Title: Safety of Herbal Preparations Herbal Medicinal Products
1Safety of Herbal Preparations/ Herbal Medicinal
Products
- Olavi Pelkonen
- Department of Pharmacology and Toxicology
- University of Oulu, Finland
- Co-opted member of HMPC, EMEA
The Toxicology Forum 2005 Annual European
Meeting, Brussels, Nov 8-10, 2005
2HMPC (Committee for Herbal Medicinal Products)
- First Meeting on September 23, 2004
- Chair elected Konstantin Keller (Germany)
- Vice chair elected Heribert Pittner (Austria)
- Meetings at EMEA 6 per year for 2 to 3 days
- 25 delegates and 25 alternates
- (1 per each EU Member State)
- Members from Norway and Iceland (with separate
counting of votes) - up to 5 additional co-opted members
3Goals of Regulation of Herbal Medicinal Products
in the European Union
- Harmonisation of requirements on quality, safety
and efficacy for herbal medicinal products - Improvement of pharmacovigilance for herbal
medicinal products - Facilitation of free movement of safe herbal
medicinal products within the European Union
4HMPC Drafting Groups
- Organisatory Matters (Chair E van Galen)
- Quality (Chair D Dempsey)
- Safety and Efficacy (Chair H Pittner)
-
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6Pharmacovigilance/Safety
- EMEA/HMPC/138139/05 Public Statement on the
allergenic potency of herbal medicinal products
containing soya or peanut protein (Released for
consultation April 2005)EMEA/HMPC/138379/05
Public Statement on Capsicum / capsaicin
containing herbal medicinal products (Released
for consultation April 2005)EMEA/HMPC/138309/05
Public Statement on Chamomilla containing herbal
medicinal products (Released for consultation
April 2005)EMEA/HMPC/138381/05 Public Statement
on the risks associated with the use of herbal
products containing Aristolochia species
(Released for consultation April
2005)EMEA/HMPC/137212/05 Public Statement on the
use of herbal medicinal products containing
estragole (Released for consultation April
2005)EMEA/HMPC/138363/05 Public Statement on the
use of herbal medicinal products containing
methyleugenol (Released for consultation April
2005)EMEA/HMPC/138386/05 Public Statement on the
use of herbal medicinal products containing
pulegone and menthofuran(Released for
consultation April 2005)EMEA/HMPC/139215/05
Public Statement on the use of herbal medicinal
products containing asarone (Released for
consultation April 2005)
http//www.emea.eu.int/htms/human/hmpc/hmpcguide.h
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7HMPC Drafting Group Safety Efficacy Agenda
- Draft guideline on non-clinical documentation for
well-established and traditional herbal medicinal
products (ongoing) - Draft guideline on assessment of clinical safety
and efficacy for well-established and traditional
herbal medicinal products (ongoing) - Draft guideline on clinical assessment of fixed
combinations of herbal substances / herbal
preparations (published for commenting) - Monographs and lists (5 2 published for
commenting)
8Community herbal monographs
- Definition
- Document the purpose of which is
- to provide a scientific summary of all data
available on the safety and efficacy of a herbal
substance / herbal preparation intended for
medicinal use and - to facilitate a harmonisation of marketing
authorisations / registrations throughout the EU
9Community herbal monograph
- According to SPC
- Name of the medicinal product
- Qualitative and quantitative composition
- Pharmaceutical form
- Clinical particulars
- 5. Pharmacological particulars
- (For traditional herbal medicinal products
information on pharmacological properties is not
required unless such data are available and
relevant for the safe use of the products) - 6. Date of compilation
10Community herbal monographSources
- ESCOP Monographs (European Scientific Cooperative
on Phytotherapy) - WHO Monographs
- European Pharmacopoeia
- Other Pharmacopoeias
- Any Published Literature
- other information available to national competent
authorities. e.g. pharmacovigilance data, studies
etc.
11Community herbal monographsWhich
substance/product first?
- Based on core-data created by the former
EMEA/CPMP Working Party on Herbal Medicinal
Products (HMPWP 1997 2004) - Proposals from AESGP (Association of the European
Self-Medication Industry) and other organisations - Final Decision by HMPC
12Community herbal monographs
- Valerian
- Linseed
- Ispaghula husk
- Ispaghula seed
- Psyllium seed
- Senna leaf
- Senna pods
13Alternative/complementary (drug-like) treatment
options
- Herbal medicinal products (well established vs
traditional) - Traditional preparations (European, Chinese,
Ayurvedic etc) - Outside the responsibility of the HMPC
- Nutraceuticals
- Nutrients/food supplements
- Homeopathic/anthroposophic products
14Safety concerns of old substances
- Old substances are widely used, but there are few
formal toxicological studies - Very little incentives to make such studies no
protection of data and intellectual property - Animal experiments are difficult to justify, if
only the "completeness of dossier is the goal - What is the value of past experience
15Possible solutions to safety concerns of old
substances
- Require formal studies (as pharmaceuticals
check-box approach) - Accept common experience / pharmacovigilance data
for safety assessment if no serious concerns - Mixed approach depending on a substance/
preparation and specific toxicity - Cause for concern toxicological threshold of
concern (TTC)
16Problem issues in safety assessment of old
substances
- Certain forms of toxicity not easily recognisable
in daily use - Genotoxicity/mutagenicity
- Carcinogenicity
- Reproductive toxicity
- Numerous potential interactions with
pharmaceuticals
17Mutagenicity/Genotoxicity
18Mutagenicity/Genotoxicity
- The "full set" of ICH/OECD genotoxicity tests
versus a reduced set of selected tests? - What is the absolute minimum for acceptance of a
registration/marketing authorisation of old
herbal substances - In current practice, no agency is asking for a
full genotoxicity testing programme
19Carcinogenicity
- In vivo carcinogenicity tests (24-month rat
study, 18-month mouse study) - TG or KO strains (short-term tests)
- Colony forming assays (transformation assays)
- Gap junction inhibition assays
20Safety of herbal products - status
- Boundaries between foods, herbals and
pharmaceuticals - Long experience vs formal toxicity studies
- Well-established vs traditional
- Cause for concern (vigilance signals)
- Hidden hazards
- Hazard assessment vs risk assessment