Independent · non-commercial · publishes on a quarterly cycle|Current cycle 2026 Q3
Compound Evidence InstituteEvidence synthesis · established 2023Graded assessments of compounds, trials, methods and supply
Document set current to 30 July 2026
Public comment period · §2

Draft monograph: Gonadorelin — submissions

The 9 submissions received, published in full with declared interests and secretariat responses.

Document identifier
CEI-CP-054/2
Series
Public comment period
Version
1.0
Published
08 Sep 2024
Last reviewed
08 Sep 2024
Next review
08 Sep 2025
Identifier
10.71829/cei.cp.54
Certainty
Not rated
Cycle
2024 Q3
Window
29 Jul 2024 – 28 Aug 2024
Status
Closed
Submissions
9

§2Submissions and responses

9 submissions were received. Each is published in full below with its declared interest, the secretariat response and the disposition. The Institute publishes submissions it did not accept in the same form as those it did.

Gaspard Kettlewell, BPharm, PhD National pharmacovigilance centre
DRAFT-GONADORELIN-/002 received 01 Aug 2024

The absence of a rare harm in the trial set is presented as reassurance

The draft states that a specific serious event was not observed in the contributing trials. The respondent states that trials of the size conducted here could not have detected an event at the frequency in question, and that reporting the absence without that arithmetic converts an uninformative result into a reassuring one.

The respondent proposes that the detectable frequency be stated wherever the absence of an event is reported.

Declared interest. Is a member of the Institute's external reviewer register but did not review the document under consultation.
Secretariat responseAccepted18 Sep 2024

The secretariat accepts this submission. The Institute's own framework treats an absent event in an underpowered set as uninformative, and the draft departed from it.

Wherever the monograph reports that an event was not observed, it now states the total exposure and the frequency the contributing trials could have detected, so that the absence is read as the limit of the evidence rather than as a finding.

Valentin Tollemache, PharmD, PhD University teaching hospital, department of endocrinology
DRAFT-GONADORELIN-/001 received 06 Aug 2024

The monograph does not tell a reader that a stated mass may be substantially counter-ion and water

The draft quotes vial contents in milligrams without stating whether the figure refers to peptide content or to total solids. For an acetate or trifluoroacetate salt of a peptide, the difference between the two can exceed a fifth of the stated mass.

The respondent, an analytical chemist, states that this is the single most consequential misreading in the field and that a monograph that does not address it directly is leaving the reader to discover it.

Declared interest. Has received consultancy fees from a supplier named in the Institute's supplier assessment set within the preceding two years.
Secretariat responseAccepted07 Sep 2024

The secretariat accepts this submission. Moderate certainty evidence from published analytical surveys suggests that content and total solids are routinely conflated in supply documentation, and the draft did not warn the reader.

The monograph now states, at the point where vial contents are first mentioned, that a mass figure is uninterpretable unless it states whether it is peptide content or total solids, and cross-references the content standard in the analytical series.

Dr Evander Whitmarsh-Obi, MD, MSc Community pharmacy practice, doctoral candidate
DRAFT-GONADORELIN-/005 received 07 Aug 2024

The recorded evidence gaps omit outcomes a reader would consider material

The evidence-gap section records what has not been studied. The respondent, a practising clinician, states that the list is drawn from the outcomes the trials chose to measure and therefore reproduces the sponsor's outcome selection rather than correcting for it.

The respondent proposes that the gap list be constructed from the outcomes a prescribing decision turns on, and that outcomes measured by no trial appear in it as such.

Declared interest. Employed by a national competent authority. This submission is made in a personal capacity and does not represent the position of that authority.
Secretariat responseAccepted in part18 Sep 2024

The secretariat accepts this submission in part. The gap list is reconstructed from the decision-relevant outcome set rather than from the measured set. The proposal that every unmeasured outcome be listed is declined, because an unbounded list of things not studied is not a finding.

The evidence-gap section is now derived from the anchor and decision-relevant outcomes for the indication, and any such outcome measured by no contributing trial is recorded as not measured rather than omitted.

Dr Nikolai Yeovil-Bakare, PhD (Chemistry), MRSC University department of pharmacy practice
DRAFT-GONADORELIN-/006 received 10 Aug 2024

Every contributing trial shares one sponsor and the monograph does not say so

The respondent, who has published a systematic review of this literature, states that all of the contributing trials for the principal outcome were conducted by a single sponsor, and that this is a property of the evidence base rather than a criticism of any individual trial.

The respondent proposes that sponsor concentration be recorded as a characteristic of the evidence base in the certainty assessment rather than as a note in the discussion.

Declared interest. No financial interest. Has published a systematic review reaching a different conclusion from the draft, which the respondent declares as a non-financial interest.
Secretariat responseAccepted20 Sep 2024

The secretariat accepts this submission. Sponsor concentration bears on what an independent replication would add, and the draft recorded it where a reader was least likely to see it.

Sponsor concentration is now stated with the certainty rating, and the monograph records how many independent sponsors contributed evidence to each assessed outcome.

