Recently I wrote to the MHRA to ask the basis for the recommendation that liothyronine be dispersed/dissolved when a dose of less than one tablet is prescribed.
Today I have received their response. The entire text may be found below.
Thank you for your further request, made under the Freedom of Information (FOI) Act and dated 06 October 2018, where you asked to “know the basis of the decision that tablet splitting is not appropriate which would, of course, include data demonstrating unsatisfactory dosing in patients splitting tablets contrasted against satisfactory dosing in patients using the described dissolving technique.”
Ease of sub-division of tablets (“splitting”) is influenced by the size, shape and physical characteristics of the tablet. Tablets that are round in shape and have a relatively small diameter present significant challenges to uniform tablet sub-division. This is the case for liothyronine 20 microgram tablets marketed in the UK; all of which are round in shape and range between 5.5 - 6.0 mm in diameter. Further, attempts to sub-divide small tablets, such as liothyronine 20 microgram tablets, will present difficulties to patients or carers with limited manual dexterity.
Marketing authorisation holders that propose that a tablet should be sub-divided for purposes of dosing require to demonstrate compliance with the general test for uniformity of sub-division, included within the European Pharmacopeia monograph for Tablets (0478). This test method requires that a specified number of sub-divided tablet halves are weighed and that the uniformity of the individual weights (“uniformity of mass”) meets certain acceptance criteria. Data from clinical studies in humans for this purpose does not require to be presented; indeed such studies would be considered unethical as the content of drug substance in sub-divided tablets may be determined directly by analytical means.
However, for tablets containing a very low percentage of a potent active substance, assessment of uniformity of mass of sub-divided tablets is not considered to provide sufficient assurance of dose uniformity as while the weight of tablet halves may be uniform, the content of active substance within the tablet halves may vary significantly. This is the case for liothyronine 20 microgram tablets where the content of active substance is ~ 0.025% w/w of the tablet. For tablets containing a potent active substance, tablet crumbling / fragmenting as a result of tablet sub-division also presents an unacceptable risk of loss of active substance and surface contamination. The scientific literature contains a number of publications where difficulties with reproducible sub-division and poor dose uniformity have been highlighted when studying ease and uniformity of sub-division of tablets containing potent active substances.
To summarise, it is the view of the MHRA that tablet sub-division is inappropriate for tablet presentations of liothyronine 20 microgram tablets as accuracy of the dose is not adequately assured. This position has been strongly endorsed by experts of the Commission on Human Medicines (CHM) and its Expert Advisory Committee for Chemistry and Pharmacy Standards. The above forms the basis of the decision that tablet splitting is not appropriate for liothyronine tablets.
Liothyronine 20 microgram tablets may be dissolved in a glass of water. This ensures that the active substance is uniformly distributed in the volume of liquid in the glass. With the help of a measuring device, liothyronine may then be accurately dosed. This method of subdividing the dose by dissolving the tablets in water has been discussed with and endorsed by experts of the Commission on Human Medicines (CHM) and its Expert Advisory Committee for Chemistry and Pharmacy Standards.
If you are dissatisfied with the handling of your request, you have the right to ask for an internal review. Internal review requests should be submitted within two months of the date you receive this response and addressed to: info@mhra.gov.uk. Alternatively, you may write to:
The Communications Division
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The practice and clinical implications of tablet splitting in international health; Ivo Elliott et al; Volume 19 no 7 pp 754–760
onlinelibrary.wiley.com/doi...
The accuracy, precision and sustainability of different techniques for tablet subdivision: Breaking by hand and the use of tablet splitters or a kitchen knife; Diana Van Riet-Nales et al, Volume 466, Issues 1–2, 15 May 2014, Pages 44-51
sciencedirect.com/science/a...
Tablet splitting: a review of weight and content uniformity; MK Freeman et al; Consult Pharm. 2012 May;27(5):341-52. doi: 10.4140/TCP.n.2012.341.
[Abstract only available.]
researchgate.net/publicatio...
[I have just added links for the references indicated by the MHRA.]