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Drug-Induced Liver Injury: Premarketing Clinical Evaluation

FinalCenter for Drug Evaluation and Research Center for Biologics Evaluation and Research07/29/2009

Description

This guidance is intended to assist the pharmaceutical industry and other investigators who are conducting new drug development in assessing the potential for a drug2 to cause severe liver injury (i.e., irreversible liver failure that is fatal or requires liver transplantation). In particular, the guidance addresses how laboratory measurements that signal the potential for such druginduced liver injury (DILI) can be obtained and evaluated during drug development. This evaluation is important because most drugs that cause severe DILI do so infrequently; typical drug development databases with up to a few thousand subjects exposed to a new drug will not show any cases. Databases may, however, show evidence or signals of a drug’s potential for severe DILI if the clinical and laboratory data are properly evaluated for evidence of lesser injury that may not be severe, but may predict the ability to cause more severe injuries. This guidance describes an approach that can be used to distinguish signals of DILI that identify drugs likely to cause severe liver injury from signals that do not suggest such a potential. This guidance does not address issues of preclinical evaluation for signals of DILI, nor the detection and assessment of DILI after drug approval and marketing.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

4
Gene therapies

Excluded from the scope of this guidance

oral anticoagulant

ximelagatran is an oral anticoagulant

nonsteroidal anti-inflammatory drug

bromfenac was a nonsteroidal anti-inflammatory drug (NSAID)

Vaccines

Products for which batch/lot information is particularly important

Stakeholders

6
Pharmaceutical Industry

The intended audience for the guidance.

FDA advisory committee

discussed potential liver toxicity of ximelagatran in September 2004

Cardiovascular and Renal Drugs Advisory Committee

FDA advisory body reviewing Exanta

Applicant

Entity submitting development data and knowledge; Entity performing the work process for change

Applicants

Entities submitting supplements to BLAs

Trial investigators

Personnel who must receive local retesting results immediately

Regulatory Context

Regulatory Activities

5
NDA

New Drug Application

NDA 20-720

New Drug Application for Troglitazone

marketing approval

Trials conducted to support approval of drugs

IND

Investigational New Drug submissions

BLA

Biologics License Application

Document Types

5
Case Report Forms

Used to delineate dose and timing of administration

Dear Health Care Professional Letter

issued to warn about severe hepatotoxicity

package insert

User Safety Warnings section of the package insert

product labeling

Must conform to requirements of 21 CFR 107.10-107.30.

Narrative Summary

Required for each Hy's Law case and for subjects who died of hepatic illness.

Attributes

6
Dose-related

A characteristic of predictable toxicity often discovered in preclinical testing.

ALT elevations >3xULN

seen in 2.8 percent of patients on bromfenac

elevations of AT

marked elevations of aminotransferases as a signal of injury

Rule of 3

Statistical calculation used to estimate the upper limit of the rate for severe DILI.

Idiosyncratic

Term for reactions dependent upon an individual person's constitution.

ULN

Upper limit of normal used as a reference for laboratory abnormalities

Technical Details

Substances

10
Troglitazone

A drug withdrawn from the market due to hepatotoxicity.; drug associated with severe clinical and histologic hepatotoxicity; approved by the FDA in January 1997 for Type 2 diabetes mellitus

warfarin

Example drug with multiple serious drug interactions.

Fialuridine

associated with mitochondrial and cellular toxicity

Bromfenac

drug associated with acute liver failure and liver transplantation; nonsteroidal anti-inflammatory drug (NSAID) studied for analgesia and arthritis

CYP450 system

System responsible for oxidative metabolism of most hepatotoxic drugs.

Aminotransferases

Measured as AT, AST, or ALT to detect hepatocellular injury.

Ximelagatran

A novel anticoagulant tested against warfarin in the SPORTIF V study.; Compared with warfarin for prevention of thromboembolism.

Serum aminotransferases

Mild elevations are often seen during drug development.

Alanine aminotransferase

ALT values used to identify potential DILI candidates

Aspartate aminotransferase

Reflected as AST; used to indicate hepatocellular injury.

Testing Methods

10
Aminotransferase

Enzymes measured to detect leakage from injured liver cells.

serum testing

monitoring method for evidence of liver injury

Time-to-event analysis

used to account for differences in trial duration

Bilirubin

Combined elevations with aminotransferases are analyzed for DILI signals.

Liver Biopsy

A diagnostic procedure mentioned as having no pathognomonic findings for DILI.; Special study used to evaluate the nature of liver injury.

Plasma prothrombin time

A measure of liver function suggesting potential for severe injury.

ALT

Alanine aminotransferase monitored for liver injury.

AST

Aspartate aminotransferase monitored for liver injury.

ALP

Alkaline phosphatase test used to detect liver injury

TBL

Total bilirubin test used to detect liver injury

Processes

2
Drug Development

General Drug Development Considerations

Drug Metabolism

Assessment of how a drug is metabolized to hepatotoxic metabolites.

Clinical Concepts

10
Drug-Induced Liver Injury

Potential safety concern (DILI) in subjects with underlying liver disease.; Event requiring adjudication recorded in ZA domain; assessing potential DILI likelihood; To aid evaluation of potential DILI; potential DILI injury workup flags; Analysis of DILI injury and washout parameters

thromboembolic complications

prevention after joint replacement surgical procedures

hepatic encephalopathy

time from jaundice to hepatic encephalopathy was rapid

Type 2 diabetes mellitus

Insulin products intended for the treatment of patients with Type 2 diabetes

liver transplant

severe hepatic failure cases requiring liver transplant

Serious Unexpected Adverse Event

Events requiring prompt reporting to FDA.

Hy's Law

A signal used to identify drugs likely to cause severe liver injury.; A combination of AT and bilirubin elevations indicating potential for severe DILI.; used to predict the rate of severe drug-induced liver injury

Acute Liver Failure

Irreversible liver failure that is fatal or requires liver transplantation.; severe outcome of drug-induced liver injury; rates for bromfenac were estimated to be in the range of 1/10,000

Hepatotoxicity

Risk increased by concomitant use of hepatotoxic drugs with DRUG-X.

Cholestasis

A pattern of liver injury that is generally reversible.; Must be ruled out (indicated by elevated ALP) to identify Hy's Law cases.

Identified Hazards

Hazards

1
Hepatotoxicity

Potential harm from overdose due to dosing schedule deviation

Standards & References

Specifications

2
Upper limits of normal

Used as a baseline (ULN) for measuring enzyme elevations.

3xULN

Threshold for aminotransferase abnormalities signaling potential DILI.; threshold for ALT elevations in clinical trials

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)

Drug-Induced Liver Injury: Premarketing Clinical Evaluation | Guideline Explorer | BioRegHub