Professional Documents
Culture Documents
Pharmacovigilance A Practical Approach 1st Edition
Pharmacovigilance A Practical Approach 1st Edition
MONDIRA BHATTACHARYA, MD
Former Senior Medical Director
Safety Science
Pharmacovigilance and Patient Safety
AbbVie
North Chicago, Illinois, United States
FABIO LIEVANO, MD
Vice President
Safety Science
Pharmacovigilance and Patient Safety
AbbVie
North Chicago, Illinois, United States
LINDA SCARAZZINI, MD
Vice President
Pharmacovigilance and Patient Safety
AbbVie
North Chicago, Illinois, United States
]
3251 Riverport Lane
St. Louis, Missouri 63043
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v
vi LIST OF CONTRIBUTORS
We would like to thank our families, friends, and We wish to thank Dawn Dvorak, Shannon Gacke,
colleagues for their insights, support, and encourage- Jennifer Koeller, Mary Locicero, Rosalind Munoz, Pam
ment in this endeavor to make an impact on the future Spezialetti, and Adrienne Towles for their assistance.
of medical safety and pharmacovigilance. The authors acknowledge and thank their patients
We appreciate the following reviewers for their whose lived experiences have contributed to the science
thoughtful comments: Ronda Goldfein, Sherrie Gallas, of pharmacovigilance.
Katherine Hiegel, Paul J. Lee, Jianzhong Liu, Jennifer Finally, we appreciate the support from Elsevier,
Manski, Gregory Pawell, Pam Puttfarcken, Jorge Ng with special thanks to Kayla Wolfe, Nadhiya Sekar,
Zheng, Sudhir Penugonda, Diane Schommer, and and Jennifer Horrigan.
Susanna Sit.
We also acknowledge the help of Christopher Sinclair
and David Sternala with the artwork in several chapters.
ix
Introduction
xi
SECTION I THE REGULATORY ENVIRONMENT
CHAPTER 1
1
2 SECTION I The Regulatory Environment
BOX 1.2
BOX 1.1 Thalidomide Use Today
The Trigger for Global PV Thalidomide is available today for the treatment of several
The thalidomide disaster triggered global regulations devastating medical conditions, such as leprosy and
requiring evaluation of both efficacy and safety of new multiple myeloma, due to risk minimization measures
medicines. being implemented.
24,000 affected babies were born worldwide, with a chapter 13). When thalidomide was reintroduced into
significantly large number of miscarriages and stillbirths the market, it came with one of the first comprehensive
in women also attributable to thalidomide. The Pregnancy Prevention Programs. The program provides
disaster resulted in significant changes globally to the educational information for both prescribers and pa-
regulation of medicines, requiring more rigorous clin- tients on the risks of using thalidomide and the impor-
ical trial testing and the need to demonstrate both the tance of avoiding pregnancy while receiving the drug.
efficacy and the safety of new medicines. Much of The supply of the drug is also carefully controlled.
what occurs today in PV is rooted in the lessons learned Dispensing pharmacies must register with the program
from thalidomide (Box 1.1). and understand the limited circumstances under which
Interestingly, the drug is still used today because it the drug can be dispensed. Female patients of child-
was found to be effective in a complication of leprosy bearing age must agree to use contraception and a nega-
and multiple myeloma.3 In addition to the lessons tive pregnancy test result must be provided before each
learned from the birth defects, the continued use of month’s supply of drug is issued. Pharmacies are
thalidomide has been made possible for diseases where required to maintain accurate records of treatment.
the benefit-risk balance is determined to be positive Although the program has been very successful, it has
(Box 1.2). This has provided the opportunity to develop not completely prevented further babies from being
strategies and methodologies for risk minimization (see born with the devastating birth defects.
CHAPTER 1 Does Regulation Drive Science or Does Science Drive Regulation? 3
Worldwide there was a unified desire to never let Two main organizations, supported by a number of
another thalidomide tragedy happen again. Countries non-profit industry trade organizations, are credited
began to set up national systems for the collection of with creating the foundation of modern PV: the Council
adverse drug reaction reports. In 1967 the World Health for International Organizations of Medical Sciences
Organization (WHO) received their mandate to start a (CIOMS) and the International Council for Harmonisa-
research project on the International Monitoring of tion (ICH).
