(3) Use information on unapproved/off-label drugs that may be provided (quality-related information)
Q(Question)
When a physician or pharmacist requests information on a simple suspension method not covered by the approval, what information may be provided?
A(MHLW answer)
Same as A7.
So what (meaning): The same conditions as Q7 apply to unapproved quality information related to the simple suspension method. Information must pass internal Guideline-compliance review and be provided with test conditions and methods.
So why (rationale): The simple suspension technique is widely used for patients with swallowing difficulties, making the quality information need equivalent to Q7, so identical treatment applies.
Commentary — background, application, practical notes
The simple suspension method involves dissolving or suspending tablets or capsules in warm water for administration via syringe through a nasogastric tube or percutaneous endoscopic gastrostomy (PEG). This technique is widely used for patients requiring enteral medication delivery, but enteric-coated or extended-release formulations may undergo significant pharmacokinetic changes upon suspension — constituting use outside approved specifications. Q8 is treated as the same category as Q7: in-house stability and suspension-compatibility data may be provided together with the test conditions under which they were obtained.
Typical inquiries come from ward nurses and pharmacists managing medications for elderly patients with dysphagia or patients with impaired consciousness, or from home healthcare providers managing enteral nutrition patients. Providing data that specifies time-to-administration limits after suspension, water temperature requirements, and other test-condition parameters enables the recipient to compare those conditions against their clinical setting and make an informed judgment.
A common error is answering by analogy — for example, concluding that suspension is acceptable because a drug in the same therapeutic class is routinely suspended. Differences in formulation and excipients mean that post-suspension behavior varies between products, and analogy-based answers without product-specific test data do not satisfy the scientific-evidence requirement. Furthermore, even where in-house documents indicate that suspension is feasible, those documents must have passed an internal Guideline-compliance review before being provided to the requesting healthcare professional.
Source: MHLW MSA Guidelines Q&A Part 2, Mar 29 2019, Q8