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: Semax — submissions

The 15 submissions received, published in full with declared interests and secretariat responses.

Document identifier
CEI-CP-074/2
Series
Public comment period
Version
1.0
Published
14 Oct 2025
Last reviewed
14 Oct 2025
Next review
14 Oct 2026
Identifier
10.71829/cei.cp.74
Certainty
Not rated
Cycle
2025 Q3
Window
24 Jul 2025 – 18 Sep 2025
Status
Closed
Submissions
15

§2Submissions and responses

15 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 Vittoria Quintanilha, MD, MSc (Clinical Trials) Independent evidence-synthesis consultancy · submitting on evidence synthesis
DRAFT-SEMAX-MONOGR/001 received 28 Jul 2025

Open-label extension data are presented alongside randomised data without distinction

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

Long-term figures in the clinical section come from open-label extensions in which every participant received the active compound and those who did not tolerate it had already withdrawn. They are printed in the same table as randomised comparisons and in the same typeface.

The respondent proposes that extension data be presented in a separate table, or at minimum in a separately labelled block, and that the surviving-population problem be stated once where it arises.

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 responseAccepted06 Oct 2025

The secretariat accepts this submission. An extension estimate answers a different question from a randomised one and should not be read as though it answered the same one.

Extension data now appear in a separate table headed as uncontrolled follow-up, with a standing note on differential withdrawal.

Dr Abimbola Sotomayor-Ekwueme, PharmD, PhD Reader in Pharmaceutics · submitting on pharmaceutics
DRAFT-SEMAX-MONOGR/002 received 31 Jul 2025

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

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

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.

The respondent supports submission 001 so far as it goes and adds the matter set out here.

Declared interest. Has received consultancy fees from a supplier named in the Institute's supplier assessment set within the preceding two years.
Secretariat responseAccepted04 Oct 2025

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 Zdenka Nyquist-Obiora, MD, PhD Metabolic medicine service, tertiary centre · submitting on clinical pharmacology
DRAFT-SEMAX-MONOGR/003 received 02 Aug 2025

Evidence for one member of the class is presented as evidence for this compound

This submission concerns the draft on Semax and is made from a pharmacological rather than a clinical standpoint.

The draft supports a statement about this compound with a citation to a trial of a different compound in the same class. The respondent states that a class-level inference is a judgement that should be labelled as one rather than presented as direct evidence.

The respondent proposes that any class-level extrapolation be flagged at the point of use and excluded from the certainty rating for the compound itself.

Declared interest. Is a practising clinician who prescribes compounds in the class under assessment. No financial relationship with any manufacturer.
Secretariat responseAccepted20 Oct 2025

The secretariat accepts this submission. Moderate certainty evidence supports several class-level statements in this area, but a class-level statement is not evidence about a particular member of the class.

Class-level inferences are now labelled at the point of use, are excluded from the certainty rating for the compound, and are reported in a separate subsection stating which compound the underlying evidence concerns.

Ivo Mountstephen, MSc (Clinical Pharmacy) National medicines information service · submitting on medicines information
DRAFT-SEMAX-MONOGR/004 received 08 Aug 2025

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

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

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 Oct 2025

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.

Dr Henrike Jastrzębska, MD, PhD Metabolic medicine service, tertiary centre · submitting on clinical pharmacology
DRAFT-SEMAX-MONOGR/005 received 08 Aug 2025

The document should state what a reader ought to do

The respondent’s comment on the draft for Semax arises from a clinical practice in which people ask about compounds of this class.

The draft assesses evidence and stops. The respondent, a practising clinician, states that a reader arriving at the document with a decision to make is left to convert an assessment into an action without help, and proposes that each document close with a recommendation.

The respondent argues that other evidence bodies issue recommendations and that declining to do so transfers the difficult part of the work to the reader.

This point is adjacent to the one made in submission 004 and the respondent puts it in a form the secretariat can act on.

Declared interest. Is a practising clinician who prescribes compounds in the class under assessment. No financial relationship with any manufacturer.
Secretariat responseNot accepted10 Oct 2025

The secretariat does not accept this submission, and records that the point is a reasonable one rather than a misunderstanding.

The Institute assesses evidence and does not issue recommendations, because a recommendation embeds values and a resource context that the Institute does not hold and cannot state. That constitutional limit is published on the methodology page and is not varied by consultation. The submission remains published in full.

Dr Yusuf Whitmarsh-Obi, MD, MSc (Clinical Trials) University department of public health · submitting on evidence synthesis
DRAFT-SEMAX-MONOGR/006 received 19 Aug 2025

Effect estimates are given without naming the comparator

The draft on Semax was read by a respondent who assesses subjective outcomes and the instruments used to record them.

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.

The respondent notes submission 005 above and does not repeat the ground it covers.

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 responseAccepted02 Oct 2025

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.

Anselm Mountstephen, MSc (Clinical Pharmacy) University department of pharmacy practice · submitting on medicines information
DRAFT-SEMAX-MONOGR/007 received 20 Aug 2025

The compound is supplied under names the monograph does not list

The respondent submits on Semax.

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.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted20 Oct 2025

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 Adaeze Underhill-Okafor, MD, MSc (Clinical Trials) University department of public health · submitting on evidence synthesis
DRAFT-SEMAX-MONOGR/008 received 25 Aug 2025

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

This submission concerns the draft on Semax. The respondent’s work is in cognitive outcome measurement.