Adverse Drug Reaction Reports; this work continues CIOMS was established in 1949. Based in
today.4 In 1968 the UK regulatory authority introduced Switzerland, the mission of CIOMS was to advance
the Medicines Act that governs the control of medicines public health through guidance on health research,
for human use and veterinary use, including the manu- including ethics, medicine development, and safety.
facture and supply of medicines. This act remains the Through its different expert advisory working groups,
foundation of UK legislation today. The importance CIOMS has set many of the global standards and
of PV took hold across the world but responses thinking around key PV topics. The CIOMS-1 form12
continued to be reactive. is one of the best known examples of CIOMS work
and it sets the international standard for exchange of
safety information between organizations, regulators,
IMPORTANT PHARMACOVIGILANCE and countries (Box 1.3).
ORGANIZATIONS ICH was formed by regulators in the United States,
The creation of the most influential PV organizations Europe, and Japan in the 1990s. By this time, some coun-
throughout the world is described in Fig. 1.2.5e11 tries had developed national PV regulation aimed at pro-
Some of these groups were developed as non-profit, tecting patient safety and public health. However, as each
non-governmental organizations whose aim was to set country’s regulations were developed in isolation, the re-
international harmonized PV principles and standards. sults were sometimes contradictory or duplicative. The
FIG. 1.4 Comparison between the US and EU pharmacovigilance regulations. (Sources: FDA & EMA
websites November 06, 2017.)
medicines and for reviewing and assessing all aspects of • Periodic Safety Update Reports;
risk management (Box 1.6). • Post authorization Safety Studies (PASS);
Specifically, the PRAC reviews: • Renewals of marketing authorizations.
• Product referrals for safety reasons;
Each PRAC member is chosen on the basis of the
• Safety signal assessment and prioritization;
strength of their expertise in PV and risk assessment
• Risk management plans, both pre- and post-
of medicines. Although the meetings themselves are
authorization;
CHAPTER 1 Does Regulation Drive Science or Does Science Drive Regulation? 7
Is Regulatory Guidance Just Guidance? from existing international requirements and promote
In addition to regulations stated in law, regulatory guid- alignment with neutral international standards (such
ance linked to PV activities can exist in different forms. as ICH or CIOMS) or influence the addition of new
This includes formal published guidance, question and requirements.
answer documents, letters to MAHs, written correspon- Regulators such as EMA and FDA hold regular public
dence between the MAH and the regulatory authority, meetings with all stakeholders who have an interest in
and verbal guidance given during conferences and sym- PV (for example, industry trade associations, academia,
posia. Additional detail provided in published guidance and patient associations) and are willing to meet with
enables clarity in interpretation of the legal obligations. the industry. Industries have been successful in driving
There is a hierarchy associated with guidance. For meaningful change through these interactions.
example, in Europe the EU GVP guidance28 is at the
top of this hierarchy, so any deviation from it should Enforcement of Pharmacovigilance
be carefully considered. When it comes to the assess- Regulations
ment of compliance with the EU guidance through reg- Similar to other industries, regulatory authorities who
ulatory inspections, a critical finding is defined as define PV regulations need to have an effective mecha-
nism in place to monitor and enforce compliance to
A deficiency in pharmacovigilance systems, practices or
the requirements (Box 1.8). There are slightly different
processes that adversely affects the rights, safety or well-being
approaches taken globally, but the key to achieve the
of patients or that poses a potential risk to public health or that
represents a serious violation of applicable legislation and greatest degree of compliance is linked to the effective-
guidelines.29 ness of the following strategies:
1. Setting the standards
This is in contrast to the more pragmatic approach of If requirements are sufficiently detailed and are clear
the formal FDA Guidance for Industry that states that and proportionate to the local environment and
that guidance contains nonbinding recommendations needs, there is a greater likelihood of compliance
and includes the following statement: being achieved for the majority of companies that
This guidance represents the current thinking of the Food and strive to comply.
Drug Administration (FDA or Agency) on this topic. It does 2. Performing inspections
not establish any rights for any person and is not binding on This is the main approach to assess compliance.
