CENTER FOR DRUG EVALUATION AND
`RESEARCH
`
`
`
`APPLICATION NUMBER:
`203168Orig1s000
`
`
`PROPRIETARY NAME REVIEW(S)
`
`
`
`
`
`

`

`Department of Health and Human Services
`Public Health Service
`Food and Drug Administration
`Center for Drug Evaluation and Research
`Office of Surveillance and Epidemiology
`Office of Medication Error Prevention and Risk Management
`
`Date:
`
`Reviewer:
`
`Team Leader:
`
`Drug Name and Strength:
`Application Type/Number:
`Applicant:
`OSE RCM #:
`
`
`
`
`
`
`
`
`
`
`
`Proprietary Name Review--Final
`
`March 4, 2013
`
`
`
`Jung Lee, RPh
`Division of Medication Error Prevention and Analysis
`Jamie Wilkins Parker, PharmD
`Division of Medication Error Prevention and Analysis
`Prolensa (Bromfenac Ophthalmic Solution), 0.07%
`NDA 203168
`Bausch & Lomb, Inc
`2012-2787
`
`*** This document contains proprietary and confidential information that should not be released to
`the public.***
`
`Reference ID: 3270876
`
`1
`
`

`

`CONTENTS
`
`INTRODUCTION......................................................................................................................................... 3
`1
`2 METHODS AND DISCUSSION.................................................................................................................. 3
`3
`CONCLUSIONS........................................................................................................................................... 3
`4
`REFERENCES.............................................................................................................................................. 4
`
`Reference ID: 3270876
`
`2
`
`

`

`INTRODUCTION
`1
`This re-assessment of the proposed proprietary name, Prolensa is written in response to the anticipated
`approval of this NDA within 90 days from the date of this review. DMEPA found the proposed
`name, Prolensa, acceptable in OSE Review #2012-2056 dated November 6, 2012.
`
`2 METHODS AND DISCUSSION
`For re-assessments of proposed proprietary names, DMEPA searches a standard set of databases and
`information sources (see section 4) to identify names with orthographic and phonetic similarity to the
`proposed name that have been approved since the previous OSE proprietary name review. For this
`review we used the same search criteria described in OSE Review #2012-2056. We note that none of
`the proposed product characteristics were altered. However, we evaluated the previously identified
`names of concern considering any lessons learned from recent post-marketing experience, which may
`have altered our previous conclusion regarding the acceptability of the proposed proprietary name.
`The searches of the databases yielded one new name
` thought to look or sound similar to
`Prolensa and represent a potential source of drug name confusion. Failure mode and effects analysis
`was applied to determine if the proposed proprietary name could potentially be confused with
`Prolensa and lead to medication errors. This analysis determined that the name similarity between
`Prolensa and the identified name was unlikely to result in medication error for the reasons presented
`in Appendix A.
`Additionally, DMEPA searched the USAN stem list to determine if the name contains any USAN
`stems as of the last USAN updates. The Safety Evaluator did not identify any United States Adopted
`Names (USAN) stems in the proposed proprietary name, as of January 4, 2013. The Office of
`Prescription Drug Promotion OPDP re-reviewed the proposed name on January 10, 2013 and had no
`concerns regarding the proposed name from a promotional perspective.
`
`3 CONCLUSIONS
`The re-evaluation of the proposed proprietary name, Prolensa, did not identify any vulnerabilities that
`would result in medication errors with any additional names noted in this review. Thus, DMEPA has
`no objection to the proprietary name, Prolensa, for this product at this time.
`DMEPA considers this a final review; however, if approval of the NDA is delayed beyond 90 days
`from the date of this review, the Division of Transplant and Ophthalmology Products should notify
`DMEPA because the proprietary name must be re-reviewed prior to the new approval date.
`If you have further questions or need clarifications, please contact Karen Townsend, OSE project
`manager, at 301-796-5413.
`
`
`*** This document contains proprietary information that should not be released to the public
`
`Reference ID: 3270876
`
`3
`
`(b) (4)
`
`

