FREEDOM OF INFORMATION SUMMARY (continued, Part 5)

POSILAC® (sterile sometribove zinc suspension)

i. Reproduction

Reproductive performance was evaluated in the following studies individually and from a pooled analysis:

Multi-lactation Chronic Animal Toxicity Study (TAS)
Multi-location SC Dose Response Clinical Study (4 Dose-SC)
Multi-location IM Single Dose Study (Single Dose-IM)
IM Dose Titration Study (Dose-IM)
IM/SC Bridging Study (IM/SC)

The experimental design and methods for each of these studies are described in Sections 6.b, 5.a, 6.e, 6.d, and 6.c, respectively. Location-specific practices were followed for vaccination programs, sire selection, management of reproductive problems, and calving management. All cows received a veterinary examination to evaluate reproductive health prior to initiation of the breeding program. All breeding was by artificial insemination. Estrus detection was by visual appraisal of standing estrus according to the following system: 1 = standing heat; 2 = bulling, sniffing, and attempting to mount other cows; 3 = bawling and restlessness; 4 = clear vaginal discharge, vulva lips swollen and/or flabby; 5 = metestrus bleeding; 6 = other, when 1-5 did not apply, explained in an observation column. Some locations may also have used heat detection aids such as heat mount detectors or tailhead chalking. Use of prostaglandins and gonadotropins to induce fertile estrus was not restricted in the IM studies and normal location practices were allowed. In the 4 Dose-SC study, use of any medication to alter the normal cycle was not allowed until after 120 days in milk. No restriction, however, was placed on the use of these products to treat a diagnosed ailment such as cystic ovarian disease or pyometra. Data were analyzed using all available information and again, separately, excluding those cows that received any medication intended to alter the estrous cycle. Since the trends regarding the effects of sometribove treatment on reproduction were the same in either case, only the overall analysis is discussed.

All locations participated in a routine herd health program. Pregnancy status was determined by rectal palpation by the herd veterinarian or other qualified person at regular intervals. This information was used to determine the conception date and to identify any loss of a previously diagnosed pregnancy. At parturition, a calving ease score was assigned, with increasing calving difficulty indicated by increasing score. Calving ease scores were as follows: 1 = an unassisted delivery in which progressive fetal expulsion continued throughout and labor did not exceed 3 or 5 hours for multiparous or primiparous cows, respectively; 2 = a multiparous or primiparous cow delivered a calf after prolonged or difficult unassisted labor of >3 or >5 hours, respectively; 3 = manual assistance (traction only) was required; 4 = delivery was assisted due to improper calf positioning for parturition; 5 = calving occurred unobserved. Scores were grouped into high (scores 2, 3, and 4) versus low (score 1) calving difficulty for analysis. All calves were weighed at birth.

Data from each of the five studies were analyzed separately by parity. Data were then pooled where appropriate, i.e., where similar sometribove doses and similar reproductive management techniques were used, and analyzed by parity to allow the most complete evaluation of the effects of sometribove on reproduction. In all IM studies (including the IM/SC Bridging Study), attempts to breed cows began at approximately 40 days after calving. Because of this, approximately 40 % of all cows on these studies received at least one insemination prior to the first sometribove administration. In the 4 Dose-SC study, all inseminations occurred after the first administration of sometribove. For this reason, pooling across the IM and SC studies was not possible. Thus, the data from clinical studies using the IM route of administration were pooled for the control and 500 mg doses (including only the IM injected cows from the IM/SC study) and analyzed as the "Pooled IM" studies, and the 4 Dose-SC study was analyzed separately. Finally, the TAS Study was evaluated separately from the other studies because of the higher doses used.

Reproductive variables were analyzed over several separate study periods. In the Pooled IM studies, where breeding was initiated prior to sometribove treatment, reproductive performance was evaluated in the pretreatment period to determine, among other things, whether breedings occurring within a few weeks of initiating sometribove treatment resulted in greater failure in conception rates. Reproductive performance in the Pooled IM studies was also evaluated from the initiation of sometribove treatment (i.e., approximately 60 days postpartum) until the breeding cut-off (i.e., days postpartum in which attempts to breed a cow ceased), which was set at 170 days in these studies. Finally, reproductive performance over the entire breeding period (pretreatment through 170 days postpartum) was evaluated. In the 4 Dose-SC study, breeding initiated after the start of sometribove treatment and continued until at least 305 days postpartum. Evaluation of reproductive performance in this study covered the periods from 60 to 180 days postpartum, and from 60-305 days postpartum. (For example, for the 60-180 day evaluation, if a cow conceived at 250 days postpartum, she was nevertheless classified as "open" in the analysis.) Finally, in both the Pooled IM and 4 Dose-SC analyses, reproductive performance across dose groups was evaluated during the first 28 days of sometribove treatment to determine whether negative effects, if any, were predominantly associated with the earliest period of treatment when treated cows usually had a reduction in energy balance compared to controls. It should be noted that individual cows were only included in the periods of analysis for variables in which they were "eligible." For example, in the Pooled IM studies, a cow conceiving to a full-term pregnancy prior to the initiation of sometribove treatment was excluded from the day 60 to 170 analyses for selected variables because she was already pregnant. However, if she lost the fetus prior to 170 days postpartum, she would have been included in the day 60 to 170 analyses for these variables because she was once again eligible for breeding.