FDA or the public. You can use an alternative approach if Regulatory inspectors visit MAHs to assess the
it satisfies the requirements of the applicable statutes and systems, personnel, and procedures in place to
regulations. To discuss an alternative approach, contact the
determine the degree of compliance. Any de-
FDA office responsible for this guidance as listed on the title
ficiencies are graded into three categories: critical,
page.30
major and minor. A report is usually provided, to
Collaborative partnership among MAHs, regulatory which the company must respond and commit to
agencies, and patients will facilitate evolution of taking action to address any deficiency. Adequacy of
thoughtful and practical PV regulations, which is critical these actions can be assessed on re-inspection of the
for advancing benefit-risk monitoring of medicines and MAH at a future date. If the finding is significant some
their use in the real world.
regulatory authorities require written evidence of assessment of medicines has become much more trans-
completion of the action. There is a harmonized parent and dynamic. Leading regulatory agencies are
approach to inspections in the EU that is coordinated hugely influential globally and information made pub-
by the EMA;31 however, there is no international lic from these agencies can lead to a global focus on
harmonization for PV inspections. A risk-based safety issues. However the breadth and complexity of
approach is commonly adopted to determine which PV frameworks in well-resourced countries, may not
companies are inspected and how frequently they are be the right approach for resource-limited regulators.
inspected. This may include gathering information A “right-size” PV approach is advised to newer regula-
from other parts of the regulatory agency that tors, with harmonization of PV legislation where
monitor quality and timeliness of safety information possible. Early identification of safety issues via more
submitted by a company. recent sources of safety information such as social me-
3. Educating and advising dia is a priority for regulators and the industry alike.
Regulatory authorities engage and educate stake- Regulators are working hard to keep up with new
holders through trade association meetings or con- technologies such as robotic automation and artificial
ferences to enhance understanding and practical intelligence, and with innovation in drug development
application of the requirements, which in turn and delivery. However, the rate of change is very fast.
increases the likelihood of compliance. Additional Therefore the answer to whether regulation drives sci-
methods include publishing guidance such as the ence or whether science drives regulation is that science
Medicines and Healthcare products Regulatory and technology appear to be driving regulation in our
Agency’s (MHRA) Good Pharmacovigilance Practice rapidly moving digital environment.
guide (the “Purple” guide) and publishing inspec-
tion metrics.32,33
4. Warnings REFERENCES
Warning letters and making information public 1. US Food and Drug Administration. http://wwwfda.gov.
where there is significant and/or persistent AboutFDA/WhatWedo/History; 2017.
noncompliance provides an opportunity for the 2. Thalidomide Society. www.thalidomidesociety.org; 2017.
recipient to rectify the noncompliance before formal 3. Greenstone G. Special feature: the revival of thalidomide:
legal action is taken. It also acts as either a deterrent from tragedy to therapy. BC Med J. 2011;53(5):203e233.
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clarity to the authorities’ expectations. Two examples ines/areas/quality_safety/safety_efficacy/advdrugreactions/
en/; 2017.
of these letters are the used in the United Kingdom
5. World Health Organization. http://www.who.int/about/
and the FDA 483 warning letters.32,34
en/; 2017.
5. Enforcement action 6. Council for international Organizations of Medical
Regulators can take legal action for the most serious Sciences. https://cioms.ch/about/; 2017.
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example, in the EU, financial penalties can be & Associations. https://www.ifpma.org/who-we-are/ifpma-
imposed for the infringement of PV obligations. This in-brief/; 2017.
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the preceding business year, which is a significant Associations. https://www.efpia.eu/about-us/; 2017.
deterrent.35 9. Uppsala Monitoring Centre. https://www.who-umc.org/
global-pharmacovigilance/who-programme/; 2017.
10. The International Council for Harmonization of Technical
CONCLUSIONS Requirements for Pharmaceuticals for Human Use. http://
In recent years, regulators and This is resulting in newer www.ich.org/home.html; 2017.
regulations are more focused on proactive safety 11. The International Society of Pharmacovigilance. http://
measures. There is emphasis on earlier signal detection isoponline.org/; 2017.
12. CIOMS-1. Form: https://cioms.ch/wp-content/uploads/
capabilities and risk proportionate approaches to
2017/05/cioms-form1.pdf; 2017.
decision-making. This is resulting in earlier provision 13. The Pharmaceutical and Medical Devices Agency. https://
of relevant safety information to prescribers and www.pmda.go.jp/english/; 2017.
patients. Robust and comprehensive PV legislation is 14. European Medicines Agency. http://www.ema.europa.
in place in countries with mature PV systems, which eu/ema/index.jsp?curl¼pages/about_us/general/general_
include education and enforcement processes. Risk content_000091.jsp; 2017.