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 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 responseAccepted06 Oct 2025

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 Yehudit Yorkstone, PhD (Chemistry), MRSC Academic peptide-chemistry group · submitting on peptide chemistry
DRAFT-SEMAX-MONOGR/009 received 27 Aug 2025

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

The respondent notes that much of the source literature for Semax is published in one national literature, and submits with that in view.

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 consultancy fees from a supplier named in the Institute's supplier assessment set within the preceding two years.
Secretariat responseAccepted05 Oct 2025

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 Ottoline Fitzgerald-Nwosu, PhD (Chemistry), MRSC Academic peptide-chemistry group · submitting on peptide chemistry
DRAFT-SEMAX-MONOGR/010 received 30 Aug 2025

Preclinical findings are reported without the model that produced them

The respondent submits on the draft monograph for Semax. A neuroactive peptide raises a question the reader wants answered early, which is whether the compound reaches the compartment in which it is said to act.

The section reports effects on healing, on mitochondrial function or on cognition without stating whether the observation was made in a cell line, in a rodent, or in an isolated tissue, and without stating the dose relative to anything a person would receive.

The respondent proposes that every preclinical statement carry its model and its dose, on the ground that a reader cannot otherwise judge how far the finding travels.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted06 Oct 2025

The secretariat accepts this submission. A preclinical claim without its model is not a citation, it is an assertion with a reference attached.

Every preclinical statement in the series now carries the model and, where the source reports it, the dose and the route.

Vittoria Ylönen, MSc (Epidemiology) Health-technology assessment agency · submitting on public health
DRAFT-SEMAX-MONOGR/011 received 01 Sep 2025

The population to which the headline estimate applies is not stated with the estimate

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

The draft carries a headline effect estimate in the abstract without the eligibility criteria of the trials that produced it. The respondent states that the estimate applies to a trial population with specific age, comorbidity and baseline criteria, and that a reader will apply it to whoever is in front of them.

The respondent proposes a one-line population statement adjacent to every headline estimate.

The respondent notes submission 007 above and does not repeat the ground it covers.

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 responseAccepted26 Sep 2025

The secretariat accepts this submission. An estimate detached from its population is an estimate of nothing in particular.

Every headline estimate now carries a one-line statement of the population in which it was observed, and the full eligibility criteria are reported in the included-studies table rather than only in the source.

Dr Vasilisa Immelmann, PharmD, PhD Health-technology assessment agency · submitting on regulatory science
DRAFT-SEMAX-MONOGR/012 received 03 Sep 2025

Regulatory status is stated without naming the jurisdiction

This submission concerns Semax and a convention used across the Institute’s output.

The draft states that the compound is approved, or not approved, without saying by whom. The respondent, employed by a health-technology assessment body, states that approval status differs between jurisdictions for several compounds in the series and that an unqualified statement will be wrong somewhere.

The respondent proposes that every status statement name the authority and carry the date on which the status was checked.

Declared interest. Employed by a health technology assessment body that has issued guidance on a compound named in the draft.
Secretariat responseAccepted09 Oct 2025

The secretariat accepts this submission. An unattributed status statement is a claim the Institute cannot support.

Every regulatory status statement now names the authority, states the date on which the status was verified, and is recorded per jurisdiction rather than as a single global assertion.

Dr Delphine Trelawney, MD, PhD Academic clinical pharmacology unit · submitting on clinical pharmacology
DRAFT-SEMAX-MONOGR/013 received 05 Sep 2025

The preclinical section is extensive and the clinical section is not

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

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. Employed by a university department that has received unrestricted research funding from a manufacturer of a compound in the class under assessment. The respondent had no role in that funding.
Secretariat responseAccepted in part06 Oct 2025

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.

Bertrand Ollerenshaw, MSc (Regulatory Affairs) Regulatory affairs, marketing-authorisation holder · submitting on regulatory science · industry submission
DRAFT-SEMAX-MONOGR/014 received 09 Sep 2025

The monograph should reproduce the approved labelling rather than paraphrase it

Having read the draft under consultation, which concerns Semax, the respondent submits as follows.

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.

This submission is made by a respondent with a different professional interest in the outcome from the one behind submission 004.

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 part06 Oct 2025

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 Evander Ashworth-Danquah, PharmD, MSc Health-technology assessment agency · submitting on health-technology assessment
DRAFT-SEMAX-MONOGR/015 received 15 Sep 2025

The same concept is given three different names in one document

This is a submission on Semax.

The draft refers to the same quantity as a response rate, a responder proportion and a categorical outcome in different sections. The respondent, who works in health-technology assessment, states that a reader cannot tell whether the three refer to one thing or to three.

The respondent proposes that the glossary term be used at every occurrence and that the glossary entry be linked at first use in each section rather than only at first use in the document.

The respondent supports submission 001 so far as it goes and adds the matter set out here.

Declared interest. Employed by a health technology assessment body that has issued guidance on a compound named in the draft.
Secretariat responseAccepted22 Oct 2025

The secretariat accepts this submission. The variation was stylistic and its cost to the reader exceeds any benefit.

A single term is now used throughout for each defined concept, and the glossary entry is linked at first use within each section rather than once per document.

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.

Nothing published by the Institute is medical advice, a diagnosis, a prescription, a treatment recommendation or a purchasing recommendation. Compounds supplied for research use are not approved for human or veterinary use in any jurisdiction, and a favourable analytical assessment of a supplier is not a statement that any product is safe or effective. The Institute publishes certainty ratings and never recommendations. No telephone number, messaging handle or ordering channel appears anywhere on this site.