`

`4 REFERENCES
`1.
`Lee, J; OSE Review 2012-2056, Proprietary Name Review of Prolensa; November 6, 2012
`2.
`Lee, J; OSE Review 2012-471, Proprietary Name Reconsideration Review; May 4, 2012
`3.
`Lee, J; OSE Review 2011-2415, Proprietary Name Review of Prolensa; December 12, 2011
`
`4.
`
`5.
`
`6.
`
`Drugs@FDA (http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm)
`Drugs@FDA contains most of the drug products approved since 1939. The majority of labels,
`approval letters, reviews, and other information are available for drug products approved from 1998 to
`the present. Drugs@FDA contains official information about FDA approved brand name, generic
`drugs, therapeutic biological products, prescription and over-the-counter human drugs and discontinued
`drugs and “Chemical Type 6” approvals.
`
`USAN Stems (http://www.ama-assn.org/ama/pub/physician-resources/medical-science/united-states-
`adopted-names-council/naming-guidelines/approved-stems.page?)
`USAN Stems List contains all the recognized USAN stems.
`
`Division of Medication Error Prevention and Analysis Proprietary Name Consultation Request
`Compiled list of proposed proprietary names submitted to the Division of Medication Error Prevention
`and Analysis for review. The list is generated on a weekly basis from the Access database/tracking
`system.
`
`Reference ID: 3270876
`
`4
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`

`

`Amndix A: Risk of medication errors due to product confusion minimized by dissimilarity of the names
`and/ or use in clinical practice for the reasons described. (n=1)
`
`
`
`m This document contains proprietary information that should not be released to the public
`
`Reference ID: 3270876
`
`

`

`---------------------------------------------------------------------------------------------------------
`This is a representation of an electronic record that was signed
`electronically and this page is the manifestation of the electronic
`signature.
`---------------------------------------------------------------------------------------------------------
`/s/
`----------------------------------------------------
`JUNG E LEE
`03/04/2013
`
`JAMIE C WILKINS PARKER
`03/04/2013
`
`Reference ID: 3270876
`
`

`

`Department of Health and Human Services
`Public Health Service
`Food and Drug Administration
`Center for Drug Evaluation and Research
`Office of Surveillance and Epidemiology
`Office of Medication Error Prevention and Risk Management
`
`Proprietary Name Review
`
`Date:
`
`November 6, 2012
`
`Jung Lee, RPh
`Reviewer:
`Division of Medication Error Prevention and Analysis
`
`Zachary Oleszczuk, PharmD
`Team Leader:
`Division of Medication Error Prevention and Analysis
`
`Carol Holquist, RPh
`Division Director:
`Division of Medication Error Prevention and Analysis
`
`Prolensa (Bromfenac Ophthalmic Solution), 0.07%
`Drug Name and Strength:
`Application Type/Number: NDA 203168
`Applicant:
`Bausch & Lomb, Inc
`OSE RCM #:
`2012-2056
`
`
`
`*** This document contains proprietary and confidential information that should not be
`released to the public.***
`
`Reference ID: 3213544
`
`

`

`1
`
`CONTENTS
`
`2
`
`INTRODUCTION................................................................................................................... 1
`1.1
`Regulatory History......................................................................................................... 1
`1.2
`Product Information ....................................................................................................... 1
`RESULTS................................................................................................................................ 2
`2.1
`Promotional Assessment................................................................................................ 2
`2.2
`Safety Assessment.......................................................................................................... 2
`CONCLUSIONS ..................................................................................................................... 4
`3.1
`Comments to the Applicant............................................................................................ 4
`REFERENCES........................................................................................................................ 5
`4
`APPENDICES................................................................................................................................. 8
`
`3
`
`Reference ID: 3213544
`
`

