this event and minimize the implication that the formulation change results in a lower and more acceptable seizure rate.

 

PRECAUTIONS

 

The most significant changes I have made here are in the General Precautions subsection.  The sponsor has minimized several of the adverse findings noted in this section: agitation and insomnia; psychosis, etc., and appetite and weight changes.  Again, the difficulty is that the SR data are based on a generally lower dosage strategy than that used in the IR program.  I have proposed modifications in this section that illustrate more clearly the dose-relatedness for these findings and their equal relevance for the IR and SR formulations.

 

ADVERSE REACTIONS

 

The general problem with this section was the same a in the earlier sections, a failure to distinguish between the different doses of bupropion used in the IR and SR programs.  I have asked the sponsor to redo this section, focusing on the 2 pertinent fixed doses used in the SR program, i.e., 300 and 400 mg/day.

 

DOSAGE AND ADMINISTRATION

 

I have added back in the “General Dosing Considerations” statement that is in current labeling, since I feel it is as relevant for the SR as for the IR.  I have also modified dosing instructions to clarify that 300 mg/day, and not 150 mg/day, is the initial target dose for Wellbutrin.

 

 

3.0     CONCLUSIONS AND RECOMMENDATIONS

 

Given that the sponsor is now willing to recommend a dosing range for bupropion SR that is comparable to the range currently recommended for bupropion IR, I think we can consider this application approvable.  However, major work is still needed to develop labeling that will adequately inform clinicians about the risks and benefits of this drug, and I have proposed comments for a letter that emphasizes the discrepancy between the labeling they have proposed and what is needed.

 

 

cc:

Orig NDA 20-358

HFD-120/DivFile

HFd-120/TLaughren/PLeber/PAndreason/GDubitsky/PDavid

HFD-101/RTemple

 

DOC: MEMBRPSR.AE1

 

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