Modelling inert tablets, diluents, and solvents

We are seeking feedback on a proposed approach to modelling inert tablets, diluents, and solvents in a way that’s consistent with the international medicinal product concept model. Modelling these concepts will allow us to (for example) distinguish between a 21 tablet hormone pack (which contains only tablets with an active ingredient) and a 28 tablet hormone pack (which contains an additional 7 sugar tablets); and also between a pack that contains only a ‘powder for solution for injection’ and a pack that contains both a vial of the powder and a vial of the diluent/solvent.

The proposed approach for inert tablets is to create:

  • MP: |Inert product|
    • Is a Medicinal product
    • Count of active ingredients = #0
  • MPF: n/a
  • CD: |Inert oral tablet|
    • Is a Medicinal product
    • Count of active ingredient = #0,
    • Has manufactured dose form = |Oral tablet|

Note that even though the |Inert oral tablet| does not include a strength, we’re proposing to add this as a Clinical Drug, so that this concept can be used by the ‘Packaged Clinical Drug’ as a value of the |Contains clinical drug| relationship.

For diluents that contain ‘Sterile water’ or ‘Sodium chloride’, we are planning to use these substances as the ‘active ingredient’ of the clinical drug (e.g. ‘Sterile water 100% solution for injection’) - even though they are not an active part of the combined packaged clinical drug, they are often available separately with this active ingredient.

Thoughts on this proposal?

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Assuming I’ve read the proposal correctly, we’d either need to update the Editorial Guide or make an exception for these.

According to the guide:
Count of base of active ingredient (attribute)
Concrete Type: Integer
Range: >#0..
Cardinality: 1..1

I’m not sure whether there are any other problems with setting a ‘concrete value’ to exactly zero. For example does ECL or any databases cope with it?

But I do like the way of saying this concept is stated as having precisely no / zero active ingredients.

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Hi @lbird2 ,

Thanks - it would be good to have a standardised approach here.

Looking at the modelling, proposing a slight variation on above for conversation - if ‘inert matter (substance)’ is used as the substance it would allow the ‘count of base…’ attribute to be >0, and allow modelling at MP-containing, MP-only and MPF to adhere to International Drug Model.

Clinical Drug concept level would still be a variation from International Drug Model as there is no strength to represent.

Example below showing MP-Only, Clinical Drug, and extending to a Real Clinical Drug post classification. (Ignore FSNs/PTs - I was only looking at the modelling)

Some points:

  • If a substance was to be used, would ‘inert matter’ be the most appropriate?
  • Including the substance brings it closer to the clinical drug modelling - but still not adhering to it (even if we ignore the fact that, by definition, the ‘inert matter’ does not play the role of a PAI or BoSS).
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Hi Linda,

@mcordell and I discussed this yesterday, sorry we didn’t get back to you sooner.

AMT currently uses has active ingredient = inert substance. This pattern comes from AMT v3, which inherited it from v2, and so on.

Here’s some examples, first the "clinical drug” level concept

and a “real clinical drug” level concept

Personally, I have never been comfortable with this modelling. “Has active ingredient = inert substance” feels like an oxymoron, although it depends on how you define “active” and “inert”. Likewise, concepts like “Loette (inert substance) tablet” with a non-zero count of active ingredients seem logically inconsistent.

My preference would be to avoid using has active ingredient (or any subproperty) altogether for inert products. Nothing in these products is intended to be active by definition. A simple “count of active ingredient = 0” is accurate, and in my view sufficient to define the concept. If I could redesign this part of AMT, that is the approach I would take.

That said, the current AMT implementation does not cause any functional problems that I am aware of. AMT has used this pattern for nearly twenty years, and there has been no push from stakeholders to change it. If I tried to convince vendors to adopt a revised model, I doubt I could demonstrate enough practical benefit to justify the cost and consultation effort. So although the current pattern is not ideal, changing it would be hard to justify.

On diluents, I would not model “sterile water” or “sodium chloride” as active ingredients, even though AMT sometimes does so. These substances do not meet the definition of active ingredient:

The clinically relevant part or whole of the substance that is intended to have a therapeutic action on or within the body. It excludes esters, salts or other non-covalent derivatives (such as a complex, chelate etc.), but may include secondary modifications.

AMT mostly uses the same pattern as the inert tablets for diluents, with has active ingredient = inert substance, and usually does not specify the actual excipients because AMT does not model excipients for active products either.

But in some cases like this multi chamber drug, it does model the ingredient in the diluent chamber

I find this awkward. Sodium chloride in a diluent does not have a therapeutic action. It is a functional ingredient, which is a subtype of excipient. In this case it is a tonicity adjuster that supports safe and comfortable administration but does not contribute to the therapeutic effect.

I am not saying we should not model these ingredients. I am saying they are not active ingredients according to the definition. Ideally, we would have a separate branch under has ingredient for inactive ingredients, with the option to further specify their functional roles if useful.

Again, this is something I would change about AMT if the costs and benefits made sense, but at present they do not.

If I were to remodel diluents, I would treat them the same way as inert tablets: count of active ingredient = 0 with no has active ingredient relationship. I would only explicitly model diluent ingredients where clinically necessary or useful, and I would represent them using a separate subproperty under has ingredient, not under has active ingredient.

Those are my thoughts on what I would do different, but as I said I would have a hard time selling that change in and of itself - unless I’m missing some existing problems or benefits.

I hope that’s useful,

Dion

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I do like the approach you’ve described @lbird2. @dmcmurtrie has covered everything we talked about, but I will add - one factor why AMT has had “inert substances” is how the concept names are generated - it’s always been based off the modelling. Though simply saying “has ingredient=Inert substance” would be a more accurate way of getting that string in there. And for diluents - why not just use the attribute 762951001|Has ingredient (attribute)| ? Rather than “has active ingredient”?

But I also wanted to respond to this:

There isn’t actually any such thing as a “Clinical Drug”.

The range for “Contains clinical drug” is simply “Medicinal Products”.
image See: Packaged Clinical Drug (PCD) Specifications

This ties back to my comments on the semantic tags. I’m not sure why the drug project started proliferating them… (AMT has a variety also due to the legacy Dion touched on).

But it’s the actual grouper concepts that are important/useful. And there no such concept as |Clinical Drug| - so it can’t be referenced in MRCM or ECL… (except with ECL description filters…).

We dropped “class grouper” concepts in AMT in the move from v3-v4, but they are useful. (And would be easy to add back in).

Really great point Stuart! Yes, this proposal would require the MRCM rule to expand the range of this attribute to allow a #0 value.

Thanks for your feedback Shane! And I agree that it would be good to have a standardised approach here. This is something that most countries will need to deal with.

To me, it seems like an oxymoron to say that a product has an active ingredient, but it only contains inert matter. I do find it difficult to get comfortable with thinking of inert matter as an active ingredient. Stuart has also referred me to a product in the UK called Osmohale - which is a licensed diagnostic medicine, that includes an empty capsule. The empty capsule is a component of the licensed medicine, which does not contain any inert matter - it literally contains nothing.

The other aspect of your modelling, which I would question, is the use of the |Has basis of strength substance|, without a strength to be the basis of. It doesn’t feel right to me to separate these.

Thanks Shane!

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