`

`INTRODUCTION
`1
`This review evaluates the proposed proprietary name, Prolensa, from a safety and
`promotional perspective. The sources and methods used to evaluate the proposed name
`are outlined in the reference section and Appendix A respectively.
`
`REGULATORY HISTORY
`1.1
`On June 27, 2011, the Sponsor submitted a request for a proprietary name review of the
`name Prolensa (Bromfenac Ophthalmic Solution) with a new strength, 0.07% and a
`similar once-a-day dosing regimen to Bromday. The Division of Medication Error
`Prevention and Analysis (DMEPA) found the proposed name, Prolensa, unacceptable in
`OSE Review 2011-2415 based on the names Prolens and Prolinic. The Sponsor was
`notified of our decision in a letter dated December 21, 2011. The Sponsor submitted a
`request for reconsideration of the proposed proprietary name, Prolensa, on February 20,
`2012. Based on our evaluation of the data submitted by the Sponsor, we determined that
`the information supports the claim that the names Prolens and Prolinic will not pose a
`risk for confusion with Prolensa. Thus, on May 4, 2012, DMEPA found the name
`acceptable under the IND in OSE Review 2012-471.
`On August 31, 2012, the Applicant submitted a Request for Proprietary Name Review for
`the proposed name, Prolensa under the NDA.
`
`PRODUCT INFORMATION
`1.2
`The following product information is provided in the August 31, 2012 proprietary name
`submission.
`• Active Ingredient: Bromfenac
`•
`Indication of Use: Treatment of postoperative inflammation and reduction of
`ocular pain in patients who have undergone cataract extraction
`• Route of Administration: Ophthalmic
`• Dosage Form: Solution
`• Strength: 0.07%
`• Dose and Frequency: One drop into the affected eye once daily beginning 1 day
`prior to surgery, continued on the day of surgery, and through the first 14 days of
`post-surgery
`• How Supplied: 1.6 mL and 3 mL in a 7.5 mL container
`• Storage: Store at -15°C to 25°C (59°F to 77°F)
`• Container and Closure System: White LDPE plastic squeeze bottle with a 15 mm
` dropper-tip and 15 mm
` gray cap. The gray cap color is
`consistent with the American Academy of Ophthalmology’s policy statement
`“Color Code for Ocular Medications” which recommends the gray cap color for
`nonsteroidal anti-inflammatories (NSAIDS).
`
`Reference ID: 3213544
`
`1
`
`(b) (4)
`
`(b) (4)
`
`

`

`RESULTS
`2.
`The following sections provide the information obtained and considered in the overall
`evaluation of the proposed proprietary name.
`2.1
`PROMOTIONAL ASSESSMENT
`The Office of Prescription Drug Promotion OPDP determined the proposed name is
`acceptable from a promotional perspective. DMEPA and the Division of Transplant and
`Ophthalmology Products concurred with the findings of OPDP’s promotional assessment
`of the proposed name.
`
`SAFETY ASSESSMENT
`2.2
`The following aspects of the name were considered in the overall safety evaluation.
`
`2.2.1 United States Adopted Names (USAN) SEARCH
`The September 28, 2012 search of the United States Adopted Name (USAN) stems did
`not identify that a USAN stem is present in the proposed proprietary name.
`
`2.2.2 Components of the Proposed Proprietary Name
`The proposed proprietary name, Prolensa, is comprised of a single word. According to
`the Applicant, the derivation of the name Prolensa is from the word lens. The Applicant
`states this product is an ophthalmic solution intended to be used for cataract surgery
`where the natural human lens is replaced by an intraocular lens; therefore, the name and
`derivation of the name seems appropriate for this product.
`
`2.2.3 FDA Name Simulation Studies
`Ninety-seven practitioners participated in DMEPA’s prescription studies. The
`interpretations did not overlap with or appear or sound similar to any currently marketed
`products. Most of the outpatient participants (33 out of 34) correctly interpreted the
`name Prolensa with the exception of one participant who omitted the letter ‘s’ in the
`name. Of the inpatient participants, 22 out of 32 participants correctly interpreted the
`name; however, one participant incorrectly stated the dosage form as “tablets” instead of
`“drops”. Only 3 of the verbal participants interpreted the name Prolensa correctly. The
`majority misinterpreted the letter ‘s’ for the letter ‘z’ or the letter ‘e’ for the letter ‘i’. See
`Appendix C for the complete listing of interpretations from the verbal and written
`prescription studies.
`
`2.2.4 Comments from Other Review Disciplines
`In response to the OSE, September 19, 2012 e-mail, the Division of Transplant and
`Ophthalmology Products (DTOP) did not forward any comments or concerns relating to
`the proposed name at the initial phase of the proprietary name review.
`
`2.2.5 Previously Completed Reviews
`Because the proposed product characteristics have not changed since our previous
`reviews, we evaluated all the names in the previous reviews considering lessons learned
`
`Reference ID: 3213544
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`2
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`

