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drug safety

Barbrae

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Joined
Jun 26, 2004
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644
Rolfe posted this on another thread which led me to thinking and wondering some questions.

"Don't you think that if real medicine introduced drugs with no safety testing, and no evidence of efficacy, and no idea regarding interactions with other substances, or safe handling, or expiry data, people might be a bit worried?"


So first the questions - can someone tell me with regards to drug testing what the difference between placebo and drug needs to be for a drug to be approved? Are there any drugs that have been approved that had only slightly better results than placebo?
Also, how many times does a study need to be done before approval? Also what type of safety rules are there, after all - drugs are rarely 100% safe so how unsafe can they be before not being approved? Is there a standard or is it done on a case by case basis?


Now, to comment on Rolfe's statement. Every drug approved by the FDA can be legally prescribed for any indication as seemed appropriate by an MD - without any efficacy testing for that condition or any safety testing for that condition - this must seem illogical to a group who holds testing for efficacy and safety so high - what are your comments about this practice?
 
WRONG WRONG WRONG!

Sorry, but had to put that in bold.

Again, you're wrong, and this simply highlights how little you know about conventional medicine and how quickly you'll believe anything uncritically that seems to be anti-"allopathy" and pro-homeopathy.

From http://www.fda.gov/fdac/special/newdrug/benefits.html:

Under current law, all new drugs need proof that they are effective, as well as safe, before they can be approved for marketing.

Efficiency MUST be proven for a new drug, and drugs approved by the FDA can only legally be prescribed for the condition they are intended to treat. Consider the massive studies done to show the efficiency fo aspirin in preventing second heart attacks.
Approval History
The approval history is a chronological list of all FDA actions involving one drug product having a particular FDA Application number (NDA). There are over 50 kinds of approval actions including changes in the labeling, a new route of administration, and a new patient population for a drug product. "
http://www.fda.gov/cder/drugsatfda/glossary.htm#prescription_drug
Bolding mine.

The FDA requires approval for any new uses of a drug other than its intended purpose. Also, prescripbing a drug for other than it's intended purpose, outside of FDA approval or FDA-approved clinical trials, is illegal.

You are, plainly, wrong.

You're most likely confusing the drug approval process with the process for food and "nutritional supplements", which must only prove safety, and never efficiency.
 
Huntsman said:
WRONG WRONG WRONG!

Sorry, but had to put that in bold.

Again, you're wrong, and this simply highlights how little you know about conventional medicine and how quickly you'll believe anything uncritically that seems to be anti-"allopathy" and pro-homeopathy.



Thanks for setting me straight. I must say however that although I was misinformed I spent the bulk of my life in the allopathic world of treatment so please don't behave like allopathy is foreign to me. I am worng all the time, about many many thing, it doesn't always mean it's because I am a homeopath - rather I am human.

Now - I found this on a medical site
2. Off-label indications

Once a drug has been approved by the FDA for an indication and then marketed for that indication, physicians are allowed to prescribe the drug for any other indication (treatment for other diseases or conditions) if there is reasonable scientific evidence that the drug is effective for that indication. These uses that have not been approved by the FDA are the off-label indications.


this is what I was referencing. So my quesiton is - what is reasonable scientific evidence? Is it under the same scrutiny as the studies done for indicated diseases? Are the efficacy and safety tests the same?

Now, am I also mistaken that drugs approved for adults can be given to children whether safety and efficacy studies have been done for kids?

I also had info that vaccines are not tested against placebo for safety but rather tested against another vaccine, is this true?

Thanks for the info.
 
Barbrae,

You haven't seen me around here much, mostly because I have had very little time this year to do much more than scan the science sections and post infrequently.

Just to give you a brief history, I'm a science teacher who used to work in a pathology laboratory as a medical scientist for a Queensland (Australia) lab. So you have to understand that I'm more familiar with Australian procedures than with US and UK.

Hunstman covered most of the finer points, and I can't disagree with his post at all. I would like to add, however, that my most vehement opposition to natural therapies and homopathy arises from this very point (arguing the merits of whether it works, and how, I tend to leave well alone for it very quickly becomes obvious that when somebody falls into a pit without logic, you can't use logic to pull them out).

There are similar laws in Australia which cover the use of natural and homeopathic remedies. Several progressive layers of testing are required by law before any drug can be administered by a medical practitioner. The drug can only be administered for the purposes outline in the trials; there is, however, one exception caused by a loophole which could be a problem. There are efforts at moment to address this.

