Case Study Reports (ICSRs) and recommended CDSCO to take
necessary steps to incorporate Nicolau’s Syndrome as an adverse drug
reaction in to the prescribing information leaflet (PIL) of the drug Diclofenac
injection marketed in the country.
Subsequently, the PvPI recommendation was deliberated in the Sublet Expert
Committee (SEC-Analgesic & Rheumatology) meeting held on 19.06.2019 at
CDSCO HQR, New Delhi. After detailed deliberation the Committee
recommended that Nicolau’s Syndrome shall be incorporated in the package
insert of the drug Diclofenac injection as suggested by PvPI.NY
The recommendation of the SEC has been considered by this office.
Accordingly, you are requested to direct the manufacturers of Diclofenac injection
under your jurisdiction to mention Nicolau’s Syndrome as an adverse drug
reaction in the package insert/promotional literature of the drug.
Action taken in this regard may be intimated to this office.
Yours faithfully,
Dr. S. Eswara Reddy
Drugs Controller General (India)
1. Copy for information & follow-up: -
All Zonal / Sub Zonal Offices of CDSCO.
2. Copy for information to: -
JS(R), Nirman Bhawan, MoHFW, New Delhi-110002.