A glossary of terms is included at the end of this Section (Table 65) and reflects most of the variables analyzed. Results of the analyses during the pretreatment period did not indicate that initiation of sometribove treatment shortly after breeding adversely affected conception or other reproduction indices. Effects during the first 28 days of treatment were not substantially different from those observed during the remainder of the breeding period.

The results of reproductive performance in the TAS study from days 60-140 postpartum in Year 1 and days 60-275 postpartum in Year 2, in the Pooled IM studies from day 60 to 170 postpartum, and the 4 Dose-SC study from days 60-180 postpartum in general were found to reflect the effects of sometribove treatment during the entire breeding period. Based on these data, both primiparous and multiparous cows experienced a reduction in pregnancy rates (see Table 61) and variables related to pregnancy rate (e.g., conception rate and successful calving rate). Primiparous cows had an increase in days open (see Table 62). Administration of sometribove was also associated with an increased rate of twinning and an increase in the incidence of cystic ovaries (Tables 63 and 64). Other parameters of reproductive performance, such as days to first estrus and insemination, interestrous interval, services per conception and incidence of fetal loss were not consistently affected by the administration of sometribove.

Conclusions

The product labeling states that treatment of cows with sometribove may result in reduced pregnancy rates and an increase in days open for primiparous cows. Also, the incidence of cystic ovaries and multiple births may increase. The labeling recommends the implementation of a comprehensive and ongoing herd reproductive health program preceding use of sometribove.

(Eds. note: The following table consists of 6 columns.)

Table 61.   Pregnancy rates (full term).


TAS Study1                                                                                         

Dose            0 mg             600 mg       1800 mg      3000 mg         P    
    
Year 1; days 60-140 of lactation                                                              
Primiparous  100 % (3/3)2       43 %  (3/7)   40 % (2/5)    20 % (1/5)   .078     
Multiparous  100 % (10/10)      45 % (5/11)   43 % (3/7)    50 % (6/12)  .072     

Year 2; days 60-275 of lactation                                                              
Primiparous  100 % (4/4)       100 % (2/2)    50 % (1/2)    0 % (0/1)    .016     
Multiparous  100 % (10/10)      17 % (1/6)   100 % (4/4)    75 % (6/8)   .916     

Pooled IM Analyses; days 60-170 of lactation3                                                       
Dose         0 mg                   500 mg       P        

Primiparous  90 % (37/41)      63 % (30/48)     .002     
Multiparous  77 % (89/115)     70 % (90/129)    .115     

4 Dose-SC Study; days 60-180 of lactation1                                                          
Dose         0 mg             250 mg       500 mg        750 mg          P        

Primiparous  77 % (20/26)   63 % (17/27)  70 % (19/27)   80 % (20/25)  .680     
Multiparous  86 % (30/35)   62 % (21/34)  66 % (21/32)   66 % (23/35)  .105     

 
1 Linear trend in proportions across dosage levels
  (Cochran-Armitage). 

2 Number of cows pregnant full term divided by number of cows in
  group. 

3 Cochran-Mantel-Haenszel Chi-square test for difference between
  control and treated.
(Eds. note: The following table consists of 7 columns.)

Table 62.   

Days Open A (average number of days from calving to final
conception for cows pregnant to term).1


TAS Study                                                       Probability                                                                               

Dose       0 mg        600 mg        1800 mg        3000 mg     A2      B3    
   
Year 1; days 60-140 of lactation                                                                 
P4    77±13.2(3)5    101±13.2(3)   91±16.2(2)    125±22.9(1)   .372    .180                                                                                       
M4    95± 8.5(10)     96±12.0(5)   86±15.5(3)     91±11.0(6)   .945    .616     
                                                                                      
Year 2; days 60-275 of lactation                                                              
P     93±23.9(4)     196±33.9(2)   64±47.9(1)      ±      (0)  .116      E       
M  107ab±10.4(10)   223c±32.9(1)  84a±16.5(4)   135b±13.4(6)  .006    .182  
   
Pooled IM Analyses; days 60-170 of lactation                                                          
Dose         0 mg                500 mg                          A  
P       89a±5.0(37)           105b±5.0(30)                     .024     --      
M      101±4.2(89)            103±3.5(90)                      .646     --  
    
4 Dose-SC Study; days 60-180 of lactation                                                             
Dose 0 mg              250 mg         500 mg       750 mg        A      B        
P    102a±6.8(20)   112a±7.6(17)  103a±7.2(19)  131b±7.5(20)  .024    .017     
M    106±6.5(30)    115±7.7(21)   109±8.5(21)   110±7.6(23)    .817    .836     
 
a,b,c Means within a row with different superscripts are
  significantly different  (P< .10). 

