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.

Dr Jozef Brandvold-Achterberg, PhD (Pharmacoepidemiology) Senior Lecturer in Pharmacoepidemiology · submitting on evidence synthesis
DRAFT-GONADORELIN-/001 received 01 Aug 2024

Trials are described as terminated where they completed as planned

The respondent notes that the draft on Gonadorelin rests largely on physiological studies rather than on clinical trials, and submits with that in view.

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 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 responseAccepted in part18 Sep 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.

Quentin Whitmarsh-Obi, MSc (Clinical Pharmacy) Regional hospital pharmacy department · submitting on medicines information
DRAFT-GONADORELIN-/002 received 06 Aug 2024

The compound is supplied under names the monograph does not list

The respondent has read the draft covering Gonadorelin and makes one submission.

The respondent states that the compound is supplied under several trade names, research codes and transliterations, and that a reader holding a label bearing one of them will not find the monograph.

A list of names observed in supply, with the source of each observation, accompanied the submission.

The respondent endorses the general approach taken in submission 001 and asks that it be extended to the matter identified here.

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 responseAccepted07 Sep 2024

The secretariat accepts this submission. A monograph a reader cannot find is not serving the reader.

The synonym list is extended to include every name the Institute can evidence from a document it holds, each recorded with its source. Names asserted without a supporting document are not added, and the distinction is stated at the head of the list.

Dr Rurik Haverkamp-Diallo, MD, FFPH University department of public health · submitting on public health
DRAFT-GONADORELIN-/003 received 07 Aug 2024

Declared interests should appear on the document rather than on a separate page

The respondent submits on the draft monograph for Gonadorelin. Reproductive-axis peptides act on a system with strong feedback, and a document that describes an effect without the feedback response describes half of it.

The draft links to a central conflicts register. The respondent argues that a reader assessing whether to rely on a particular document should not have to leave it to find out who assessed it and what they declared.

The respondent proposes that the interests of every named contributor to a document be printed on that document.

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 responseNoted, no amendment18 Sep 2024

The secretariat notes this submission and records that the draft already provides for it, which the respondent could reasonably have missed because the provision sits in an appendix.

Every document carries the declared interests of its named contributors in its front matter, and the central register exists so that a reader can see a person across all documents rather than one at a time. No amendment arises; the provision has been moved from the appendix into the body of the methodology document so that it is findable.

Dr Zdenka Ximenes, MD, MPH National pharmacovigilance centre · submitting on pharmacovigilance
DRAFT-GONADORELIN-/004 received 10 Aug 2024

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

The respondent read the draft on Gonadorelin and has confined this submission to a single matter.

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. 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 responseAccepted20 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.

Dr Fenella Lavrentiev, MD, FRCP Endocrine surgery service · submitting on endocrinology
DRAFT-GONADORELIN-/005 received 16 Aug 2024

The difference between pulsatile and continuous administration is not addressed

The respondent’s comment on the draft for Gonadorelin arises from practice in a service where this axis is investigated.

For an axis regulated by feedback, continuous exposure and intermittent exposure can produce opposite effects, and the compound is supplied in a form and schedule that differs from the one studied. The monograph reports the studied effect without recording the schedule that produced it.

The respondent proposes that the administration schedule be stated with every effect estimate for compounds acting on a feedback-regulated axis, and that the reversal be described once in the pharmacology section.

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 responseAccepted27 Sep 2024

The secretariat accepts this submission. For this class the schedule is not a detail of the method; it determines the direction of the effect.

The administration schedule is now stated with every effect estimate for these compounds, and the pharmacology section describes the dependence of direction on schedule.

Dr Eamon Immelmann, PhD (Chemistry), CChem Independent analytical consultancy · submitting on analytical chemistry
DRAFT-GONADORELIN-/006 received 20 Aug 2024

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

The respondent submits on Gonadorelin. The point would apply equally to any document in the series.

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. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted11 Sep 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.

Dr Quentin Zimmerthal, PhD (Chemistry), CChem Independent analytical consultancy · submitting on analytical chemistry
DRAFT-GONADORELIN-/007 received 23 Aug 2024

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

Having read the draft monograph on Gonadorelin, the respondent puts one point to the committee.

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. 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 responseAccepted22 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 Abimbola Sotomayor-Ekwueme, PharmD, PhD Reader in Pharmaceutics · submitting on pharmaceutics
DRAFT-GONADORELIN-/008 received 25 Aug 2024

The route of administration studied is not the route in which the compound is supplied

The respondent read Gonadorelin in draft. The point applies to it and to the series generally.

The clinical section describes findings obtained by one route and the supply section describes presentations intended for another. A reader moving between the two sections will carry the effect estimate across the change without noticing that it has been carried, because nothing on the page marks the transition.

The respondent proposes that where the studied route and the supplied presentation differ, the difference be stated in the assessed-outcome table itself rather than in the supply section, on the ground that a reader consults the outcome table and does not always reach §8.

Declared interest. Has received consultancy fees from a supplier named in the Institute's supplier assessment set within the preceding two years.
Secretariat responseAccepted04 Sep 2024

The secretariat accepts this submission. The route by which an estimate was generated is a condition of the estimate and belongs beside it.

The assessed-outcome table now carries the studied route in every row, and a standing note appears wherever the supplied presentation differs from it.

Dr Ivo Quintanilha, MD, MSc (Clinical Trials) University department of public health · submitting on evidence synthesis
DRAFT-GONADORELIN-/009 received 27 Aug 2024

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

This submission concerns the draft on Gonadorelin and is made by a respondent who has published on the axis it acts on.

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 responseAccepted05 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.

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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