`

`from recent post—marketing experience which may have altered our previous conclusion
`on the acceptability of the proposed proprietary name. We did not identify any new
`concerns with the previously identified names in our previous reviews. Thus, section
`2.2.6 identifies any new names not previously identified for evaluation of the proposed
`proprietary name.
`
`2.2. 6 Failure Mode and Effects Analysis ofSimilar Names to Prolensa
`
`Appendix B lists possible orthographic and phonetic misinterpretations of the letters
`appearing in the proposed proprietary name, Prolensa. Table 1 lists the names with
`orthographic, phonetic, or spelling similarity to the proposed proprietary name, Prolensa
`identified by the primary reviewer, the Expert Panel Discussion (EPD), and other review
`disciplines.
`
`Table 1: Collective List of Potentially Similar Names (DMEPA, EPD, and Other
`Disciplines)
`
`Look Similar
`
`Name
`
`Source
`
`Name
`
`Source
`
`Name
`
`Source
`
`Patanase
`
`FDA
`
`Profen
`
`FDA
`
`Proloid
`
`"”
`
`FDA
`
`ProfenLA
`
`FDA
`
`Prefiin-A
`
`FDA
`
`Profenal
`
`FDA
`
`Protuss
`
`Pruclair
`
`FDA
`
`FDA
`
`FDA
`
`Prelan
`
`Pretema
`
`FDA
`
`Proflora
`
`FDA _D__FD_
`
`Rescula
`
`prelude.
`
`FDA ____
`
`Sound Similar
`
`Our analysis of the 14 names contained in Table 1 considered the information obtained in
`the previous sections along with their product characteristics. We determined 14 names
`will not pose a risk for confusion as described in Appendices D through E.
`
`2.2.6 Communication ofDMEPA ’s Final Decision to Other Disciplines
`
`DMEPA communicated our findings to the Division of Transplant and Ophthahnology
`Products via e-mail on October 23, 2012. At that time we also requested additional
`information or concerns that could inform our review. Per e-mail correspondence from
`the Division of Transplant and Ophthalmology Products on October 31, 2012, they stated
`no additional concerns with the proposed proprietary name, Prolensa.
`
`888
`
`This document contains proprietary information that should not be released to the public
`
`Reference ID: 3213544
`
`3
`
`

`

`CONCLUSIONS
`3
`The proposed proprietary name is acceptable from both a promotional and safety
`perspective.
`If you have further questions or need clarifications, please contact Karen Townsend, OSE
`project manager, at 301-796-5413.
`
`COMMENTS TO THE APPLICANT
`3.1
`We have completed our review of the proposed proprietary name, Prolensa, and have
`concluded that this name is acceptable. However, if any of the proposed product
`characteristics as stated in your August 31, 2012 submission are altered, the name must
`be resubmitted for review.
`Additionally, the proposed proprietary name must be re-reviewed 90 days prior to
`approval of the NDA. The conclusions upon re-review are subject to change.
`
`Reference ID: 3213544
`
`4
`
`

`

`4
`
`REFERENCES
`
`1. Micromedex Integrated Index (http://csi.micromedex.com)
`Micromedex contains a variety of databases covering pharmacology, therapeutics,
`toxicology and diagnostics.
`
`2. Phonetic and Orthographic Computer Analysis (POCA)
`POCA is a database which was created for the Division of Medication Error
`Prevention and Analysis, FDA. As part of the name similarity assessment, proposed
`names are evaluated via a phonetic/orthographic algorithm. The proposed proprietary
`name is converted into its phonemic representation before it runs through the phonetic
`algorithm. Likewise, an orthographic algorithm exists which operates in a similar
`fashion.
`
`3. Drug Facts and Comparisons, online version, St. Louis, MO
`(http://factsandcomparisons.com)
`Drug Facts and Comparisons is a compendium organized by therapeutic course; it
`contains monographs on prescription and OTC drugs, with charts comparing similar
`products. This database also lists the orphan drugs.
`
`4. FDA Document Archiving, Reporting & Regulatory Tracking System [DARRTS]
`DARRTS is a government database used to organize Applicant and Sponsor
`submissions as well as to store and organize assignments, reviews, and
`communications from the review divisions.
`
`5. Division of Medication Errors Prevention and Analysis proprietary name
`consultation requests
`This is a list of proposed and pending names that is generated by the Division of
`Medication Error Prevention and Analysis from the Access database/tracking system.
`
`6. Drugs@FDA (http://www.accessdata.fda.gov/scripts/cder/drugsatfda/index.cfm)
`Drugs@FDA contains most of the drug products approved since 1939. The majority of
`labels, approval letters, reviews, and other information are available for drug products
`approved from 1998 to the present. Drugs@FDA contains official information about FDA
`approved brand name, generic drugs, therapeutic biological products, prescription and over-
`the-counter human drugs and discontinued drugs and “Chemical Type 6” approvals.
`7. U.S. Patent and Trademark Office (http://www.uspto.gov)
`USPTO provides information regarding patent and trademarks.
`
`8. Clinical Pharmacology Online (www.clinicalpharmacology-ip.com)
`Clinical Pharmacology contains full monographs for the most common drugs in
`clinical use, plus mini monographs covering investigational, less common,
`
`Reference ID: 3213544
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`5
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`

