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Seanad Éireann debate -
Wednesday, 4 May 1994

Vol. 140 No. 6

Adjournment Matter. - Anti D Immunoglobulin and Hepatitis C.

I welcome the Minister to the House. While I am not under the illusion that the Members of the Seanad rely on me for medical opinions, because of my medical qualifications I try to be especially careful when speaking on health matters.

When the Minister spoke in the Seanad on 23 February on the Anti D immunoglobulin and hepatitis C problem, I supported all he had done. I praised him for alerting women rather than having them in a state of alarm and I praised the transparency of his Department in this situation. This was a contrast to the problems we have had in obtaining information in the past. I still support the line he has taken. I was delighted to see that in the programme, Shaping a healthier future — A strategy for effective healthcare in the 1990s, the Minister has set up an expert group to advise him on this problem.

While I support all he has done, I was under the impression when I spoke on 23 February that the Anti D immunoglobulin which was being introduced into the country to replace our own product, even though the latter appeared to be all right, had the approval of the US Food and Drugs Administration. This body was established about 50 years ago and has the highest standards for verifying the qualities of any drugs or products.

The Minister rightly stressed that from the date he learned of the problem with our own Anti D immunoglobulin, albeit in the past, one of his immediate concerns was the protection of all future recipients of the product. Quite rightly he said that despite everyone's best endeavours all over the world, the use of blood and blood products carry some risks and the benefits of treatment must be weighed against any risk.

For women who may have received Anti D, the benefit of treatment with Anti D immunoglobulin is enormous for Rhesus negative women who give birth to Rhesus positive children. I am old enough to remember in the 1960s the sad situation of it being virtually impossible for women who had one Rhesus positive child to have subsequent children; there could be subsequent miscarriages, stillbirths or the birth of children with brain damage.

While I am not suggesting that the product involved here — WinRho — is in any way suspect, I would have asked far more questions on 23 February if I had not been under the impression that it had FDA approval. I realised it could not have been evaluated in this country because it was brought in over a weekend and there was no possibility of the National Drugs Advisory Board being able to evaluate it in such a short period. We cannot expect everything to be evaluated by the board. One must consider not only the number of products but also that we could lose out on very good drugs because it costs money to have a drug evaluated by the NDAB. If the company involved does not think it is worth while having a drug investigated, we might lose out. I find it perfectly acceptable that the product might not have been evaluated by the board.

Last week I visited the FDA in Washington about a different matter. While there, I discussed with FDA officials the Anti D products which are available. To my astonishment I found out that WinRho did not have FDA approval but that approval was pending and it might be a month or more before a definite decision was made. While I cannot definitely say that this is why it is pending, I got the impression from my detailed discussion with the officials — they discussed with me methods of production and I believe the method of production of WinRho is very similar to our own — that the delay was probably because the manufacturers of WinRho had asked for a second use for it, that is, in the treatment of idiopathic thrombocytopaenic purpura. This is an unusual condition. The delay has probably occurred because the FDA insists that not only should a drug be safe but it should also be efficacious.

On my return, I immediately wrote to the Minister to ask him to check the FDA status of WinRho and asked when he spoke in both Houses on the topic, did he think it had FDA approval. On Saturday morning one of his officials kindly phoned me. This showed that the Minister took immediate action, for which I was grateful. I know it was impossible to contact the FDA for some time because it was closed due to the funeral of Richard Nixon, former President of the USA. The official told me that I was right in saying approval was pending. Because I had been so positive in my support for the Minister's actions, I felt I should inform the House as soon as possible — which is today — that, while I stress I have no reason to be suspicious of the drug, I would be grateful if the Minister would clarify its international status. There are three FDA approved Anti D immunoglobulins widely in use in the United States. I do not know why one of them or one of the well monitored European brands was not chosen. Is WinRho considered to be the drug of choice in the USA and Europe?

