Reporting Adverse Drug Reactions in Product Labels

Product labels are intended to provide health care professionals with clear and concise prescribing information that will enhance the safe and effective use of drug products. In this manuscript, we offer suggestions to improve product labels. First, we recommend that product labels that include comparator data be changed to include adjusted incidence proportions (or adjusted incidence rates when needed and appropriate) for adverse drug reactions that are somewhat common. Second, we believe that including comparator incidence in product labels is a good practice, as it gives health care providers and patients appropriate information to put the absolute risks in perspective. Finally, we recommend changing the practice of reporting extremely rare events based on the Rule of 3 in the Summary of Product Characteristics in Europe. We recommend that these adverse drug reactions be put in a separate table from other adverse drug reactions with a note that it is difficult to reliably estimate their incidences. In exceptional circumstances, it may be possible to present an estimate of their incidence based on postmarketing data. We believe the proposed changes could help product labels to better reflect the risk of a drug relative to a comparator.