`

`combination, nutraceutical and nutritional products. It also provides a keyword search
`engine.
`
`9. Data provided by Thomson & Thomson’s SAEGIS ™ Online Service, available at
`(www.thomson-thomson.com)
`The Pharma In-Use Search database contains over 400,000 unique pharmaceutical
`trademarks and trade names that are used in about 50 countries worldwide. The data
`is provided under license by IMS HEALTH.
`
`10. Natural Medicines Comprehensive Databases (www.naturaldatabase.com)
`Natural Medicines contains up-to-date clinical data on the natural medicines, herbal
`medicines, and dietary supplements used in the western world.
`
`11. Access Medicine (www.accessmedicine.com)
`Access Medicine® from McGraw-Hill contains full-text information from
`approximately 60 titles; it includes tables and references. Among the titles are:
`Harrison’s Principles of Internal Medicine, Basic & Clinical Pharmacology, and
`Goodman and Gilman’s The Pharmacologic Basis of Therapeutics.
`
`12. USAN Stems (http://www.ama-assn.org/ama/pub/about-ama/our-people/coalitions-
`consortiums/united-states-adopted-names-council/naming-guidelines/approved-
`stems.shtml)
`USAN Stems List contains all the recognized USAN stems.
`
`13. Red Book (www.thomsonhc.com/home/dispatch)
`Red Book contains prices and product information for prescription, over-the-counter
`drugs, medical devices, and accessories.
`
`14. Lexi-Comp (www.lexi.com)
`Lexi-Comp is a web-based searchable version of the Drug Information Handbook.
`
`15. Medical Abbreviations (www.medilexicon.com)
`Medical Abbreviations dictionary contains commonly used medical abbreviations and
`their definitions.
`
`16. CVS/Pharmacy (www.CVS.com)
`This database contains commonly used over the counter products not usually
`identified in other databases.
`
`17. Walgreens (www.walgreens.com)
`This database contains commonly used over the counter products not usually
`identified in other databases.
`
`Reference ID: 3213544
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`

`18. Rx List (www.rxlist.com)
`RxList is an online medical resource dedicated to offering detailed and current
`pharmaceutical information on brand and generic drugs.
`
`19. Dogpile (www.dogpile.com)
`Dogpile is a Metasearch engine that searches multiple search engines including
`Google, Yahoo! and Bing, and returns the most relevant results to the search.
`
`20. Natural Standard (http://www.naturalstandard.com)
`Natural Standard is a resource that aggregates and synthesizes data on complementary
`and alternative medicine.
`
`Reference ID: 3213544
`
`7
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`