1 Least-squares analysis; results reported as least-squares
  means ± SE of least-squares means. 

2 A = Probability of dose main effect. 

3 B = Probability of linear contrast (E = all doses are not
  present). 

4 P = Primiparous; M = Multiparous. 

5 Number of cows included in analysis.
(Eds. note: The following table consists of 6 columns.)

Table 63.   Rate of multiple births (full-term pregnancies).

TAS Study1                                                                                           
Dose             0 mg             600 mg          1800 mg         3000 mg            P        
Year 1; days 60-140 of lactation                                                               
Primiparous   0.0 % (0/3)2       0.0 % (0/3)      0.0 % (0/2)    100.0 % (1/1)     .025    
Multiparous   0.0 % (0/10)       0.0 % (0/5)      0.0 % (0/3)      0.0 % (0/6)    1.000    

Year 2; days 60-275 of lactation                                                               
Primiparous   0.0 % (0/4)        0.0 % (0/2)      0.0 % (0/1)      0.0 % (0/0)    1.000    
Multiparous   0.0 % (0/10)     100.0 % (1/1)     25.0 % (1/4)     16.7 % (1/6)     .411    

Pooled IM Analyses; days 60-170 of lactation3                                                        
Dose         0 mg                                500 mg                              P        
Primiparous  2.9 % (1/34)                         20.8 % (5/24)                    .016     
Multiparous  1.2 % (1/86)                         13.6 % (11/81)                   .003     

4 Dose-SC Study; days 60-180 of lactation1                                                           
Dose           0 mg             250 mg          500 mg           750 mg              P        
Primiparous   5.0 % (1/20)     5.9 % (1/17)     5.3 % (1/19)     10.0 % (2/20)     .560     
Multiparous  13.3 % (4/30)     4.8 % (1/21)     9.5 % (2/21)     13.6 % (3/22)     .936     


1 Linear trend in proportion across dosage levels
  (Cochran-Armitage). 

2 Number of cows with multiple births (full term) divided by
  number of cows with full-term pregnancies. 

3 Cochran-Mantel-Haenszel Chi-square test for difference between
  control and treated.

(Eds. note: The following table consists of 7 columns.)

Table 64.   

Incidence of cystic ovaries (number of cases, number of cases per
100 cow days, and number of cows affected).

 TAS Study
 
 Dose         0 mg    600 mg     1800 mg     3000 mg      P
 
 Year 1; days 60-140 of lactation                        
 P1  #  cases  0       2          0           2           
     # /100 d2 0.00    0.53       0.00        0.51       .887
     #  cows3  0 (3)4  2 (7)      0 (5)       2 (5)      .425
      
 M1  #  cases  1       3          4           0           
     # /100 d  0.42    0.50       1.32        0.00       .279
     #  cows3  1 (10)  2 (11)     2 (8)       0 (12)     .390
              
 Year 2; days 60-275 of lactation                        
 P   #  cases  0       1          0           2           
     # /100 d  0.00    0.36       0.00        2.35       .087
     #  cows3  0 (4)   1 (2)      0 (2)       1 (1)      .143
 
 M   #  cases  3       13         1           2           
     # /100 d  0.64    1.62       1.02        0.31       .113
     #  cows3  2 (10)  2 (6)      1 (4)       2 (8)      .916
     
 Pooled IM Analyses; days 60-170 of lactation
 Dose             0 mg         500 mg            P
 
 P   #  cases       3            14                 
     # /100 d       0.21          0.48          .183
     #  cows5       3 (41)        9 (48)        .108
 
 M   #  cases       21           55                 
     # /100 d       0.36          0.70          .018
     #  cows5      17 (117)      34 (130)       .048
     
 4 Dose-SC Study; days 60-180 of lactation
 Dose         0 mg    250 mg     500 mg      750 mg        P
 
 P   #  cases  13      19         7           15          
     # /100 d  0.86    1.03       0.50        0.76        .694
     #  cows3  5 (26)  8 (27)     5 (27)      12 (25)     .065
 M   #  cases  10      11         21          17          
     # /100 d  0.50    0.42       0.97        0.74        .120
     #  cows3  6 (35)  7 (34)     10 (32)     9 (35)      .265
 
1 P = primiparous; M = multiparous. 

2 Poisson regression. 

3 Linear trend in proportions across dosage levels
  (Cochran-Armitage). 

4 Number of cows included in analysis. 

5 Cochran-Mantel-Haenszel Chi-square test for differences
  between control and treated.
  
(Eds. note: The following table consists of 2 columns.)