That loophole allows doctors to prescribe medications trialled only on adults on children. This is due to the problem that permission is required prior to testing, and ethical issues arise where minors are concerned. Erroneous assumptions can occur where dosages are simply reduced for infants, not taking into account that many drugs have completely different effects on infants than on adults.

Why am I telling you this? Afterall, it's another example of hideous allopathy potentially causing grief, no?

We know this because people have challenged the way things are done, and see that problems can occur. An infant's equivalent of MIMS is being written, stressing that there are still many medications which have to be treated with care as there is minimal data on it where children are concerned. This is a solution to a problem which has been brought to our attention because we have a system which looks at what works and asks 'why' and 'how'.

Any chemical which alters the biochemical working of an organism is a drug. Homeopathy, if it has any effect on an organism's functioning -- whether for good or bad -- is a drug. It must have a mechanism of action (if it works), hence it must influence how an organism operates either in good health or in poor. It stands to reason that it could interfere with other medications, or could work differently in different situations. In science, we are obligated to raise questions when something is not fully known, or fully understood. And until there are answers, we must use caution when treating somebody with that chemical.

These laws do not apply to naturopathy or homeopathy. It is truly criminal. In naturopathy it's fine to prescribe willow bark for pain, but I need a licence if it is purified and has an acetyl group added (aspirin). I can sell willow bark without respecting the laws applied to aspirin! Homeopathy goes a step further -- I can legally prescribe 'unproven' medication without demonstrating its effectivity in any trials or having it analysed by independent parties.

You ask if there are any drugs which can be prescribed which have demonstrated only marginal benefits over their placebo. Indeed, it is possible that a drug could be statistically shown to be beneficial when in doesn't in fact have the aniticipated effect. But it does not seem to happen often due to the nature of the testing process, and through the nature of good science and the fact that we are allowed to challenge what we see, the few that are subsequently questioned tend to succumb to a form of natural selection and are then often left out of the doctor's big medicine cabinet. I've read papers in the past which question how effective a drug is in given conditions, and more often than not it falls by the wayside in a year or so.

Athon
 
To answer your question about off-label uses:

http://www.fda.gov/cder/guidance/105-115.htm#SEC. 401

Section 401 of the FDA Modernization Act.

b) Specific Requirements.--A manufacturer may disseminate
information under subsection (a) on a new use only if--
``(1)(A) in the case of a drug, there is in effect for the
drug an application filed under subsection (b) or (j) of section
505 or a biologics license issued under section 351 of the
Public Health Service Act; or
``(B) in the case of a device, the device is being
commercially distributed in accordance with a regulation under
subsection (d) or (e) of section 513, an order under subsection
(f) of such section, or the approval of an application under
section 515;
``(2) the information meets the requirements of section 552;
``(3) the information to be disseminated is not derived from
clinical research conducted by another manufacturer or if it was
derived from research conducted by another manufacturer, the
manufacturer disseminating the information has the permission of
such other manufacturer to make the dissemination;
``(4) the manufacturer has, 60 days before such
dissemination, submitted to the Secretary--
``(A) a copy of the information to be disseminated;
and
``(B) any clinical trial information the
manufacturer has relating to the safety or effectiveness
of the new use, any reports of clinical experience
pertinent to the safety of the new use, and a summary of
such information;
``(5) the manufacturer has complied with the requirements of
section 554 (relating to a supplemental application for such
use);
``(6) the manufacturer includes along with the information
to be disseminated under this subsection--
``(A) a prominently displayed statement that
discloses--
``(i) that the information concerns a use of a
drug or device that has not been approved or
cleared by the Food and Drug Administration;
``(ii) if applicable, that the information is
being disseminated at the expense of the
manufacturer;
``(iii) if applicable, the name of any authors
of the information who are employees of,
consultants to, or have received compensation
from, the manufacturer, or who have a significant
financial interest in the manufacturer;
``(iv) the official labeling for the drug or
device and all updates with respect to the
labeling;
``(v) if applicable, a statement that there
are products or treatments that have been approved
or cleared for the use that is the subject of the
information being disseminated pursuant to
subsection (a)(1); and
``(vi) the identification of any person that
has provided funding for the conduct of a study
relating to the new use of a drug or device for
which such information is being disseminated; and
``(B) a bibliography of other articles from a
scientific reference publication or scientific or
medical journal that

[[Page 111 STAT. 2358]]

have been previously published about the use of the drug
or device covered by the information disseminated
(unless the information already includes such
bibliography).