`

`APPENDICES
`Appendix A
`FDA’s Proprietary Name Risk Assessment considers the promotional and safety aspects
`of a proposed proprietary name. The promotional review of the proposed name is
`conducted by OPDP. OPDP evaluates proposed proprietary names to determine if they
`are overly fanciful, so as to misleadingly imply unique effectiveness or composition, as
`well as to assess whether they contribute to overstatement of product efficacy,
`minimization of risk, broadening of product indications, or making of unsubstantiated
`superiority claims. OPDP provides their opinion to DMEPA for consideration in the
`overall acceptability of the proposed proprietary name.
`The safety assessment is conducted by DMEPA. DMEPA staff search a standard set of
`databases and information sources to identify names that are similar in pronunciation,
`spelling, and orthographically similar when scripted to the proposed proprietary name.
`Additionally, we consider inclusion of USAN stems or other characteristics that when
`incorporated into a proprietary name may cause or contribute to medication errors (i.e.,
`dosing interval, dosage form/route of administration, medical or product name
`abbreviations, names that include or suggest the composition of the drug product, etc.).
`DMEPA defines a medication error as any preventable event that may cause or lead to
`inappropriate medication use or patient harm while the medication is in the control of the
`health care professional, patient, or consumer. 1
`Following the preliminary screening of the proposed proprietary name, DMEPA gathers
`to discuss their professional opinions on the safety of the proposed proprietary name.
`This meeting is commonly referred to the Center for Drug Evaluation and Research
`(CDER) Expert Panel discussion. DMEPA also considers other aspects of the name that
`may be misleading from a safety perspective. DMEPA staff conducts a prescription
`simulation studies using FDA health care professionals. When provided, DMEPA
`considers external proprietary name studies conducted by or for the Applicant/Sponsor
`and incorporates the findings of these studies into the overall risk assessment.
`The DMEPA primary reviewer assigned to evaluate the proposed proprietary name is
`responsible for considering the collective findings, and provides an overall risk
`assessment of the proposed proprietary name. DMEPA bases the overall risk assessment
`on the findings of a Failure Mode and Effects Analysis (FMEA) of the proprietary name
`and misleading nature of the proposed proprietary name with a focus on the avoidance of
`medication errors.
`DMEPA uses the clinical expertise of its staff to anticipate the conditions of the clinical
`setting where the product is likely to be used based on the characteristics of the proposed
`product. DMEPA considers the product characteristics associated with the proposed
`product throughout the risk assessment because the product characteristics of the
`proposed may provide a context for communication of the drug name and ultimately
`determine the use of the product in the usual clinical practice setting.
`
`1 National Coordinating Council for Medication Error Reporting and Prevention.
`http://www nccmerp.org/aboutMedErrors html. Last accessed 10/11/2007.
`
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`

`Typical product characteristics considered when identifying drug names that could
`potentially be confused with the proposed proprietary name include, but are not limited
`to; established name of the proposed product, proposed indication of use, dosage form,
`route of administration, strength, unit of measure, dosage units, recommended dose,
`typical quantity or volume, frequency of administration, product packaging, storage
`conditions, patient population, and prescriber population. DMEPA considers how these
`product characteristics may or may not be present in communicating a product name
`throughout the medication use system. Because drug name confusion can occur at any
`point in the medication use process, DMEPA considers the potential for confusion
`throughout the entire U.S. medication use process, including drug procurement,
`prescribing and ordering, dispensing, administration, and monitoring the impact of the
`medication.2
`The DMEPA considers the spelling of the name, pronunciation of the name when spoken, and
`appearance of the name when scripted. DMEPA compares the proposed proprietary name
`with the proprietary and established name of existing and proposed drug products and names
`currently under review at the FDA. DMEPA compares the pronunciation of the proposed
`proprietary name with the pronunciation of other drug names because verbal communication
`of medication names is common in clinical settings. DMEPA examines the phonetic
`similarity using patterns of speech. If provided, DMEPA will consider the Sponsor’s intended
`pronunciation of the proprietary name. However, DMEPA also considers a variety of
`pronunciations that could occur in the English language because the Sponsor has little control
`over how the name will be spoken in clinical practice. The orthographic appearance of the
`proposed name is evaluated using a number of different handwriting samples. DMEPA
`applies expertise gained from root-cause analysis of postmarketing medication errors to
`identify sources of ambiguity within the name that could be introduced when scripting
`(e.g.,“T” may look like “F,” lower case ‘a’ looks like a lower case ‘u,’ etc). Additionally,
`other orthographic attributes that determine the overall appearance of the drug name when
`scripted (see Table 1 below for details).
`
`
`2 Institute of Medicine. Preventing Medication Errors. The National Academies Press: Washington DC.
`2006.
`
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`