 
Table 65.   Glossary of Reproduction Terms



Number of Cows        Total number of cows available for analysis.            

Estrous Period        Period of time the cow is receptive to breeding         
                      activity.  Generally defined by immobility during       
                      mounting attempts of other cows.  Activity is scored    
                      (see below) and all scores within a 4 day period are    
                      considered to be a single estrous period.  The first    
                      date of the 4 day period is used as the date of         
                      estrus which is used to calculate interestrous          
                      interval.  The last date of the 4 day period is used    
                      to assign estrous period to a particular study period.  

Total Estrous         Total number of estrous periods during a given time.    
Periods               This excludes estrous periods after conception in       
                      full term pregnancies and after conception and up to    
                      fetal loss in cows that later lost a pregnancy.         

Average Number of     The average number of estrous periods during a given    
Estrous Periods       time.  Same exclusions as for Total Estrous Periods.    

Interestrous          Average number of days between all estrous periods.     
Interval              Same exclusions as for Total Estrous Periods.           

First Interestrous    Average number of days between the first estrous        
Interval              period and the second estrous period.  Same             
                      exclusions as for Total Estrous Periods.                

Second Interestrous   Average number of days between the second estrous       
Interval              period and the third estrous period.  Same exclusions   
                      as for Total Estrous Periods.                           

Expected Estrous      Calculated by using the open days divided by 21.        
Periods                                                                       

Days to First Estrus  Average number of days to first observation of          
                      estrus.  Definitions for estrous scores follow:  
                      1 =  Standing estrus. 
                      2 =  Bulling, sniffing and attempting to mount other cows.  
                      3 =  Bawling and restlessness.  
                      4 =  Clear vaginal discharge, vulva      
                           lips swollen and/or flabby.  
                      5 =  Metestrus bleeding.   
                      6 =  Other; when 1-5 does not apply, explain in         
                           observation column. 
                                                          
Total Inseminations   The total number of inseminations for all cows within   
                      a group.                                                

Average Number of     The average number of inseminations per cow within a    
Inseminations         group.                                                  

First Insemination    The average number of days between the first and        
Interval              second insemination.                                    

Second Insemination   The average number of days between the second and       
Interval              third inseminations.                                    

Inseminations/Estrus  The average number of inseminations per estrous         
                      period.                                                 

Missed Inseminations  The total number of estrous periods for which there     
                      is no insemination and no insemination occurs within    
                      24 hours after the end of an estrous period.            

Days to First         Average number of days to first insemination.           
Insemination                                                                  

Days From First       Average number of days from the first estrus to         
Estrus to Pregnancy   conception, resulting in full term pregnancy (250       
                      days gestation).                                        

Days From First       Average number of days from the first insemination to   
Insemination to       conception, resulting in full term pregnancy.           
Pregnancy                                                                     

Days Between          Average number of days between inseminations.           
Inseminations         Includes all inseminations excluding those occurring    
                      after conception date resulting in full term            
                      pregnancy.                                              

Services/Conception   Average number of inseminations per cow required to     
                      attain full term pregnancy.                             

Days From             Average number of days from the first injection of      
Initiation of         sometribove to conception, resulting in full term       
Treatment to          pregnancy.                                              
Pregnancy                                                                     

Days Open A           Average number of days from calving to conception for   
                      cows pregnant to term.                                  

Days Open B           Average number of days from calving to conception,      
                      for cows pregnant full term, or to upper limit of       
                      breeding period in days postpartum for cows not         
                      pregnant full term (e.g., if breeding cut off was 180   
                      days, cows not pregnant by this time were assigned      
                      180 days open).            
                                                   
Median Days Open      The value for days open for pregnant cows above and     
                      below which there are an equal number of values. 
                             
Calving Interval      Average number of days between successive               
                      parturitions for full term pregnancies.      
                                 
Days Carried Calf     Average number of days cows were pregnant between       
During Treatment      conception date and the last injection date plus 14     
                      days (end of last cycle) or the date of diagnosed       
                      late fetal loss or early fetal loss whichever           
                      occurred first.                                         

Percent of Cows       Number of cows inseminated divided by total number of   
Inseminated           cows available for breeding.                            

Conception Rate       Number of cows that conceived (diagnosed pregnant by    
                      palpation per rectum at any time after insemination)    
                      divided by the number of cows that were inseminated.    

Fertilization Rate    Number of cows which conceived at least once divided    
                      by the number of inseminations for cows which           
                      conceived.                                              

First Service         The number of conceptions from the first insemination   
Pregnancy Rate        resulting in full term pregnancy divided by the         
                      number of cows receiving the first insemination.        

Second Service        The number of conceptions from the second               
Pregnancy Rate        insemination resulting in full term pregnancy divided   
                      by the number of cows receiving the second              
                      insemination.                                           

Third Service         The number of conceptions from the third insemination   
Pregnancy Rate        resulting in full term pregnancy divided by the         
                      number of cows receiving the third insemination.        

