ANNEX I
LIST OF THE NAMES, PHARMACEUTICAL FORM, STRENGTH OF THE MEDICINAL PRODUCTS, ROUTE OF ADMINISTRATION, APPLICANT, MARKETING AUTHORISATION HOLDER IN THE MEMBER STATES
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Marketing Authorisation Route of Content Member State Applicant Invented name Strength Pharmaceutical Form Holder administration (concentration)
THE GUERBET ARTIREM 0.0025 mmol/ml Solution for injection Intraarticular use 0.0025 mmol/ml NETHERLANDS GERMANY GUERBET ARTIREM 0.0025 mmol/ml Solution for injection Intraarticular use 0.0025 mmol/ml
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ANNEX II
SCIENTIFIC CONCLUSIONS AND GROUNDS FOR AMENDMENT OF THE SUMMARY OF PRODUCT CHARACTERISTICS PRESENTED BY THE EMEA
3/14 SCIENTIFIC CONCLUSIONS
OVERALL SUMMARY OF THE SCIENTIFIC EVALUATION OF ARTIREM (see Annex I)
Contrast-enhanced arthrography using Magnetic Resonance Imaging (MRI) is performed by administering contrast agents by intravenous route (indirect MRI arthrography) or intra-articular injection directly into the joint (i.e. direct MRI arthrography). Contrast agents such as Gd-DTPA (Magnevist®) and Gd-DOTA (DOTAREM®) have been approved for intravenous use at the concentration of 0.5 M in the late 1980’s. In the European Union, DOTAREM is licensed in Austria (1997), Belgium (1989), Denmark (1996), Finland (1995), France (1989), United Kingdom (1996), Greece (1996), Ireland (1996), Italy (1996), Portugal (1991), Luxembourg (1989), Sweden (1995), The Netherlands (1991) and Spain (1998). ARTIREM (a ready-to-use diluted Gd-DOTA, solution for injection in prefilled syringes) has been approved as a line extension of DOTAREM in France (2002), Switzerland (2002), Belgium (2002), Luxembourg (2003), The Netherlands (2003) and Denmark (2004). ARTIREM has the same qualitative formulation as the authorised DOTAREM (Gd-DOTA), but is administered by intra-articular injection directly into the joint, at a much lower concentration of 0.0025 mmol/ml. A referral for Arbitration, under article 29 of Directive 2001/83/EC to the CHMP was triggered by the the German Authorities, BfArM on 5 March 2004. The major objections raised were that the efficacy and safety of ARTIREM 0.0025 mmol/ml had not been sufficiently substantiated and that the claimed indications do not refer to diseases, sufferings, bodily injuries or disease symptoms but solely to the method of arthrography. Additionally, it was considered that there could be potentially serious public health concerns related to the use of this product because of the safety concerns. The CHMP list of questions was issued on 25 March 2004.
• Efficacy issues CHMP considers it well known that the diagnostic performance of Gd complexes depends only on the paramagnetic ion gadolinium (Gd), which is responsible for the efficacy (effect on MRI signal) of such contrast agents. DOTA or DTPA are used only to complex Gd in order to reduce the toxicity of Gd. Gd-DOTA and Gd-DTPA are known to have the same efficacy. Comprehensive references and arguments of Gd-DOTA and Gadolinium-DTPA as being equivalent in terms of safety and efficacy have been presented in view of the comparability of these two compounds, and justify why the diagnostic efficacy of Gd-DOTA could be sufficiently supported by bibliographical listing of clinical studies performed with gadolinium complexes with different chemical structure. The CHMP considers it acceptable that the company did not take into consideration the document “Points to Consider in the Evaluation of Diagnostics Agents” (CPMP/EWP/1119/98) that came into force in November 2001, after the Mutual Recognition Procedure for the present application that was initiated in July 2001 in The Netherlands. Although there are no specific clinical pharmacokinetic data available after the intraarticular injection of Gd-DOTA, the overall systemic exposure is expected to be much lower than the one observed after the
4 intravenous administration. The Company has committed to perform a clinical pharmacokinetic study of Gd-DOTA after intraarticular administration to confirm the available animal data indicating that Gd- DOTA is rapidly and completely cleared from the joint cavity.
- Safety issues The CHMP considers that company has provided sufficient data about the safety profile of diluted Gd-DOTA by the intraarticular route. Since ARTIREM 0.0025 mmol/ml in prefilled syringes was first approved in Europe (2002), 12,000 patients have been exposed to this product. On the basis of the PSURs provided during this period, no severe adverse events (SAEs) have been reported. Additionally, no adverse reactions were reported for diluted Gd-DOTA in vials in Switzerland since available on the market (1992). Therefore the available post-marketing information on the safety of intraarticular Gd-DOTA does not raise any additional safety concern. Direct MRI arthrography with diluted Gd chelate solutions has been performed off-label by physicians using a self-prepared dilution, since no ready-to-use diluted product was available on the market. The CHMP considers that the availability of gadolinium complex formulations specifically aimed for direct MRI arthrography is regarded as an improvement by removing the septic risk related to the on-site preparation of a concentrated product. - Benefit/Risk considerations Overall, from the data provided it is concluded that the efficacy and safety of ARTIREM have been sufficiently established. The company has committed to perform a clinical pharmacokinetic study of Gd- DOTA after intraarticular administration to confirm the available animal data indicating that Gd-DOTA is rapidly and completely cleared from the joint cavity. Consequently, a positive risk/benefit conclusion for ARTIREM is concluded with the available data.
GROUNDS FOR AMENDMENT OF THE SUMMARY OF PRODUCT CHARACTERISTICS
Whereas,