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: Glutathione — submissions

The 14 submissions received, published in full with declared interests and secretariat responses.

Document identifier
CEI-CP-053/2
Series
Public comment period
Version
1.0
Published
29 Mar 2024
Last reviewed
29 Mar 2024
Next review
29 Mar 2025
Identifier
10.71829/cei.cp.53
Certainty
Not rated
Cycle
2024 Q1
Window
08 Feb 2024 – 07 Mar 2024
Status
Closed
Submissions
14

§2Submissions and responses

14 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.

Dr Séverine Oduya-Kaltenbrunner, PhD Head of Mass Spectrometry, academic core facility
DRAFT-GLUTATHIONE-/012 received 10 Feb 2024

Doses are expressed in units that differ between sections

The draft expresses dose in milligrams in one section and in micrograms per kilogram in another, drawn from different sources without conversion. The respondent, a hospital pharmacist, states that this is the shape of error that reaches a patient.

The respondent proposes a single unit throughout, with the source unit retained in parentheses where a conversion was performed.

Declared interest. No interest to declare. The respondent is a graduate student and states that the submission forms no part of any assessed work.
Secretariat responseAccepted15 Mar 2024

The secretariat accepts this submission. The inconsistency was inherited from the sources and should have been resolved in drafting.

A single dose unit is now used throughout each monograph, with the source unit retained in parentheses wherever a conversion was applied, and every conversion is stated rather than performed silently.

Xiomara Fairweather-Duru, PhD (Analytical Chemistry) Patient advocacy organisation
DRAFT-GLUTATHIONE-/008 received 11 Feb 2024

Quantitative claims are reproduced without the method that produced them

Several figures in the draft are quoted from sources that determined them by different methods. A figure obtained by one determination and a figure obtained by another are not comparable, and the draft places them in the same sentence without distinguishing them.

The respondent, an analytical chemist, proposes that every quantitative claim carry the method that produced it at the point of use rather than in the reference.

Declared interest. Holds a personal shareholding, below the Institute's materiality threshold, in a diversified fund with pharmaceutical sector exposure. No direct holding in any named company.
Secretariat responseAccepted21 Mar 2024

The secretariat accepts this submission. Placing two figures side by side is an implicit claim that they are the same kind of quantity, and in the cases identified they were not.

Every quantitative claim now carries the determination that produced it at the point of use, and figures obtained by non-comparable methods are no longer presented in the same row or sentence.

Dr Liesbeth Achterberg, MPharm, MRPharmS Academic nephrology unit
DRAFT-GLUTATHIONE-/011 received 13 Feb 2024

The certainty rating for the principal assessed outcome cannot be traced to the contributing trials

The draft states a certainty rating for the principal assessed outcome and lists the contributing trials, but does not state which domain drove the downgrade. A reader who disagrees with the rating cannot tell whether the disagreement concerns risk of bias, imprecision, indirectness or inconsistency.

The respondent proposes that each rating carry its downgrade reasons explicitly, in the same row as the rating, so that a reader can accept the evidence assessment while disputing a single domain judgement.

Declared interest. Employed by a health technology assessment body that has issued guidance on a compound named in the draft.
Secretariat responseAccepted28 Mar 2024

The secretariat accepts this submission. A rating without its reasoning is an assertion, and the draft asserted rather than showed.

Each assessed outcome now carries its downgrade domains in the summary-of-findings row, with a short statement of the judgement made in each, so that the rating can be checked domain by domain against the contributing trials.

Dr Amara Vandergraaf, MD, MRCP Independent analytical consultancy
DRAFT-GLUTATHIONE-/014 received 13 Feb 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 amendment07 Apr 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.

Ms Rhiannon Okoye-Vandergraaf, BSc, patient representative Patient representative
DRAFT-GLUTATHIONE-/005 received 15 Feb 2024

A purity figure from a certificate is quoted as though it were a content figure

The draft quotes a purity percentage from supply documentation in a sentence about how much compound a vial contains. Chromatographic purity is a relative area within what was detected; it is not a mass fraction and it does not bound vial content.

The respondent, an analytical chemist, proposes that purity and content never appear in the same sentence without an explicit statement that they answer different questions.

Declared interest. Has previously served as an investigator on a trial included in the evidence base under consultation. Received no personal payment; institutional payment was made to the trial site.
Secretariat responseAccepted01 Apr 2024

The secretariat accepts this submission. The conflation is the error the Institute most often corrects in supply documentation, and it appeared in an Institute draft.

Purity and content are now reported in separate rows with separate definitions, and the monograph states that a purity figure sets no bound on content and that a content figure requires a determination against a standard of assigned content.

Leonhard Achterberg, PhD (Pharmaceutics) Endocrine surgery service
DRAFT-GLUTATHIONE-/010 received 16 Feb 2024

Mechanistic claims for a peptide fragment are carried without evidence that the fragment acts as described

The respondent states that the draft repeats a mechanistic account originating in supply documentation rather than in the primary literature, and that the account attributes activity to a fragment on the basis of the activity of the parent molecule.

The respondent proposes that any mechanistic claim be traceable to a primary source and removed where it is not.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted21 Mar 2024

The secretariat accepts this submission. A mechanism repeated from marketing material has no evidential status regardless of how widely it is repeated.

Mechanistic claims not traceable to a primary source are removed, and those retained carry their source and a statement of whether the underlying work was conducted in vitro, in animals or in humans.