Combined Pregnancy    The number of conceptions from the first three          
Rate                  inseminations combined resulting in full term           
                      pregnancy divided by the number of cows receiving the   
                      first three inseminations.                              

Pregnancy Rate        Number of cows pregnant full term divided by the        
                      number of cows in the group.                            

Full Term Pregnancy   Gestation length >=250 days and < =314 days.             
Unsuccessful Calving  A cow which meets one of the following criteria:  
                         1. Calves < 250 or > 314 days gestation. 
                         2. Dies within 7 days of parturition or does not lactate 
                            after parturition.  
                         3. Calf dies within 24 hours after birth. 
                         4. Cow was removed from herd within 7            
                            days of parturition.                                    

Unsuccessful          Includes all cows in "unsuccessful calving" plus any    
Reproduction          cow that does not calve for any reason.                 

Successful Calving    Number of cows delivering a calf at greater than or     
Rate                  equal to 250 and less than or equal to 314 days of      
                      gestation divided by the number of cows in the group.   
                      Also the cow must have lived 7 days and the calf 24     
                      hours postpartum.  The cow must not have been removed   
                      from the herd within 7 days postpartum.                 

Total Fetal Loss      The sum of all fetal loss categories including early    
                      fetal loss, late fetal loss, stillbirth and other       
                      fetal loss.                                             

Early Fetal Loss      Pregnancy loss at < 70 days gestation.                   

Late Fetal Loss       Pregnancy loss >=70 and < 250 days of gestation.         

Stillbirth            Pregnancy loss at >=250 and <=314 days of gestation.    
                      Gestation >314 days.  Calf dies within 24 hours after   
                      birth.                                                  

Other Fetal Loss      Pregnancy loss that does not fit into early fetal       
                      loss, late fetal loss or stillbirth definitions         
                      includes unexpected circumstances such as death of      
                      the cow (natural or euthanized).                        

Cystic Ovary          A cow is determined to have a cystic ovary if at        
                      least one diagnosis of cystic ovary has been made       
                      based on rectal palpation.                              

Incidence Rate of     Duration of cystic ovarian condition divided by 30.     
Cystic Ovaries                                                                

Conception Rate       Number of cows that conceived at least once after a     
After Cystic Ovary    diagnosis of cystic ovary has been made divided by      
                      the number of cows diagnosed with the condition.        

Treatment Rate for    The number of times a cow was treated (GnRH, HCG,       
Cystic Ovaries        Prostaglandins, Rupture) for a cystic ovary divided     
                      by the number of cows diagnosed with the condition.     

Insemination          Passage of an insemination pipette and deposition of    
                      semen in the reproductive tract of the female.          

Excluded Cows for     Cows receiving reproductive aids such as                
PGF                   prostaglandins, HCG, or GnRH to induce a fertile        
                      estrus were dropped from analysis of a given variable.  

HCG                   Human Chorionic Gonadotropin.  Used as a source of      
                      luteinizing hormone for the treatment of cystic         
                      ovaries or to induce ovulation.                         

GnRH                  Gonadotropin Releasing Hormone.  Used to cause          
                      endogenous release of luteinizing hormone for the       
                      treatment of cystic ovaries or to induce ovulation.     

P4 Kit                Milk progesterone test.  A test to determine the        
                      concentration of progesterone in milk for the purpose   
                      of confirming estrous behavior.                         

j. Mastitis

The effect of sometribove treatment on clinical mastitis, subclinical mastitis and somatic cell count (SCC) was evaluated from the following studies in separate and pooled analyses:

Multi-lactation Chronic Animal Toxicity Study (TAS)
Multi-location SC Dose Response Clinical Study (4 Dose-SC)
Multi-location IM Single Dose Study (Single Dose-IM)
IM Dose Titration Study (Dose-IM)
IM/SC Bridging Study (IM/SC)

The experimental design and sample collection schedule for each of these studies has been described (Sections 6.b, 5.a, 6.e, 6.d, 6.c, respectively).

Since the individual effectiveness trials lacked sufficient numbers of animals to examine any association between use of sometribove and effect on mastitis and milk somatic cell count, data from studies were pooled in order to augment animal numbers and increase the reliability of conclusions. As discussed in Sections 5.a and 6.e, data collected at one location (Utah) from the 4 Dose-SC study and the same location in the Single Dose-IM study were excluded from the clinical and subclinical mastitis analysis. Clinical mastitis was rarely treated during these trials, possibly affecting the incidence of mastitis and confounding any effects due to sometribove.

