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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
- 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:
 | No torsade de pointes |
 | A rare incidence of a QTc interval >500 msec |
 | A well-characterized ECG
profile |
 | Postmarketing 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:
 | One 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."
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 | In 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:
- Immediately discontinue the use of these and any other promotional
materials and activities with the same or similar issues.
- 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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