``(c) Additional Information.--If the Secretary determines, after
providing notice of such determination and an opportunity for a meeting
with respect to such determination, that the information submitted by a
manufacturer under subsection (b)(3)(B), with respect to the use of a
drug or device for which the manufacturer intends to disseminate
information, fails to provide data, analyses, or other written matter
that is objective and balanced, the Secretary may require the
manufacturer to disseminate--
``(1) additional objective and scientifically sound
information that pertains to the safety or effectiveness of the
use and is necessary to provide objectivity and balance,
including any information that the manufacturer has submitted to
the Secretary or, where appropriate, a summary of such
information or any other information that the Secretary has
authority to make available to the public; and
``(2) an objective statement of the Secretary, based on data
or other scientifically sound information available to the
Secretary, that bears on the safety or effectiveness of the new
use of the drug or device.

As to using drugs in children, it is true that many drugs have not specifically been tested for children. They have been tested for adults and the results are extrapolated. Howeve,r the FDA is currently pushing for more testing in children, so that specific effects and reactions can be identified. See here: http://www.fda.gov/fdac/special/newdrug/kidmed.html

As to vaccines, try here: http://www.fda.gov/fdac/features/095_vacc.html

All this is about 30 minutes of looking on the FDA's website. The results are compared to other vaccines; the vaccines currently in use have been tested and found safe and effective, thus new vaccines must be measured against existing ones to see if they are as safe as exiting vaccines, and if they provide a higher level of protection. Now, tthey do not mention (nor do I know yet) if they include placebo or not, but they do measure against the baseline (the general population that does not recieve the new vaccine).


More information is available here: http://www.cdc.gov/nip/vacsafe/#Prelicensure.

From that page:
"Typically these trials last several years. Because the vaccinated group can be compared to those who have not received the vaccine, researchers are able to identify true side effects."

In other words, they compare vaccine to unvaccinated. If anything, this would increase the side-effect picture of the vaccines (many people experience side-effects because of placebo effect, especially when warned beforehand that they may experience a side effect).

And sorry to be so harsh in my first post, but these are really issues that set me off. Especially when answers are so readily available. The FDA does not approve off-label use, but does regulate it, as section 401 of the Modernization act states.

IN any case, even if your assertions are true, this does not really say anything bad about conventional medicine compared to homeopathy. Homeopathic rememdies do no testing for efficiency, and little testing for safety. Where as a vaccine might easily be in trials for ten years or more, and a new drug five to ten years in some case, homeopathic remedies are covered under the "dietary supplement" regulations. From the fda (http://www.cfsan.fda.gov/~dms/supplmnt.html):

"FDA regulates dietary supplements under a different set of regulations than those covering "conventional" foods and drug products (prescription and Over-the-Counter). Under the Dietary Supplement Health and Education Act of 1994 (DSHEA), the dietary supplement manufacturer is responsible for ensuring that a dietary supplement is safe before it is marketed. FDA is responsible for taking action against any unsafe dietary supplement product after it reaches the market. Generally, manufacturers do not need to register with FDA nor get FDA approval before producing or selling dietary supplements. Manufacturers must make sure that product label information is truthful and not misleading.

FDA's post-marketing responsibilities include monitoring safety, e.g. voluntary dietary supplement adverse event reporting, and product information, such as labeling, claims, package inserts, and accompanying literature. The Federal Trade Commission regulates dietary supplement advertising.

Almost all the regulation here is after-the-fact and based on voluntary reporting from the manufacturers and users.
 
I'm not jumping in on this because I'm not American and I know little about this "FDA" of which you all speak.

However, I know that in this country it is very difficult to get a veterinary product licence or marketing authorisation for a new product. There are many hoops which have to be jumped through, and it all costs a great deal of money - then over £20,000 just for the privilege of submitting the application. And by the way, all this has to be paid for by the drug company - so much for all the pleas to give "alternative" medicines equivalent funding so that the same quality of trials can be carried out! Safety, efficacy and public health (including withdrawal times of drugs when administered to food-producing animals) are all closely addressed, and the data has to be extremely complete.