For clinical mastitis, data from the 4 Dose-SC, Single Dose-IM, Dose-IM and IM/SC studies (i.e., 8 trials) were pooled for analysis. The TAS study was excluded from the pooled analysis because of the higher doses used. A separate analysis of this study was carried out. For subclinical mastitis, data from the 4 Dose-SC study were pooled with the IM/SC study and the Dose-IM study. Finally, for somatic cell counts, several analyses were carried out on data from individual studies and on pooled data.

Detection of clinical mastitis.

In all studies, milkers were responsible for the detection of abnormal milk by the examination of foremilk from each quarter at each milking. There was some variation from location to location in routine practices and therapy related to mastitis. However, within a given location, control and sometribove-treated cows were assessed and administered therapy for mastitis by identical procedures.

Detection of subclinical mastitis.

Milk samples were obtained for determination of subclinical mastitis by microbiological culture once before initiation of treatment with sometribove and at approximately 8 week intervals during the treatment period.

Determination of SCC.

Milk samples for determination of SCC were taken once per week throughout the study for all of the studies. All determinations were done by independent laboratories.

Definitions.

Case Rate was the number of clinical mastitis cases per quarter per cow-day when a new case could be observed. Twenty-one (21) days must have elapsed between observations within a quarter or a new pathogen isolated for separate cases to be identified.

Days Affected Rate was the number of days affected per cow-day observed. Cases in more than one quarter on a given day were consolidated in this variable. Essentially, a yes/no response was created for each animal each day.

Results:

Clinical Mastitis

In the pooled analysis (excluding the TAS study), there was a total of 202911 quarter days when new cases could have been observed for 193 primiparous cows and 408468 quarter days when new cases could have been observed in 426 multiparous cows. Because of overlap, days observed were slightly smaller than one quarter of these values; primiparous cows were observed on 51069 days and multiparous cows on 103125 days.

Cochran-Mantel Haenszel (CMH) measures of general association were used to test for association, controlling various effects. Analyses were done (1) separately by parity, (2) controlling for parity, and (3) ignoring (collapsing) parity. There was an association between sometribove usage and the number of cows affected with clinical mastitis. Comparing the proposed use level (500 mg) to control, the relative risk of a treated animal showing signs of clinical mastitis during the treatment period was about 1.79 times that of a control animal (Table 66).

(Eds. note: The following table consists of 4 columns.)

Table 66.   Pooled analysis (0 and 500 mg sometribove only)


                        -------- Relative risk (500 mg/0 mg)-----------                            
  
Parity handling        Estimate        95 % Confidence   95 % Confidence   
                                         Lower Bound      Upper Bound      

Primiparous             1.969               0.944            4.098            
Multiparous             1.745               1.214            2.506            
Controlled for Parity   1.789               1.292            2.475            

Poisson-based regression was used to estimate the probability of observing a new case on a quarter-day when a new case could be observed. Case Rate per cow-day could then be obtained by assuming independence of the quarters. The probability was then the sum of the probabilities in each of the four quarters in the udder, or four times the probability in any one quarter. Poisson-based regression was also used to estimate the probability that a cow would be affected with clinical mastitis on any given day. The regression coefficients were used to calculate predicted Case Rates and Days Affected Rates for a standard treatment period of 252 days. Case Rate was increased for primiparous cows, with an expected 0.21 cases per control animal and 0.37 cases in treated (500 mg) primiparous cows. Case Rate was also increased for multiparous cows, with an expected 0.36 cases of clinical mastitis in control animals and 0.54 cases in treated (500 mg) cows. The total Days Affected Rate for primiparous cows was not increased by treatment with sometribove. For multiparous cows, Days Affected Rate was increased from 1.49 in controls to 2.15 in treated (500 mg) animals. The results from this analysis are presented in Table 67. The P value reported in Table 67 refers to the probability associated with the regression, not to the comparison between the 0 and 500 mg dose group.

(Eds. note: The following table consists of 4 columns.)

Table 67.   

Comparison of expected mastitis Cases and total Days Affected for
control and sometribove-treated cows -pooled analysis assuming a 252 day
standardized treatment period.


                        ------- Study Groups -------                                   

Parity Group             Control       Sometribove1          P               

Primiparous Cows                                                           
 
 Cases                    0.21            0.37             0.0147          
 Days Affected            1.15            1.21             0.6779          

Multiparous Cows                                                           
 
 Cases                    0.36            0.54             0.0021          
 Days Affected            1.49            2.15             0.0001          


1 Expected results for the 500 mg/14 day dose group.
A separate analysis was conducted for the TAS study because the range of doses of sometribove was considerably different from the range in the remainder of the studies. Over two years of treatment, this study covered 32961 quarter days when new cases could be observed in 27 primiparous cows (8466 days with overlap). In 56 multiparous cows, there were 76823 quarter days when new cases could be observed, which covered 19820 days, considering overlap. Although there was numerical evidence for a dose related increase in Case Rate and Days Affected Rate in this study, the high background level of clinical mastitis resulted in no significant differences detected in the pooled analysis at the use level of the drug (500 mg) although the linear trend was significant (Table 68).