`Table 1. Criteria Used to Identify Drug Names that Look- or Sound-Similar to a
`Proposed Proprietary Name.
`
`Considerations when Searching the Databases
`
`Attributes Examined to Identify
`Similar Drug Names
`
`Potential Effects
`
`Identical prefix
`Identical infix
`Identical suffix
`Length of the name
`Overlapping product
`characteristics
`
`• Names may appear similar
`in print or electronic media
`and lead to drug name
`confusion in printed or
`electronic communication
`• Names may look similar
`when scripted and lead to
`drug name confusion in
`written communication
`• Names may look similar
`when scripted, and lead to
`drug name confusion in
`written communication
`
`• Names may sound similar
`when pronounced and lead
`to drug name confusion in
`verbal communication
`
`Type of
`Similarity
`
`Potential
`Causes of Drug
`Name
`Similarity
`
`Similar spelling
`
`Look-
`alike
`
`Orthographic
`similarity
`
`Sound-
`alike
`
`Phonetic
`similarity
`
`Similar spelling
`Length of the name/Similar
`shape
`Upstrokes
`Down strokes
`Cross-strokes
`Dotted letters
`Ambiguity introduced by
`scripting letters
`Overlapping product
`characteristics
`Identical prefix
`Identical infix
`Identical suffix
`Number of syllables
`Stresses
`Placement of vowel sounds
`Placement of consonant sounds
`Overlapping product
`characteristics
`Lastly, DMEPA considers the potential for the proposed proprietary name to
`inadvertently function as a source of error for reasons other than name confusion. Post-
`marketing experience has demonstrated that proprietary names (or components of the
`proprietary name) can be a source of error in a variety of ways. Consequently, DMEPA
`considers and evaluates these broader safety implications of the name throughout this
`assessment and the medication error staff provides additional comments related to the
`
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`

`safety of the proposed proprietary name or product based on professional experience with
`medication errors.
`
`1. Database and Information Sources
`DMEPA searches the internet, several standard published drug product reference texts,
`and FDA databases to identify existing and proposed drug names that may sound-alike or
`look-alike to the proposed proprietary name. A standard description of the databases
`used in the searches is provided in the reference section of this review. To complement
`the process, the DMEPA uses a computerized method of identifying phonetic and
`orthographic similarity between medication names. The program, Phonetic and
`Orthographic Computer Analysis (POCA), uses complex algorithms to select a list of
`names from a database that have some similarity (phonetic, orthographic, or both) to the
`trademark being evaluated. Lastly, DMEPA reviews the USAN stem list to determine if
`any USAN stems are present within the proprietary name. The individual findings of
`multiple safety evaluators are pooled and presented to the CDER Expert Panel. DMEPA
`also evaluates if there are characteristics included in the composition that may render the
`name unacceptable from a safety perspective (abbreviation, dosing interval, etc.).
`
`2. Expert Panel Discussion
`DMEPA gathered CDER professional opinions on the safety of the proposed product and
`discussed the proposed proprietary name (Expert Panel Discussion). The Expert Panel is
`composed of Division of Medication Errors Prevention (DMEPA) staff and
`representatives from the Office of Prescription Drug Promotion (OPDP). We also
`consider input from other review disciplines (OND, ONDQA/OBP). The Expert Panel
`also discusses potential concerns regarding drug marketing and promotion related to the
`proposed names.
`The primary Safety Evaluator presents the pooled results of the database and information
`searches to the Expert Panel for consideration. Based on the clinical and professional
`experiences of the Expert Panel members, the Panel may recommend additional names,
`additional searches by the primary Safety Evaluator to supplement the pooled results, or
`general advice to consider when reviewing the proposed proprietary name.
`
`3. FDA Prescription Simulation Studies
`Three separate studies are conducted within the Centers of the FDA for the proposed
`proprietary name to determine the degree of confusion of the proposed proprietary name
`with marketed U.S. drug names (proprietary and established) due to similarity in visual
`appearance with handwritten prescriptions or verbal pronunciation of the drug name. The
`studies employ healthcare professionals (pharmacists, physicians, and nurses), and
`attempts to simulate the prescription ordering process. The primary Safety Evaluator
`uses the results to identify orthographic or phonetic vulnerability of the proposed name to
`be misinterpreted by healthcare practitioners.
`In order to evaluate the potential for misinterpretation of the proposed proprietary name
`in handwriting and verbal communication of the name, inpatient medication orders and/or
`outpatient prescriptions are written, each consisting of a combination of marketed and
`unapproved drug products, including the proposed name. These orders are optically
`
`Reference ID: 3213544
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`11
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`scanned and one prescription is delivered to a random sample of participating health
`professionals via e-mail. In addition, a ver