Contamination of blood products by hepatitis C appears to be of international concern. I am sure this is being carefully monitored by the Minister and his Department. I do not suggest that these are fly-by-night products. An extremely good gamma globulin called Gammagrad had to be withdrawn the other day because of contamination by hepatitis C. This is a difficult problem. If we are not producing a drug what criteria do we lay down before we accept products from abroad? Do we require FDA approval or do we seek approval from another well established authority in Europe? I am not suggesting that Canadian approval is inadequate, but I would be very grateful for clarification. Should we not aim for the highest standard? The FDA is reckoned to be the gold standard for approvals. Thanks to the vigilance of the FDA, there are no thalidomide children in the USA. Unless we have an emergency, we should go for the highest possible approval status of any drug we might import.

I thank Senator Henry for raising this matter. I know she shares my concern that the highest possible standards are applied to every product made available in this country. This is our joint purpose.

The Seanad will be familiar with the background which gave rise to the urgent need for the Blood Transfusion Service Board to do find alternative sources of Anti-D immunoglobulin to meet the needs of Irish patients following the recently identified risk of hepatitis C infection from the product then in use.

Following extensive inquiries by the Blood Transfusion Service Board for a suitable replacement product, I understand the board decided that the most appropriate one available was that which could be supplied by the Canadian company, Rh Pharmaceuticals Inc., under the name WinRho SD.

I have been informed that the product is licensed for general supply in Canada by the Canadian Ministry of Health and Welfare and that the manufacturing facility of the company is licensed and subject to periodic inspection by the Canadian authorities. I understand also that an application for licensing approval by the United States Food and Drugs Administration is still under consideration.

I have been informed also that the product has been sold in ten countries on four continents without license on the same lines as the exceptional permission arrangements provided for in the Irish regulations. This arrangement allows a product, which has not been licensed by the Minister for Health, to be supplied by a doctor to a patient under his or her professional care. These countries include the UK, US, Saudi Arabia, Germany and France. The position in Ireland is that an application for a product authorisation in respect of the product is currently being assessed as a matter of priority by the National Drugs Advisory Board.

Notwithstanding the fact that the product is licensed for use in Canada, it is necessary that a full and detailed assessment be carried out by the NDAB before product authorisation is issued in this country. However, as I have already stated, the process of such assessment is being treated as a priority by the NDAB and an early decision is expected.

In the mean time, the product is being made available to patients on what is commonly referred to as "a named-patient basis". Under the Medical Preparation (Licensing, Advertisement and Sale) Regulations, 1984, a medical preparation may normally only be supplied provided it is the subject of a product authorisation granted under the regulations. The normal criteria for the granting of such an authorisation is that the Minister for Health be satisfied on the advice of the National Drugs Advisory Board as to the safety, efficacy and quality of the product.

However, under article 5 (b) of the regulations, the requirement for a product authorisation shall not apply in respect of "the importation or sale of a medical preparation by or to the order of a registered medical practitioner or registered dentist for the treatment of a patient under his care". It is under this provision that the product is currently being supplied here pending full assessment of the application for a product authorisation by the National Drugs Advisory Board.

It is essential that an Anti D product be available in order to save lives and I recognise the importance which the Senator attached to this. As I indicated earlier, this product has been licensed in Canada and used in ten countries and the National Drugs Advisory Board is carrying out a thorough examination which is being conducted as speedily as possible.

I thank the Minister for his reply and I know his concern is as great as my own. Frankly, I do not think the situation is satisfactory. It is entirely unsatisfactory to have something still being supplied on a named patient basis to thousands of women three months after it has come into the country. I have used drugs on a named patient basis on, let us say, five or six patients a year. This is what is meant by "on a named patient basis". I know the Minister knows this; I am not getting at him about this. I do not care if it is used in 500 countries. It appears to me to have only one authorisation, which is in Canada.

My only concern on hearing that there was a doubt about the Anti D immunoglobulin in use in Ireland was to have an absolutely safe alternative. That was my instruction to the Blood Transfusion Service Board. Its advice was that this is the best product available. It is virally inactivated in the most sophisticated way possible using solvent detergent. As the process is new the level of technology needs to be assessed. It has been assessed and approved in its country of origin, that is, Canada. The professional advice which I was given by the experts is that this is the most suitable product. That was their recommendation which I must obviously approve.

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