(Eds. note: The following table consists of 4 columns.)

Table 68.   

Comparison of expected mastitis Cases and total Days Affected for
control and 500 mg sometribove-treated cows - TAS study assuming a 252 day
standardized treatment period.


                          ----- Study Groups -----                                       
Parity Group             Control       Sometribove           P               

Primiparous Cows                                                           
 
 Cases                    0.95            1.07             0.0784         
 Days Affected            3.50            4.33             < 0.0001        

Multiparous Cows                                                           
 
 Cases                    0.97            1.13             < 0.0001         
 Days Affected            4.43            5.62             < 0.0001         

The average duration of clinical cases of mastitis was evaluated between control and sometribove (all doses) treated cows in the 8 clinical trials and TAS study, with parities pooled (Table 69).

(Eds. note: The following table consists of 3 columns.)

Table 69.   

Average duration (in days) of cases of clinical mastitis in
control and sometribove-treated cows.
                       

              Sometribove Dose (mg/14 days)  

Trial            0 mg      All Sometribove      
                               Doses                

Arizona IM          4.5              4.0                  
Arizona SC          4.0              5.9                  
Cornell IM          4.1              3.6                  
Cornell SC          2.0              4.1                  
Florida SC          2.0              3.3                  
Dardenne IM         5.2              4.3                  
Dose-IM             5.0              4.7                  
IM/SC               3.0              5.5                  

Weighted Average    4.5              4.6                  
of Clinical Trials                                           
                                                             
TAS Study  (Year 1) 5.4              5.5                  
                                                         
The average case duration in controls versus treated cows in these clinical trials was 4.5 versus 4.6 days; in the TAS study the average durations were 5.4 versus 5.5 days, respectively. Thus, the increased total days affected with clinical mastitis in sometribove-treated cows reflected the greater number of clinical mastitis cases and not increased average duration per case.

Subclinical Mastitis

Analysis of subclinical mastitis on a per cow basis indicated that treatment with sometribove significantly increased the number of animals with this condition. The relative risks for contracting subclinical mastitis for the 250, 500, and 750 mg groups were 1.56, 1.55, and 1.51, respectively, compared to controls (Table 70).

On a quarter basis, the results showed a general association between sometribove level and testing positive for subclinical mastitis (P=0.001) for all dose levels. The relative risks for testing positive for subclinical mastitis for the 250, 500, and 750 mg groups were 1.60, 1.81, and 1.52, respectively, compared to controls (Table 70). A separate analysis (results not shown) indicated that for the four microbiological categories evaluated (i.e., pathogen, coagulase negative Staphylococcus (CNS), environmental, and other), at the use level of the drug the "pathogen" and the "CNS" categories were statistically significant (P=.001) for general association.

(Eds. note: The following table consists of 4 columns.)

Table 70.   

The effect of sometribove treatment at various dosages on the
relative risk for occurrence of subclinical mastitis compared to
controls.


                  ------------ Sometribove Dose ------------                                          
                      
                   250 mg          500 mg         750 mg            
Per cow basis                                                               
 
 Relative risk        1.56              1.55              1.51              
 Probability         <.001             <.001              .003             

Per quarter basis                                                           
 
 Relative risk        1.60              1.81              1.52              
 Probability          .001              .001              .001             

Somatic Cell Counts (SCC)

Several analyses were conducted on somatic cell count (SCC) data from the TAS, 4 Dose-SC (all four locations), Single Dose-IM (all four locations), Dose-IM, and IM/SC studies.

First, data from each study location were analyzed individually by parity. Sometribove treatment resulted in significantly higher SCC (P< 0.10) for the following location-parity groups: Dardenne IM (multiparous only), Cornell IM (multiparous only), Arizona IM (multiparous only), Dose-IM (multiparous only), Utah SQ (multiparous only), and TAS year one (primiparous only).

Data were then pooled for the Single Dose-IM (excluding the Utah location) study. Analyses showed that multiparous cows treated with 500 mg sometribove had significantly higher SCC than control multiparous cows. Also, when parities were pooled, SCC were statistically higher in treated cows (Table 71).

Results were also pooled from the 4 Dose-SC (excluding the Utah location), Dose-IM, and IM/SC studies. This analysis revealed no significant increase in SCC due to sometribove treatment (Table 72).

(Eds. note: The following table consists of 4 columns.)

Table 71.   Least-squares means for log (base 10) transformed SCC data pooled
across Dardenne, Arizona, and Cornell IM clinical trials. 


                         Sometribove Dose (mg)                               

Parity Group (n)          0               500             P           

Primiparous (68)            4.88               4.94             .2875         
Multiparous (223)           5.03               5.15             .0001         
Pooled parities (291)       4.99               5.10             .0001         

(Eds. note: The following table consists of 6 columns.)


