## Report on Terbinafine Adverse Drug Reaction Labeling
**1. Executive Summary:**
This report analyzes a directive from the Central Drugs Standard Control Organization (CDSCO) regarding the drug Terbinafine. The directive mandates that manufacturers of Terbinafine formulations include Acute Generalized Exanthematous Pustulosis (AGEP) as an adverse drug reaction (ADR) in the drug's label, package insert, and promotional literature. This change is based on recommendations from the Pharmacovigilance Programme of India (PvPI) and the Subject Expert Committee (SEC). The key finding is that Terbinafine manufacturers must immediately update their product labeling to comply with this new requirement.
**2. Introduction:**
This report aims to provide a comprehensive overview of a directive issued by the CDSCO concerning the labeling of Terbinafine products. The analysis is based solely on the information provided in the directive text.
**3. Policy Overview:**
This directive constitutes an *amendment* to existing regulations concerning the labeling and marketing of Terbinafine.
* **Core Objective(s):** Based on the text, the core objective is to enhance patient safety by ensuring that healthcare professionals and patients are aware of the potential adverse drug reaction, Acute Generalized Exanthematous Pustulosis (AGEP), associated with Terbinafine use.
**4. Background and Rationale:**
This is an amendment because it adds information to existing product labeling requirements. The likely reason for this specific amendment is the identification of a potential safety concern related to Terbinafine: the occurrence of Acute Generalized Exanthematous Pustulosis (AGEP) as an adverse drug reaction. The PvPI's review of ADR reports and the subsequent deliberation by the SEC indicate that there is sufficient evidence to warrant including AGEP in the drug's prescribing information.
**5. Key Provisions / Changes:**
This is an amendment, therefore the following items describe the changes:
* **What specific part of the original policy is being changed:** The directive amends the existing labeling requirements for Terbinafine products. Specifically, it targets the "label/Package insert/Promotional Literature" of the drug.
* **What the *new* rule/provision *is*, based *only* on the amendment text:** The new rule mandates that all manufacturers of Terbinafine formulations must include Acute Generalized Exanthematous Pustulosis (AGEP) as an adverse drug reaction in the label, package insert, and promotional literature of the drug.
* **Explain the *difference* or the *effect* of this specific change:** This change ensures that patients and healthcare providers are informed of a previously unlisted, but potentially serious, adverse reaction associated with Terbinafine. This allows for more informed prescribing decisions and potentially earlier recognition and management of AGEP if it occurs.
**6. Target Audience and Stakeholders:**
The primary target audience and stakeholders are:
* Manufacturers of Terbinafine formulations in India.
* State/UT Drugs Controllers (who are tasked with directing the manufacturers).
* Healthcare professionals prescribing and dispensing Terbinafine.
* Patients using Terbinafine.
**7. Implementation Aspects (Inferred):**
* **Responsible agency/bodies mentioned:**
* Central Drugs Standard Control Organization (CDSCO) is the issuing and overseeing body.
* National Coordination Centre for Pharmacovigilance Programme of India (NCCPvPI) provided the initial recommendation.
* Subject Expert Committee (SEC) deliberated on the recommendation.
* State/UT Drugs Controllers are responsible for directing manufacturers.
* **Any timelines or procedures specified *in the text*?:** The directive requests the State/UT Drugs Controllers to direct manufacturers immediately and to intimate the CDSCO of the action taken. This implies an expectation of prompt action, though no specific deadline is mentioned.
**8. Expected Outcomes / Impact of Changes:**
The likely intended outcome of this amendment is improved patient safety. By including AGEP as an ADR on Terbinafine labels, the amendment aims to:
* Increase awareness of this potential adverse effect among healthcare professionals and patients.
* Facilitate earlier diagnosis and management of AGEP in patients taking Terbinafine.
* Potentially reduce the incidence of severe complications associated with AGEP through timely intervention.
* Potentially impact prescribing habits by alerting physicians to this risk.
**9. Conclusion:**
The CDSCO directive mandates a critical update to the labeling of Terbinafine products, requiring the inclusion of Acute Generalized Exanthematous Pustulosis (AGEP) as an adverse drug reaction. This amendment reflects a commitment to patient safety and highlights the importance of ongoing pharmacovigilance. Terbinafine manufacturers must comply with this directive promptly to ensure that patients and healthcare providers have access to complete and accurate information about the drug's potential risks.
Key Entities Referenced
Terbinafine: An antifungal drug approved by CDSCO and marketed in India.
CDSCO: Central Drugs Standard Control Organization, the national regulatory body for pharmaceuticals and medical devices in India.
NCCPvPI: National Coordination Centre for Pharmacovigilance Programme of India, functioning at IPC Ghaziabad.
IPC Ghaziabad: Indian Pharmacopoeia Commission located in Ghaziabad, Uttar Pradesh, where the NCCPvPI functions.
PvPI: Pharmacovigilance Programme of India, responsible for monitoring drug safety and adverse drug reactions.
Acute Generalized Exanthematous Pustulosis (AGEP): A severe adverse drug reaction that the notification mandates be included in the prescribing information of Terbinafine.
SRP: Signal Review Panel, a body under the Pharmacovigilance Programme of India (PvPI) that reviews drug safety signals.
ICSR: Individual Case Study Reports, used by PvPI to evaluate drug ADRs.
SEC-Antimicrobial/Antiviral: Subject Expert Committee on Antimicrobial and Antiviral drugs, which deliberated on the PvPI recommendations.
New Delhi: Location of CDSCO HQR (Headquarters) where the Subject Expert Committee meeting was held.
F. No. 12-01/18-DC (Pt-337)
Government of India
Directorate General of Health Services
Central Drugs Standard Control Organization
(New Drugs Division)
FDA Bhawan, Kotla Road,
New Delhi-110002.
Dated:
re 12 JUN asp
All State/UT Drugs Controllers,
Sub: Terbinafine — Acute generalized Exanthematous Pustulosis
(AGEP) - Reg.
ww ke wk kk ke
Sir,
Terbinafine is approved by CDSCO and marketed in the country in various
dosage forms.
The National Co-ordination Centre for Pharmacovigilance Programme of India
(NCC-PvPI), functioning at IPC Ghaziabad has _ forwarded _ their
recommendation based on ADR reports on certain medicinal products
including Terbinafine, which were discussed by them in the 11th Signal Review
Panel (SRP) under the programme meeting held on 05.10.2017 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 Terbinafine-ADR on the basis
of Individual Case Study Reports (ICSR) and recommended CDSCO to take
necessary steps to incorporate Acute Generalized Exanthematous
Pustulosis (AEGP) as an adverse drug reaction in to the prescribing
information leaflet (PIL) of the drug Terbinafine marketed in the country.
Subsequently, the PvPl recommendations was deliberated in the Subject
Expert Committee (SEC-Antimicrobial & Antiviral) meeting held on 22.05.2019
at CDSCO HQR, New Delhi. After detailed deliberation the Committee has
recommended that Acute Generalized Exanthematous Pustulosis (AGEP)
1should be incorporated as an adverse drug reaction in the package insert of
the drug Terbinafine as suggested by PvPI.
The recommendation of the SEC has been considered by this office.
Accordingly, you are requested to direct the manufacturers of Terbinafine
formulations under your jurisdiction to mention Acute Generalized
Exanthematous Pustulosis (AGEP) as an adverse drug reaction in the
label/Package insert/Promotional Literature of the drug.
Action taken in this regard may be intimated to this office.
Yours faithfully,
¢
* of
aes «. pest B
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.