CHAPTER 1 Does Regulation Drive Science or Does Science Drive Regulation? 11
15. European Economic Area. http://www.europarl.europa. 27. Ghana Food and Drugs Authority Guidelines for Qualified
eu/atyourservice/en/displayFtu.html?ftuId¼FTU_6.5.3. Person for Pharmacovigilance. March 1, 2013. FDA/SMC/
html; 2017. SMD/GL-QPP/2013/03, Version 2.
16. Olsson S, Pal SN, Dodoo A. Pharmacovigilance in resource- 28. EMA GVP Modules; 2017. http://www.ema.europa.eu/
limited countries. Expert Rev Clin Pharmacol. 2015;8(4): ema/index.jsp?curl¼pages/regulation/document_listing/
449e460. document_listing_000345.jsp.
17. UMC. https://www.who-umc.org/vigibase/vigibase/; 2017. 29. EMA. Union Procedure on the Preparation, Conduct and
18. Website: African Medicines Regulatory Harmonisation Reporting on EU Pharmacovigilance Inspections. March 21,
(AMRH) NEPAD; 2017. www.nepad.org. 2014. EMA/INS/PhV/192230/2014.
19. EMA. European Medicines Agency Process for Engaging in 30. FDA Providing Postmarketing Periodic Safety Reports in
External Regulatory Sciences and Process Improvement Activ- the ICH E2C (R2) Format (Periodic Benefit Risk-Benefit
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20. FDA. Office of the Chief Scientist: Advancing Regulatory 31. EMA Coordination of Pharmacovigilance Inspections; 2017.
Science for Public Health. Oct. 2010. http://www.ema.europa.eu/ema/index.jsp?curl¼pages/reg-
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europa.eu/ema/index.jsp?curl¼pages/regulation/docu- 01ac058002708a.
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Decision No. 87. November 3, 2016. ICECI/ComplianceManuals/RegulatoryProceduresManual/
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Module I: Pharmacovigilance Systems and Their Quality 35. EU Commission Regulation (EC) Concerning Financial Pen-
Systems, June 25, 2012. EMA/541760/2011. alties for Infringement of Certain Obligations on Connection
25. EU Guideline on Good Pharmacovigilance Practices Module II: with Marketing Authorisations Granted under Regulation
Pharmacovigilance System Master File. March 28, 2017. (EC) No 726/2004 of the European Parliament and of the
EMA/816573/2011 Revision 2. Council, No 658/2007. June 14, 2017.
26. EMA Pharmacovigilance Risk Assessment Committee
(PRAC). http://www.ema.europa.eu/ema/index.jsp?curl¼
pages/about_us/general/general_content_000537.jsp; 2017.
SECTION II SAFETY DATA AND REAL WORLD EVIDENCE
CHAPTER 2
13
14 SECTION II Safety Data and Real World Evidence
FIG. 2.1 The US Food and Drug Administration MedWatch form. (Data from: https://www.fda.gov/
downloads/AboutFDA/ReportsManualsForms/Forms/UCM163919.pdf.)
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DANCE ON STILTS AT THE GIRLS’ UNYAGO, NIUCHI
I see increasing reason to believe that the view formed some time
back as to the origin of the Makonde bush is the correct one. I have
no doubt that it is not a natural product, but the result of human
occupation. Those parts of the high country where man—as a very
slight amount of practice enables the eye to perceive at once—has not
yet penetrated with axe and hoe, are still occupied by a splendid
timber forest quite able to sustain a comparison with our mixed
forests in Germany. But wherever man has once built his hut or tilled
his field, this horrible bush springs up. Every phase of this process
may be seen in the course of a couple of hours’ walk along the main
road. From the bush to right or left, one hears the sound of the axe—
not from one spot only, but from several directions at once. A few
steps further on, we can see what is taking place. The brush has been
cut down and piled up in heaps to the height of a yard or more,
between which the trunks of the large trees stand up like the last
pillars of a magnificent ruined building. These, too, present a
melancholy spectacle: the destructive Makonde have ringed them—
cut a broad strip of bark all round to ensure their dying off—and also
piled up pyramids of brush round them. Father and son, mother and
son-in-law, are chopping away perseveringly in the background—too
busy, almost, to look round at the white stranger, who usually excites
so much interest. If you pass by the same place a week later, the piles
of brushwood have disappeared and a thick layer of ashes has taken
the place of the green forest. The large trees stretch their
smouldering trunks and branches in dumb accusation to heaven—if
they have not already fallen and been more or less reduced to ashes,
perhaps only showing as a white stripe on the dark ground.