Table 72.   

Least-squares means for log (base 10) transformed SCC data pooled
across Arizona SC, Cornell SC, Florida SC, Dose-IM, and IM/SC trials.
-----Sometribove Dose (mg)----- Parity Group (n) Control 250 500 750 P
Primiparous (126) 4.86 4.94 4.86 4.88 .6021 Multiparous (205) 4.97 5.05 5.03 5.05 .1997 Pooled parities (331) 4.93 5.01 4.97 4.99 .1391

To summarize, SCC were elevated in some herds. Removal of clinically mastitic cows from the analysis did not eliminate the effect. Since somatic cell counts are an indicator of the subclinical infection status of a herd, the elevations observed in some sometribove trials may have reflected the increased subclinical infection rate at these study locations.

Conclusions:

Administration of sometribove (500 mg/14 days): 1) increases the risk of clinical mastitis in both primiparous and multiparous cows; 2) increases the number of cases of clinical mastitis in both primiparous and multiparous cows; 3) increases the risk of subclinical mastitis in both parity groups; and 4) increases milk somatic cell counts in some herds. The product labeling advises of these effects to inform the user of risks associated on a per animal basis. Also, the labeling states that herd mastitis management practices should be thoroughly evaluated prior to initiating the use of sometribove.

FDA also concluded that the increase in clinical mastitis in sometribove-treated cows was not a public health concern with respect to antibiotic residues in milk being increased above tolerance due to therapeutic treatment of mastitis. Although the incidence of clinical mastitis was increased in treated cows, there was no indication that these cases of mastitis were more difficult to treat, as reflected by the similar average duration of cases between treated and control cows. When examined on a per unit milk basis, the increase in the incidence of clinical mastitis due to sometribove (approximately 0.1 case per cow per year) is about 4 to 9 times less than the effects due to other sources of variation, such as season, parity, stage of lactation, and herd-to-herd variation. For example, on a per unit milk basis, the increase in mastitis incidence from winter to summer is at least nine times greater than the increase due to sometribove treatment. Also, the increase in mastitis between early lactation (when sometribove would not be administered) compared to late lactation is at least seven times greater than the effect of sometribove. (See references by Smith et al. [1985, J. Dairy Science 68:1531]; Morse et al. [1988, J. Dairy Science 71:848]; and Hogan et al. [1989, J. Dairy Science 72:1547]).

Another important factor is that therapeutic drugs, such as antibiotics for the treatment of clinical mastitis, are to be used in food-producing animals only under approved conditions and with appropriate withdrawal periods (as established by FDA) to ensure that food products are safe for human consumption. State and Federal regulatory bodies currently monitor milk supplies for drug residues, and any milk that contains illegal residues is discarded. In addition, the dairy industry currently tests every tanker truck of milk for penicillin-like, beta-lactam drugs prior to processing. The beta-lactams are the most commonly used drugs for the treatment of mastitis so that even if an increase in use of these drugs--and an increase in illegal residues--occurred as a result of increased mastitis, any residues would result in the rejection of the milk before it could enter the market.

Allergic reactions are the most common side effect of the beta-lactam antibiotics, the predominant therapeutic treatment for clinical mastitis, and these agents are the most common cause of drug allergies. Three to 10 % of the human population is allergic to penicillin. Penicillin allergies develop following long-term (weeks) exposure to high doses (therapeutic). Once an individual is allergic to penicillin, smaller doses can cause an allergic reaction. Typically these reactions consist of a skin rash and are not considered to be significant health risks. In the last 25 years, there have been less than 10 cases of allergic reactions worldwide following the consumption of penicillin residues in milk (Dewdney et al., 1991, Food Chem. Toxicol. 21:477-483). All of these adverse reactions involved penicillin residues in the milk at levels well above FDA's current tolerance of 5 parts per billion (ppb). Currently, the commonly used screening test for beta-lactam residues in milk is the Bacillus stearothemophilus  disc assay, which detects penicillin residues at >=3-5 ppb. This provides an indication of the magnitude of the public health concern for violative antibiotic residues in food.

In view of the much larger variation in the number of clinical mastitis cases due to other factors, the monitoring of milk for illegal drug residues, and the minuscule public health concern for beta-lactam antibiotic residues in milk, FDA concluded that the use of sometribove was not important in considering the overall incidence of mastitis per unit of milk produced and therefore not a public health concern.

FDA's Veterinary Medicine Advisory Committee and expert consultants were convened for an open public hearing to discuss the issue of increased mastitis in sometribove-treated cows and a potential increase in the risk of antibiotic residues in milk on March 31, 1993. After hearing presentations from interested parties, and after considering the data presented to the Committee, the Committee concluded that, while sometribove treatment might cause a statistically significant increase in mastitis, the increased risk to human health posed by mastitis and resultant use of antibiotics was insignificant.

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