CENTER FOR DRUG EVALUATION AND RESEARCH APPLICATION NUMBER: 210450Orig1s000 OTHER REVIEW(S) MEMORANDUM REVIEW OF REVISED LABEL AND LABELING Division of Medication Error Prevention and Analysis (DMEPA) Office of Medication Error Prevention and Risk Management (OMEPRM) Office of Surveillance and Epidemiology (OSE) Center for Drug Evaluation and Research (CDER) Date of This Memorandum: July 16, 2018 Requesting Office or Division: Division of Bone, Reproductive, and Urologic Products (DBRUP) Application Type and Number: NDA 210450 Product Name and Strength: Orilissa (elagolix sodium) tablets 150 mg and 200 mg Applicant/Sponsor Name: AbbVie Inc. FDA Received Date: July 12, 2018 OSE RCM #: 2017-1760-3 DMEPA Safety Evaluator: Briana Rider, PharmD DMEPA Team Leader: Lolita White, PharmD 1 PURPOSE OF MEMORANDUM The Division of Bone, Reproductive, and Urologic Products requested that we review the revised container labels and carton labeling for Orilissa (Appendix A) to determine if they are acceptable from a medication error perspective. The revisions are in response to recommendations that we made during a previous label and labeling review.a 2 OVERALL ASSESSMENT OF THE MATERIALS REVIEWED We reviewed the revised container labels and carton labeling for areas of vulnerability which could lead to medication error. We previously advised that the carton labeling (month’s supply) and the container label (week supply) could not have the same NDC package code (last 1-2 digits of the NDC number) per 21 CFR 207.33. After discussion and agreement with the CDER Electronic Drug Registration and a Rider B. Label and Labeling Review Memo for Orilissa (NDA 210450). Silver Spring (MD): FDA, CDER, OSE, DMEPA (US); 2018 JUN 14. RCM No.: 2017-1760-2. 1 Reference ID: 4292451 Listing System (EDRLS) team, AbbVie has elected not to include the NDC number on the weekly wallet container label. We find this to be acceptable. We also previously advised AbbVie to add the product’s linear barcode to each individual weekly wallet container label as required per 21 CFR 201.25(c)(2). AbbVie indicates that, because they removed the NDC number from the weekly wallet container labels, for consistency they will not add a barcode to the weekly wallet container labels. We note that per the barcode rule (21 CFR 201.25), a linear barcode must appear on the drug's label as defined by section 201(k) of the Federal Food, Drug, and Cosmetic Act. However, the barcode rule also indicates that the linear barcode must contain, at a minimum, the appropriate NDC number and there is no associated NDC number for the weekly wallet container labels. Our current review finds the proposed Orilissa (elagolix sodium) tablet packaging configuration includes an outer carton which contains four weekly wallet blister packs. We note the labeling on the outer carton includes a linear barcode and NDC number. We also note the weekly wallet blister packs are not intended to be dispensed separately from the carton. We considered the risk for medication error to occur due to the lack of a linear barcode on the weekly wallet container label and find that it does not pose a significant safety concern. For the aforementioned reasons, we find AbbVie’s proposal not to include a linear barcode on the weekly wallet container labels to be acceptable. 3 CONCLUSION The revised container labels and carton labeling for Orilissa are acceptable from a medication error perspective. We have no further recommendations at this time. 9 Page(s) of Draft Labeling have been Withheld in Full as b4 (CCI/TS) immediately following this page 2 Reference ID: 4292451 Signature Page 1 of 1 -------------------------------------------------------------------------------------------- This is a representation of an electronic record that was signed electronically. Following this are manifestations of any and all electronic signatures for this electronic record. -------------------------------------------------------------------------------------------- /s/ ------------------------------------------------------------ BRIANA B RIDER 07/16/2018 LOLITA G WHITE 07/17/2018 Reference ID: 4292451 FOOD AND DRUG ADMINISTRATION Center for Drug Evaluation and Research Office of Prescription Drug Promotion ****Pre-decisional Agency Information**** Memorandum Date: July 5, 2018 To: Maria Wasilik, Regulatory Project Manager Division of Bone, Reproductive, and Urologic Products (DBRUP) From: Lynn Panholzer, PharmD, Regulatory Review Officer Office of Prescription Drug Promotion (OPDP) CC: Matthew Falter, PharmD, Team Leader, OPDP Subject: OPDP Labeling Comments for ORILISSA (elagolix) tablets, for oral use NDA: 210450 In response to DBRUP’s consult request dated October 24, 2017, OPDP has reviewed the proposed product labeling (PI), Medication Guide, and carton and container labeling for the original NDA submission for ORILISSA (elagolix) tablets, for oral use. PI and Medication Guide: OPDP’s comments on the proposed PI are based on the draft PI retrieved from DBRUP’s sharepoint site on June 22, 2018, and are provided below. A combined OPDP and Division of Medical Policy Programs (DMPP) review of the Medication Guide was completed, and comments on the proposed Medication Guide were sent under separate cover on July 2, 2018. Carton and Container Labeling: OPDP has reviewed the attached proposed carton and container labeling submitted by the applicant to the electronic document room on May 21, 2018, and our comments are provided below. Thank you for your consult. If you have any questions, please contact Lynn Panholzer at (301) 796-0616 or [email protected]. 53 Page(s) of Draft Labeling have been Withheld in Full as b4 (CCI/TS) immediately following this page 1 Reference ID: 4287346 Signature Page 1 of 1 -------------------------------------------------------------------------------------------- This is a representation of an electronic record that was signed electronically. Following this are manifestations of any and all electronic signatures for this electronic record. -------------------------------------------------------------------------------------------- /s/ ------------------------------------------------------------ LYNN M PANHOLZER 07/05/2018 Reference ID: 4287346 Department of Health and Human Services Public Health Service Food and Drug Administration Center for Drug Evaluation and Research Office of Medical Policy PATIENT LABELING REVIEW Date: July 2, 2018 To: Hylton V. Joffe, M.D. Director Division of Bone, Reproductive, and Urologic Products (DBRUP) Through: LaShawn Griffiths, MSHS-PH, BSN, RN Associate Director for Patient Labeling Division of Medical Policy Programs (DMPP) From: Sharon W. Williams, MSN, BSN, RN Senior Patient Labeling Reviewer Division of Medical Policy Programs (DMPP) Lynn Panholzer, PharmD Regulatory Review Officer Office of Prescription Drug Promotion (OPDP) Subject: Review of Patient Labeling: Medication Guide (MG) Drug Name (established ORILISSA (elagolix) name): Dosage Form and Route: tablets, for oral use Application Type/Number: NDA 210450 Applicant: AbbVie Inc. Reference ID: 4285762 1 INTRODUCTION On August 23,2017, AbbVie Inc. submitted for the Agency’s review a New Drug Application (NDA) for elagolix, tablets for oral use indicated for the management of endometriosis with associated pain. On October 23, 2017, the Division of Medication Error Prevention and Analysis (DMEPA) approved the submitted tradename ORLISSA for the application. This collaborative review is written by the Division of Medical Policy Programs (DMPP) and the Office of Prescription Drug Promotion (OPDP) in response to a request by the Division of Bone, Reproductive, and Urology Products (DBRUP) on October 24, 2017, for DMPP and OPDP to review the Applicant’s proposed MG for elagolix (ORLISSA), tablets for oral use. 2 MATERIAL REVIEWED Draft elagolix (ORLISSA) tablets, for oral use MG received on August 23, 2017, and received by DMPP and OPDP on June 22, 2018. Draft elagolix (ORLISSA) tablets, for oral use Prescribing Information (PI) received on August 23, 2017, revised by the Review Division throughout the review cycle, and received by DMPP and OPDP on June 22, 2018. 3 REVIEW METHODS To enhance patient comprehension, materials should be written at a 6th to 8th grade reading level, and have a reading ease score of at least 60%. A reading ease score of 60% corresponds to an 8th grade reading level. Additionally, in 2008, the American Society of Consultant Pharmacists Foundation (ASCP) in collaboration with the American Foundation for the Blind (AFB) published Guidelines for Prescription Labeling and Consumer Medication Information for People with Vision Loss. The ASCP and AFB recommended using fonts such as Verdana, Arial or APHont to make medical information more accessible for patients with vision loss. In our collaborative review of the MG we have: simplified wording and clarified concepts where possible ensured that the MG is consistent with the Prescribing Information (PI) removed unnecessary or redundant information ensured that the MG is free of promotional language or suggested revisions to ensure that it is free of promotional language ensured that the MG meets the Regulations as specified in 21 CFR 208.20 ensured that the MG meets the criteria as specified in FDA’s Guidance for Useful Written Consumer Medication Information (published July 2006) Reference ID: 4285762 4 CONCLUSIONS The MG is acceptable with our recommended changes. 5 RECOMMENDATIONS Please send these comments to the Applicant and copy DMPP