This work of destruction is carried out by the Makonde alike on the
virgin forest and on the bush which has sprung up on sites already
cultivated and deserted. In the second case they are saved the trouble
of burning the large trees, these being entirely absent in the
secondary bush.
After burning this piece of forest ground and loosening it with the
hoe, the native sows his corn and plants his vegetables. All over the
country, he goes in for bed-culture, which requires, and, in fact,
receives, the most careful attention. Weeds are nowhere tolerated in
the south of German East Africa. The crops may fail on the plains,
where droughts are frequent, but never on the plateau with its
abundant rains and heavy dews. Its fortunate inhabitants even have
the satisfaction of seeing the proud Wayao and Wamakua working
for them as labourers, driven by hunger to serve where they were
accustomed to rule.
But the light, sandy soil is soon exhausted, and would yield no
harvest the second year if cultivated twice running. This fact has
been familiar to the native for ages; consequently he provides in
time, and, while his crop is growing, prepares the next plot with axe
and firebrand. Next year he plants this with his various crops and
lets the first piece lie fallow. For a short time it remains waste and
desolate; then nature steps in to repair the destruction wrought by
man; a thousand new growths spring out of the exhausted soil, and
even the old stumps put forth fresh shoots. Next year the new growth
is up to one’s knees, and in a few years more it is that terrible,
impenetrable bush, which maintains its position till the black
occupier of the land has made the round of all the available sites and
come back to his starting point.
The Makonde are, body and soul, so to speak, one with this bush.
According to my Yao informants, indeed, their name means nothing
else but “bush people.” Their own tradition says that they have been
settled up here for a very long time, but to my surprise they laid great
stress on an original immigration. Their old homes were in the
south-east, near Mikindani and the mouth of the Rovuma, whence
their peaceful forefathers were driven by the continual raids of the
Sakalavas from Madagascar and the warlike Shirazis[47] of the coast,
to take refuge on the almost inaccessible plateau. I have studied
African ethnology for twenty years, but the fact that changes of
population in this apparently quiet and peaceable corner of the earth
could have been occasioned by outside enterprises taking place on
the high seas, was completely new to me. It is, no doubt, however,
correct.
The charming tribal legend of the Makonde—besides informing us
of other interesting matters—explains why they have to live in the
thickest of the bush and a long way from the edge of the plateau,
instead of making their permanent homes beside the purling brooks
and springs of the low country.
“The place where the tribe originated is Mahuta, on the southern
side of the plateau towards the Rovuma, where of old time there was
nothing but thick bush. Out of this bush came a man who never
washed himself or shaved his head, and who ate and drank but little.
He went out and made a human figure from the wood of a tree
growing in the open country, which he took home to his abode in the
bush and there set it upright. In the night this image came to life and
was a woman. The man and woman went down together to the
Rovuma to wash themselves. Here the woman gave birth to a still-
born child. They left that place and passed over the high land into the
valley of the Mbemkuru, where the woman had another child, which
was also born dead. Then they returned to the high bush country of
Mahuta, where the third child was born, which lived and grew up. In
course of time, the couple had many more children, and called
themselves Wamatanda. These were the ancestral stock of the
Makonde, also called Wamakonde,[48] i.e., aborigines. Their
forefather, the man from the bush, gave his children the command to
bury their dead upright, in memory of the mother of their race who
was cut out of wood and awoke to life when standing upright. He also
warned them against settling in the valleys and near large streams,
for sickness and death dwelt there. They were to make it a rule to
have their huts at least an hour’s walk from the nearest watering-
place; then their children would thrive and escape illness.”
The explanation of the name Makonde given by my informants is
somewhat different from that contained in the above legend, which I
extract from a little book (small, but packed with information), by
Pater Adams, entitled Lindi und sein Hinterland. Otherwise, my
results agree exactly with the statements of the legend. Washing?
