Annex
SIMVASTATIN
Reclassification process
The proposal from Johnson & Johnson MSD
Consumer Pharmaceuticals for the pharmacy availability of simvastatin
10 mg (Zocor Heart-Pro) was first considered by members of the
Committee on Safety of Medicines (CSM) at a clarification meeting
in September 2003 and again at a CSM meeting in October 2003.
In light of discussions, CSM then advised that consultation could
take place to seek views on the pharmacy availability of Zocor
Heart-Pro.
On 17 November 2003 the MHRA started a consultation
exercise with a deadline for comments of 16 January 2004. The
consultation document (ARM 18) and the outcome of the consultation
exercise are displayed on the MHRA's website (www.mhra.gov.uk).
One hundred responses were received expressing a wide variety
of views on the proposed reclassification. Overall, about two
thirds of respondents were in favour of the proposal. The responses
received were then referred to the CSM for advice. No new issues
were raised in the responses and CSM advised Ministers that simvastatin
10 mg could be safely sold under the supervision of a pharmacist
without a prescription.
Safety assessment
Patient safety is the prime consideration in
any decision to make a medicine available over the counter (OTC).
It is assessed against strict criteria relating to its safety
in the circumstances in which it will be used. Simvastatin has
been available in the UK since 1989 and many millions of patients
have been safely treated. All medicines have the potential to
cause side effects. Most of these side effects are not serious
and are predictable from the known actions of the drug. During
the use of simvastatin in clinical practice, there have been reports
of reactions suspected to be associated with the medicine. As
with all statins, simvastatin has been associated with some rare
reports of severe muscle damage. The incidence of muscle damage
with simvastatin is dose dependent and is more likely to occur
at higher doses or when simvastatin is taken with other cholesterol
lowering drugs. As the pharmacy medicine contains low dose simvastatin
(10 mg) the risk of muscle damage is very small. This is a rare
side effect and clear unambiguous advice is in the product information,
patient information and information for pharmacists.
Efficacy of simvastatin
There is a wealth of evidence to support the
concept that lowering cholesterol is beneficial and reduces the
risk of Coronary Heart Disease (CHD). Similarly there is a wealth
of evidence that statins lower cholesterol levels and hence reduce
the risk of CHD. The amount by which statins lower cholesterol
is dose related, with higher doses resulting in greater absolute
reduction. Simvastatin 10 mg has been shown to lower cholesterol
levels, however, because the benefit is most demonstrable in patients
at higher risk, large scale clinical trials of statins (including
simvastatin) have generally targeted high risk patients. The latest
research, however, provides good evidence to support the switching
of statins to reduce the risk of a first major coronary event
in people likely to be at a moderate risk of CHD.
Numerous endpoint studies with statins confirm
that lowering low-density lipoprotein cholesterol (LDL-C) reduces
the risk of developing CHD. Simvastatin 10 mg produces around
a 27% fall in LDL-C or 1.31mmol/l in absolute terms (standardising
to a mean starting level in studies of 4.8 mmol/l). Reductions
of this order reduce the risk of a major coronary event (CHD death
or non-fatal myocardial infarction) by about one third after three
years of treatment. The level of absolute risk reduction depends
on the starting level of risk. Whilst no specific clinical trials
have been conducted with simvastatin 10 mg in this particular
patient population, it is reasonable to assume that these benefits
would also apply to this group of people given that the effect
of lowering LDL-C by simvastatin is consistent between populations,
and the relation of LDL-C to risk is linear.
In the self-medication population selected on
the basis of age and sex and risk factor status (smoking, family
history of early CHD, overweight or truncal obesity and ethnicity),
starting 10-year CHD risk is likely to be in the range of 10-15%.
Treatment with simvastatin 10 mg in this population will, therefore,
produce a valuable reduction in risk, provided people are compliant
with the treatment regimen; coupled with diet and lifestyle changes,
the benefits to these individuals will be considerable. It is
recognised that there are uncertainties about the effect of taking
a statin on compliance with behavioural risk-modifications (such
as healthy eating, exercise and smoking cessation).
CONCLUSIONPreventing
CHD is a national priority. The National Service Framework for
CHD sets out plans to ensure that the best care, in terms of prevention,
diagnosis and treatment, is available to everyone. The NSF has
prioritised those individuals at greatest risk. Making simvastatin
available OTC provides a choice to those at moderate risk of CHD
to access a preventative medicine they would not otherwise get
on prescription.
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