Title: OTC NSAIDs AND NEPHROTOXICITY Juan Carlos Pelayo, M.D. On Behalf Of The Division Of CardioRenal Drug
1OTC NSAIDsANDNEPHROTOXICITYJuan Carlos
Pelayo, M.D.On Behalf OfThe Division Of
Cardio-Renal Drug Products FDA OTC Advisory
Committee - September 20, 2002
2QUESTIONS TO ADDRESS
- ARE NON-PRESCRIPTION DOSES OF OTC NSAIDs
NEPHROTOXIC? - IF SO,
- WHAT IS THE OUTCOME OF A RISK-BENEFIT ANALYSIS?
3NSAID-INDUCED NEPHROTOXICITY(PRESCRIPTION DOSES)
- EDEMA
- HYPERKALEMIA
- ? BLOOD PRESSURE
- ? SERUM CREATININE / ARF
- PROTEINURIA / NS / INTERSTITIAL NEPHRITIS
- ACUTE PAPILLARY NECROSIS
- CRF
4AT RISK POPULATIONS
- VOLUME DEPLETION
- UNDERLYING KIDNEY DISEASE
- HEART FAILURE
- LIVER DYSFUNCTION WITH ASCITES
- ELDERLY
- PREGNANCY
5NSAID-INDUCED NEPHROTOXICITY(PRESCRIPTION DOSES)
- WHAT ARE THE RATES OF OCCURRENCE OF NSAID-RELATED
KIDNEY ADVERSE EVENTS FOR PRESCRIPTION DOSES?
6NSAID-INDUCED NEPHROTOXICITY(PRESCRIPTION DOSES)
- STUDY DESIGN
- PROSPECTIVE, RANDOMIZED, PLACEBO-CONTROLLED,
PARALLEL GROUP DESIGN - TREATMENT DURATION 18 WEEKS
- 361 HEALTHY SUBJECTS WITH OSTEOARTHRITIS WERE
EVALUATED PER GROUP - RENAL ADVERSE EVENTS AS REPORTED BY THE
INVESTIGATORS - IBUPROFEN 2400 mg/DAILY vs.. PLACEBO
7EDEMA18 Weeks
8HYPERKALEMIA 18 Weeks
9HYPERTENSION18 Weeks
10? SERUM CREATININE18 Weeks
11PROTEINURIA 18 Weeks
12NSAID-INDUCED NEPHROTOXICITY(PRESCRIPTION DOSES)
- ACUTE RENAL FAILURE 0
- INTERSTITIAL NEPHRITIS 0
- ACUTE PAPILLARY NECROSIS 0
13OTC NSAIDs
- IBUPROFEN (1984)
- Max. Dose 1200 mg/Daily (40 Prescription Dose)
- NAPROXEN (1994)
- Max. Dose 600 mg/Daily (40 Prescription Dose)
- KETOPROFEN (1995)
- Max. Dose 75 mg/Daily (25 Prescription Dose)
14NSAID-INDUCED NEPHROTOXICITY
- DOSE LEVEL vs. NEPHROTOXICITY?
15ASSESSMENT OF THE NEPHROTOXIC RISK ASSOCIATED
WITH OTC NSAIDs
- PROSPECTIVE, RANDOMIZED, PLACEBO-CONTROLLED AND
ADEQUATELY POWERED STUDIES COMPARING NON- vs.
PRESCRIPTION DOSES OF NSAIDs - HEALTHY POPULATION
- AT RISK POPULATIONS
16ASSESSMENT OF NEPHROTOXIC RISK ASSOCIATED WITH
OTC NSAIDs
- RETROSPECTIVE, UNCONTROLLED AND UNDERPOWERED
STUDIES - META-ANALYSES
- CASE REPORTS
17ASSESSMENT OF NEPHROTOXIC RISK ASSOCIATED WITH
OTC NSAIDs
- NATIONAL KIDNEY FOUNDATION
- DATABASE OF 556 ARTICLES ON ASPIRIN,
ACETOMINOPHEN, ASPIRIN-ACETOMINOPHEN
COMBINATIONS, AND NSAID-RELATED NEPHROTOXICITY.
18NATIONAL KIDNEY FOUNDATION POSITION PAPER (1996)
- RECOMMENDATION
- THERE SHOULD BE AN EXPLICIT LABEL WARNING
PATIENTS TAKING OVER-THE-COUNTER NSAIDs OF THE
POTENTIAL RENAL RISKS OF CONSUMING THE DRUGS. - American Journal of Kidney Disease, Vol 27, No
1, 1996pp 162-165.
19ASSESSMENT OF NEPHROTOXIC RISK ASSOCIATED WITH
OTC NSAIDs
- ADVERSE EVENT REPORTING SYSTEM
20AERS FOR RENAL FAILURE REPORTED FOR OTC NSAIDs
21RISK-BENEFIT ANALYSIS
- BENEFIT
- THE BENEFIT OBTAINED FROM THE USE OF OTC NSAIDs
ONLY RELATES TO THE RELIEF OF SYMPTOMS
22RISK-BENEFIT ANALYSIS
- RISK
- USE OF OTC NSAIDs CARRIES A NOMINAL RISK OF
NEPHROTOXICITY. - HOWEVER, THERE ARE NO DATA AVAILABLE TO
QUANTITATIVELY DEFINE THE RISK. THIS LACK OF
INFORMATION PREVENTS US FROM REACHING A
CONCLUSION ABOUT WHETHER THE RISK CHANGES WITH
DOSE.