Dr Leonhard Quenneville, MD, PhD, FESC ISO/IEC 17025-accredited contract testing laboratory
DRAFT-GLUTATHIONE-/002 received 20 Feb 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. Is a member of the Institute's external reviewer register but did not review the document under consultation.
Secretariat responseAccepted21 Mar 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 Stellan Cholmondeley-Ade, MD, MSc Community pharmacy practice, doctoral candidate
DRAFT-GLUTATHIONE-/007 received 20 Feb 2024

Where the compound is a glucagon-like peptide-1 receptor agonist, the cardiovascular outcome evidence should be an assessed outcome

The respondent states that for compounds in this class the cardiovascular outcome evidence, reported for semaglutide in SELECT in the New England Journal of Medicine in 2023 and for liraglutide in LEADER in the same journal in 2016, is the evidence a prescribing decision most often turns on, and that the draft treats it as background.

The respondent proposes that cardiovascular outcomes be an assessed outcome with its own certainty rating for every compound in the class for which such a trial exists.

Declared interest. Employed by an analytical laboratory that performs contract testing for suppliers, including at least one supplier named in the Institute's assessment set.
Secretariat responseAccepted in part25 Mar 2024

The secretariat accepts this submission in part. Cardiovascular outcomes become an assessed outcome where a dedicated outcome trial of the compound exists. The proposal to extend the rating across the class by inference is declined, in line with the treatment of class-level extrapolation elsewhere in the series.

Cardiovascular outcomes are now an assessed outcome with their own certainty rating in every monograph for which a dedicated cardiovascular outcome trial of that compound has reported, and are recorded as not assessed elsewhere.

Dr Ilona Mbatha-Fredriksen, MD, MSc Consultant Paediatric Endocrinologist
DRAFT-GLUTATHIONE-/001 received 24 Feb 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. Has received consultancy fees from a supplier named in the Institute's supplier assessment set within the preceding two years.
Secretariat responseAccepted06 Apr 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.

Dr Ndidi Ravensworth-Ilunga, MD, MSc (Clinical Trials) Clinical Trials Unit, academic · industry submission
DRAFT-GLUTATHIONE-/009 received 26 Feb 2024

The document should not describe uses outside the approved indication

The submission is made on behalf of a marketing-authorisation holder. It states that the draft describes uses of the compound that fall outside the approved indication, that such uses are not supported by the sponsor, and that describing them may be read as legitimising them.

The sponsor asks that the sections concerned be removed, or in the alternative that they carry a prominent statement that the sponsor does not support such use.

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 responseNot accepted21 Mar 2024

The secretariat does not accept this submission. The Institute records what is supplied and what is used, because a reader encountering a compound outside a regulated route is the reader most in need of an assessment of the evidence for it.

The sections remain. Every such section already states the regulatory status of the use described and states that the evidence for it is assessed separately from the evidence for the approved indication. The submission is published in full and identified as an industry submission.

Dr Lorcan Whitmarsh-Obi, MSc (Regulatory Affairs) Public-sector clinical trials unit
DRAFT-GLUTATHIONE-/004 received 28 Feb 2024

The analytical section is longer than the clinical assessment it accompanies

The respondent, an academic pharmacologist, states that the analytical section occupies more of the monograph than the assessment of clinical effect, and that the proportions imply the Institute considers the analytical question the more important one.

The respondent proposes that the analytical material be moved to the standards series and referenced rather than reproduced.

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 Mar 2024

The secretariat accepts this submission in part. The general analytical material is moved to the standards series and referenced. The compound-specific material stays, because a reader holding a certificate for this compound needs to know what that certificate does and does not establish for this compound.

The analytical section is reduced to compound-specific content and cross-references the relevant standards for the general procedure, which shortens it substantially without removing what is not available elsewhere.

Dr Fenella Steenkamp-Ferreira, MD, FRCP Independent evidence-synthesis consultancy
DRAFT-GLUTATHIONE-/006 received 01 Mar 2024

The preclinical section is extensive and the clinical section is not

The draft summarises a large animal literature and a small or absent human literature. The respondent states that the resulting document reads as though a great deal is known, when what is known concerns rodents.

The respondent proposes that the preclinical section be reduced to a statement of what has been observed in animals and that the detail be removed entirely.

Declared interest. Is a practising clinician who prescribes compounds in the class under assessment. No financial relationship with any manufacturer.
Secretariat responseAccepted in part18 Mar 2024

The secretariat accepts this submission in part. The section is shortened and given a standing statement. The proposal to remove the detail is declined, because a reader encountering claims derived from that literature needs to be able to see what it actually contains.

The preclinical section is reduced in length, placed after the clinical assessment rather than before it, and opens with a standing statement that an effect observed in an animal model is not a clinical outcome and does not support a certainty rating.

Dr Kolawole Isaksen-Balogun, MD, MRCP Independent analytical consultancy
DRAFT-GLUTATHIONE-/003 received 04 Mar 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. Has used a compound in the class under assessment under prescription. Declared at the Institute's request; the Institute regards a lived-experience declaration as an interest and not as a disqualification.
Secretariat responseAccepted in part06 Apr 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 Hyacinth Oyelaran-Steen, PhD (Chemistry), MRSC University department of pharmacy practice
DRAFT-GLUTATHIONE-/013 received 07 Mar 2024

Trials are described as terminated where they completed as planned

The respondent states that the draft uses the word terminated for trials stopped at pre-specified interim analyses, for trials stopped for futility and for trials closed for commercial reasons, and that these are three different facts.

The respondent proposes that the status vocabulary be fixed and defined in the glossary.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted in part29 Mar 2024

The secretariat accepts this submission in part. The vocabulary is fixed and defined. The proposal to distinguish commercial closure from futility in every case is accepted only where the Institute holds a document stating the reason.

Trial status now uses a fixed vocabulary defined in the glossary, and where the reason for stopping is not evidenced by a document the Institute holds, the status is recorded as stopped with the reason not established rather than assigned.

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

Identifiers are reproduced only where the Institute holds them. Where a digital object identifier or PubMed identifier is not shown, the Institute has recorded the journal and year and has not constructed an identifier.

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