Hapana—there is no such thing. Why should they do so? As it is, the
supply of water scarcely suffices for cooking and drinking; other
people do not wash, so why should the Makonde distinguish himself
by such needless eccentricity? As for shaving the head, the short,
woolly crop scarcely needs it,[49] so the second ancestral precept is
likewise easy enough to follow. Beyond this, however, there is
nothing ridiculous in the ancestor’s advice. I have obtained from
various local artists a fairly large number of figures carved in wood,
ranging from fifteen to twenty-three inches in height, and
representing women belonging to the great group of the Mavia,
Makonde, and Matambwe tribes. The carving is remarkably well
done and renders the female type with great accuracy, especially the
keloid ornamentation, to be described later on. As to the object and
meaning of their works the sculptors either could or (more probably)
would tell me nothing, and I was forced to content myself with the
scanty information vouchsafed by one man, who said that the figures
were merely intended to represent the nembo—the artificial
deformations of pelele, ear-discs, and keloids. The legend recorded
by Pater Adams places these figures in a new light. They must surely
be more than mere dolls; and we may even venture to assume that
they are—though the majority of present-day Makonde are probably
unaware of the fact—representations of the tribal ancestress.
The references in the legend to the descent from Mahuta to the
Rovuma, and to a journey across the highlands into the Mbekuru
valley, undoubtedly indicate the previous history of the tribe, the
travels of the ancestral pair typifying the migrations of their
descendants. The descent to the neighbouring Rovuma valley, with
its extraordinary fertility and great abundance of game, is intelligible
at a glance—but the crossing of the Lukuledi depression, the ascent
to the Rondo Plateau and the descent to the Mbemkuru, also lie
within the bounds of probability, for all these districts have exactly
the same character as the extreme south. Now, however, comes a
point of especial interest for our bacteriological age. The primitive
Makonde did not enjoy their lives in the marshy river-valleys.
Disease raged among them, and many died. It was only after they
had returned to their original home near Mahuta, that the health
conditions of these people improved. We are very apt to think of the
African as a stupid person whose ignorance of nature is only equalled
by his fear of it, and who looks on all mishaps as caused by evil
spirits and malignant natural powers. It is much more correct to
assume in this case that the people very early learnt to distinguish
districts infested with malaria from those where it is absent.
This knowledge is crystallized in the
ancestral warning against settling in the
valleys and near the great waters, the
dwelling-places of disease and death. At the
same time, for security against the hostile
Mavia south of the Rovuma, it was enacted
that every settlement must be not less than a
certain distance from the southern edge of the
plateau. Such in fact is their mode of life at the
present day. It is not such a bad one, and
certainly they are both safer and more
comfortable than the Makua, the recent
intruders from the south, who have made USUAL METHOD OF
good their footing on the western edge of the CLOSING HUT-DOOR
plateau, extending over a fairly wide belt of
country. Neither Makua nor Makonde show in their dwellings
anything of the size and comeliness of the Yao houses in the plain,
especially at Masasi, Chingulungulu and Zuza’s. Jumbe Chauro, a
Makonde hamlet not far from Newala, on the road to Mahuta, is the
most important settlement of the tribe I have yet seen, and has fairly
spacious huts. But how slovenly is their construction compared with
the palatial residences of the elephant-hunters living in the plain.
The roofs are still more untidy than in the general run of huts during
the dry season, the walls show here and there the scanty beginnings
or the lamentable remains of the mud plastering, and the interior is a
veritable dog-kennel; dirt, dust and disorder everywhere. A few huts
only show any attempt at division into rooms, and this consists
merely of very roughly-made bamboo partitions. In one point alone
have I noticed any indication of progress—in the method of fastening
the door. Houses all over the south are secured in a simple but
ingenious manner. The door consists of a set of stout pieces of wood
or bamboo, tied with bark-string to two cross-pieces, and moving in
two grooves round one of the door-posts, so as to open inwards. If
the owner wishes to leave home, he takes two logs as thick as a man’s
upper arm and about a yard long. One of these is placed obliquely
against the middle of the door from the inside, so as to form an angle
of from 60° to 75° with the ground. He then places the second piece
horizontally across the first, pressing it downward with all his might.
It is kept in place by two strong posts planted in the ground a few
inches inside the door. This fastening is absolutely safe, but of course
cannot be applied to both doors at once, otherwise how could the
owner leave or enter his house? I have not yet succeeded in finding
out how the back door is fastened.