Kolawole Oppenheimer-Ade, PhD (Pharmacology) Hospital microbiology and endotoxin testing service · industry submission
DRAFT-GONADORELIN-/007 received 16 Aug 2024

The monograph should reproduce the approved labelling rather than paraphrase it

The submission is made on behalf of the marketing-authorisation holder. It states that the draft paraphrases the approved indication, the posology and the contraindications, and that any paraphrase risks diverging from the authorised text.

The sponsor asks that the authorised wording be reproduced verbatim in each case, and offers the current summary of product characteristics as the source.

Declared interest. Is an employee of a marketing-authorisation holder for a compound named in the draft. This submission is made on behalf of that company and is identified as an industry submission throughout.
Secretariat responseAccepted in part27 Sep 2024

The secretariat accepts this submission in part. The authorised indication and the contraindications are reproduced verbatim and attributed. The posology is not, because the monograph reports what the trials administered as well as what the labelling authorises, and the two are frequently different.

The approved indication and contraindications are now reproduced verbatim from the named authorisation with its version and date, and the posology section reports the labelled schedule and the schedules studied side by side, with the source of each stated.

Dr Jozef Brandvold-Achterberg, PhD (Pharmacoepidemiology) Senior Lecturer in Pharmacoepidemiology
DRAFT-GONADORELIN-/008 received 20 Aug 2024

The pharmacokinetic section does not connect half-life to the dosing schedule

The draft reports a half-life and, separately, a dosing interval. The respondent, a clinical pharmacologist, states that the relationship between the two is what determines accumulation and time to steady state, and that the monograph leaves the reader to derive it.

The respondent proposes that time to steady state be stated explicitly, with the assumption from which it was derived.

Declared interest. Employed by a health technology assessment body that has issued guidance on a compound named in the draft.
Secretariat responseAccepted11 Sep 2024

The secretariat accepts this submission. The derivation is short, it is decision-relevant, and leaving it to the reader invites it to be done wrong.

The pharmacokinetic section now states approximate time to steady state alongside the half-life and dosing interval, with the assumption of first-order elimination stated, and records where the assumption is not supported for this compound.

Dr Fitzwilliam Danquah-Öberg, PhD (Chemistry), CChem Independent analytical consultant
DRAFT-GONADORELIN-/004 received 23 Aug 2024

Effect estimates are given without naming the comparator

Several estimates in the draft state an effect without stating what it was measured against. An estimate against placebo and an estimate against an active comparator are not the same quantity and the draft presents them in one column.

The respondent proposes that the comparator be part of every outcome row rather than a footnote, and that estimates against different comparators never share a column.

Declared interest. Holds a patent relating to a delivery technology referenced in the draft.
Secretariat responseAccepted22 Sep 2024

The secretariat accepts this submission. A footnoted comparator is a comparator a reader will not carry into the next row.

The comparator is now stated in every outcome row, and estimates against different comparators are reported in separate tables with the comparator named in the table caption.

Dr Frideswide Hazelrigg, PharmD, PhD University teaching hospital, department of endocrinology
DRAFT-GONADORELIN-/009 received 25 Aug 2024

A superseded version should remain reachable from the version that replaced it

The respondent states that the draft supersedes an earlier document and that a reader who cited the earlier version has no way to reach it from the new one, which makes it impossible to see what changed.

The respondent asks that every version carry a link both to what it supersedes and to what supersedes it.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseNoted, no amendment04 Sep 2024

The secretariat notes this submission. The corrections and versioning policy already requires bidirectional version links and every superseded document is retained at its own address.

No amendment arises. The requirement is stated in the corrections and versioning policy and the amendment log of this document links to the version it replaced. The respondent is correct that the link was absent from the draft page furnished for consultation, which was a defect of the consultation copy and not of the policy.

Adaeze Underhill-Okafor, PhD (Medicinal Chemistry) University department of public health
DRAFT-GONADORELIN-/003 received 27 Aug 2024

Absence of evidence is presented in a form a reader will take as negative evidence

Where the Institute has identified no study, the draft states that no evidence was found. In several places that sentence sits immediately after a paragraph describing an adverse outcome, and the juxtaposition invites the reading that the compound was studied and found wanting.

The respondent proposes a standing formulation, used identically wherever the situation arises, distinguishing an outcome that was studied and not demonstrated from an outcome that has not been studied at all.

Declared interest. Is a trustee of a patient organisation that has received a restricted educational grant from a manufacturer in the class under assessment.
Secretariat responseAccepted05 Sep 2024

The secretariat accepts this submission. The two states are different, they support different decisions, and the draft rendered them in language a reader could not reliably separate.

A standing formulation has been adopted and is applied wherever an evidence gap is recorded, distinguishing an outcome assessed and not demonstrated from an outcome not assessed. The formulation is identical at every occurrence so that it can be recognised at a glance.

References cited on this page

References are numbered in order of first citation in this document. Each superscript in the text links to its entry below.

  1. International Organization for Standardization. ISO/IEC 17025:2017 General Requirements for the Competence of Testing and Calibration Laboratories. ISO/IEC Standard 2017;3rd edition. identifier not held by the Institute

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