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Released by FDA: 9/3/02.  Posted by FDA:  9/19/02

Ms. Rita A. Wittich
Vice President, Worldwide Regulatory Strategy
Regulatory Affairs
Pfizer, Inc.
235 East 42nd Street
New York, New York 10017-5755

Re:   NDA 20-825
        Geodon (ziprasidone HCI)
        MACMIS # 10790

Dear Ms. Wittich:

Through routine monitoring and surveillance, the Division of Drug Marketing, Advertising, and Communications (DDMAC) has identified promotional materials (GZ102859, GZ102857) for Geodon (ziprasidone HCl) that are in violation of the Federal Food, Drug, and Cosmetic Act and applicable regulations.  In addition, DDMAC has identified misleading oral statements regarding Geodon at Pfizer's promotional exhibit booth. at the annual meeting of the American Psychiatric Association (APA) held in Philadelphia, Pennsylvania in May 2002.

Specifically, DDMAC objects to the following claims and representations:

Promotional Materials

  1. Pfizer Inc. (Pfizer) has promoted Geodon in a manner that is misleading and lacking fair balance because it minimizes the important risk information regarding the greater capacity of Geodon to cause QT prolongation, and the potential to cause torsade de pointes-type arrhythmia and sudden death.  For example, DDMAC objects to the following claims by Pfizer:
     
    bulletNo torsade de pointes
    bulletA rare incidence of a QTc interval >500 msec
    bulletA well-characterized ECG profile
    bulletPostmarketing experience ...
    .......consistent with the Geodon clinical trial database

    These statements, isolated out of context by bulleting, headlining, or other means, are misleading because they suggest that Geodon is safer than has been demonstrated by substantial evidence.  The Indications and Usage section of the approved product labeling (PI) for Geodon states that ziprasidone has a "greater capacity to prolong the QT/QTc interval compared to several other antipsychotic drugs" and that this effect "is associated in some other drugs with the ability to cause torsade de pointes-type arrhythmia, a potentially fatal polymorphic ventricular tachycardia, and sudden death.  Whether ziprasidone will cause torsade de pointes or increase the rate of sudden death is not yet known." Furthermore, the bolded warning of the PI discusses the concern regarding QT prolongation, torsade de pointes, and the risk of sudden death, including the fact that although torsade de pointes has not been observed in pre-marketing studies, "experience is too limited to rule out an increased risk,"

    In addition, the bolded warning emphasizes the uncertainty regarding the ECG profile that may result from treatment with Geodon, as the association of QT prolongation and sudden death resulting from torsade de pointes is difficult to observe.  Finally, the claim that post-marketing experience is consistent with the clinical trial database implies that there is no risk of torsade de pointes and sudden death with Geodon when, in fact, data are very limited.  Pre-marketing and post-marketing exposure is insufficient to allow a conclusion that torsade de pointes will not occur.  Further, FDA has received several spontaneous reports of QT prolongation greater than 500 cosec, all indicative of a potential risk of this arrhythmia.  There are also reports of sudden death where the cause of death is not known, but could represent torsade de pointes even if unrecognized.  In sum, it is premature to conclude that Geodon does not present any risk of torsade de pointes.

    The brochure ID# GZ102859 presents these statements in the center of the back page (see also page 12) under the blue headlines "A well-characterized ECG profile" and "Postmarketing experience."  A bolded paragraph regarding the association of QT prolongation and torsade de pointes in other drugs is found at the bottom of the page.  Although this paragraph correctly acknowledges that Geodon has a greater capacity to prolong the QT interval than several antipsychotics, it states that "in some other drugs" QT prolongation has been associated with torsade de pointes, implying that this is not a concern with Geodon.  There is no mention that there is a specific concern with Geodon because the pre-marketing experience and post-marketing experience to date is too limited to rule out this risk.  Thus, this presentation is misleading because it claims that there is no torsade de pointes when this has not been demonstrated by substantial evidence and because it fails to accurately disclose the risk.

    The brochure ID# GZl02857 focuses on the effects of Geodon on the ECG profile and prominently displays the misleading statements listed above. The overall presentation of the four-page brochure minimizes concerns regarding Geodon's effect on cardiac arrhythmia and sudden death.  In addition, the risk information is not presented with a prominence and readability that is reasonably comparable to the presentation of how "well-characterized" the ECG profile is for Geodon.  Finally, the brochure fails to communicate that experience with Geodon is too limited to rule out the risk of torsade de pointes and sudden death.

Oral Representations

At Pfizer's promotional exhibit booth (entitled "The Geodon Challenge"), representatives engaged in violative promotional activities and disseminated violative promotional material.  Specifically, during a review of participant responses to a 12-question "knowledge" test for Geodon (ID# GZ110396), Pfizer representatives minimized important risk information regarding the greater capacity of Geodon to cause QT prolongation and the potential to cause sudden death, and misrepresented Geodon as having antidepressant effects similar to the selective serotonin reuptake inhibitors (SSRIs).

Furthermore, several questions on this "test" are misleading.  Examples of false or misleading claims in the promotional materials and oral representations include the following:

bulletOne question (Question #6) states that "Geodon has a well-characterized ECG profile with:  no torsade de pointes in clinical trials, a rare incidence of QTc interval >500 msec, no confirmed cases of torsade de pointes in postmarketing experience, and a low incidence of syncope and seizure."  Two Pfizer representatives at the Geodon Challenge activity stated that all of these choices were true.  One representative stated that "there have been no torsades or deaths" and that "we have not seen the QT risk that the label talks about."
 
bulletIn one case, the adverse event question prompted a general question regarding receptor interactions for Geodon.  The representative answered that Geodon bound to dopamine, adrenergic,; serotonin, and histamine receptors.  The representative then volunteered that Geodon "has antidepressant effects through SSRI [activity]."  This is misleading because Geodon is not indicated fox depression.

To address these objections, DDMAC requests that Pfizer do the following:

  1. Immediately discontinue the use of these and any other promotional materials and activities with the same or similar issues.
     
  2. Respond to this letter within ten days.  Your response should include a statement of your intent to comply with the above, a list of all promotional materials with the same or similar issues, and your methods for discontinuing these promotional materials.

If you have any questions or comments, please contact the undersigned by facsimile at (301) 5946771, or at the Food and Drug Administration, Division of Drug Marketing, Advertising and Communications, HFD-42, rm. 8B-45,5600 Fishers Lane, Rockville, MD 20857.  DDMAC reminds you that only written communications are considered official.

In all future correspondence regarding this particular matter, please refer to MACMIS ID # 10790 in addition to the NDA number.

Sincerely,

Lisa L. Stockbridge, Ph.D.
Regulatory Reviewer
Division of Drug Marketing,
   Advertising and Communications

 

 

 

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