-Charles
Hoppes and DMETS supervisory staff found the name and the educational materials
acceptable, however, Jerry Phillips still expressed a concern that there may be
confusion. The DMETS review included
several comments for the sponsor that will be conveyed in the approval letter.
-DDMAC
apparently found the name Wellbutrin XL acceptable from a promotional
perspective (no independent review, rather, just a note to this effect in the
DMETS review).
Mock-up of container labels to facilitate final evaluation of name and labels
-The
sponsor provided the mock-up container labels
-These
materials were submitted and found to be acceptable.
Full response to CMC deficiencies
-We
provided a list of deficiencies and the required responses.
-It
is my understanding that GSK has fully and satisfactorily responded to all CMC
deficiencies, and CMC staff have recommended final approval.
Adoption of proposed dissolution specifications
-We
proposed a dissolution method and specifications.
-
The sponsor provided justification for broadening the specification at 4 hours,
and OCPB has agreed with this change.
Literature search regarding potential drug interactions
-We
noted that there are recent in vitro data suggesting that certain SSRIs and
antiretroviral drugs may be inhibitors and/or substrates for CYP2B6, the enzyme
involved in the hydroxylation of bupropion.
Thus, we requested a literature search regarding this issue, and noted
that labeling may need modification, depending on what was found.
-The
sponsor conducted a literature search and presented the results, and an argument
that clinically significant interactions are unlikely. Sally Usdin and OCPB supervisory staff agree
that literature reports do not confirm significant interactions, not do they
rule them out. Thus, they argue that
some statement is needed in Drug Interactions to at least note the possibility
of such interactions. We have asked the
sponsor to adopt such a statement, and they have agreed.
Safety
update, including literature update
-We
requested a safety update, including an update on worldwide use of Wellbutrin
XL and a literature update on this product.
-The
sponsor provided a safety update including safety data from 6 ongoing or
completed studies (1 pk, 2 comparing effects on sexual functioning, 2 in
seasonal affective disorder, and 1 in adult ADHD). There were 3 SAEs, however, none could be reasonably attributed
to drug. There were 19 discontinuations
for adverse events; while for 15 of these the specific event was not listed, we
know they did not represent SAEs. There
was no indication of any important new safety findings that would impact on the
approvability of this product or on labeling.
-Wellbutrin XL is not approved anywhere at this time, and no published references regarding this product were found.
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