(I also know that attempts have been made on several occasions to obtain licences for homoeopathic products, but none has ever made it through the system.)

Then, the prescribers are bound by a strict code known as the "cascade". This obliges vets to use a licensed product authorised for the disease in question in the species in question, if such is available. If there's no such thing, then there is a hierarchy of considerations, including drugs authorised for the same disease in a different species, drugs authorised for a different disease in the same species, and drugs with human product licences.

If one departs from the data sheet in any respect, one is obliged to explain this to the owner and obtain informed consent to this course of action. This would include any use of a drug that wasn't licensed for the relevant disease in the relevant species, any concerns regarding the listed contra-indications, and any variation in dose rate. It's actually wise to get written signed consent from the client.

If one has tried the appropriate licensed drug on a patient, and the response hasn't been as good as anticipated, and one is aware of an unlicensed drug one believes might give a better result in that patient, one is again allowed to go down the cascade using alternative preparations. This would cover things like changing a hyperthyroid cat from methimazole (licensed for cats) to carbimazole (licensed for the same condition in humans and used in cats before any licensed preparation was available) if it is considered that it might be more suited to that individual. But one is obliged to have tried the licensed preparation first, and obliged to follow the cascade - we don't have a completely free hand.

If you don't abide by this set of rules you won't have a leg to stand on if anything goes wrong - you'll need your professional indemnity insurance for sure, and you may find yourself talking to the RCVS Disciplinary Committee. So when a veterinary homoeopath of our acquaintance claims to treat hyperthyroidism first with some brand of magic sugar pills, he's very definitely in the realms of professional misconduct, and it's only the reluctance of clients to complain about the outcome when they've chosen to go the "alternative" route which is going to keep him out of trouble.

I think the data sheet is one of the greatest inventions of modern medicine. There it is, all the information you need about any licensed drug (and you can get the human data sheets for these products too) - mode of action, dose rate, side-effects, contraindications, the works. Read it, abide by it, and trouble is very unlikely to ensue.

And you know what? In the back of the book of data sheets, there is a set of pull-out yellow pages. These are forms to fill in if you even suspect a patient might have had an adverse reaction to a licensed medicine. I'm not saying everybody always fills these in as conscientiously as they might, but it does provide a valuable check on the performance of medicines in the field. All these forms as centrally-collated and examined, and if it looks as if there's any reason for concern about a product then appropriate action can be taken.

Now, that's just veterinary drugs in the UK. Pray continue about this FDA thing....

Rolfe.
 
There are many hoops which have to be jumped through, and it all costs a great deal of money - then over £20,000 just for the privilege of submitting the application

You have no idea......getting a new drug to market can cost millions but there are considerations which allow pre-marketing approval availability for patients with no other alternative if administered or prescribed under an approved clinical investigation. Its called expanded access.

Rolfe, if you want to learn more how the U.S. FDA approves new drugs, the costs and considerations which apply, the following essay may also be of interest:

http://www.fda.gov/fdac/special/newdrug/benefits.html
 
Barbrae said:
Rolfe posted this on another thread which led me to thinking and wondering some questions.

"Don't you think that if real medicine introduced drugs with no safety testing, and no evidence of efficacy, and no idea regarding interactions with other substances, or safe handling, or expiry data, people might be a bit worried?"
Not to derail this interesting thread, but this was the last sentence of a post about not simply the lack of knowledge regarding homoeopathic dose rates, handling of medicines, interactions with other substances, expiry dates and so on, but the evident lack of any interest within the homoeopathic community in settling these issues by investigating them. And I touched on the obvious difficulty - that if you can't demonstrate that the remedy has any action in the first place it's hard to see how such trials might be conducted.

Barb obviously read the post. It would be nice to get some response to the substance of it. Or should I start a new thread for that as well? (Serious question.)

Rolfe.
 
Drug Safety

An interesting thread. Firstly, my credentials. Nothing special, other than 30 years in and around the UK pharmaceutical industry, mainly in drug development. In answer to the question on what is acceptable safety, essentially a significant excess of adverse events compared with placebo will have to be explained. By significant I mean statistically significant. Adverse events are anything adverse reported during the study - whatever the reason. EG if someone gets hit by a meteorite it goes in the database. Anything serious or life threatening, if present in significant excess, would normally cause development of the drug to be stopped. But if the primary disease were already life threatening, then the risk-benefit ratio shifts. If your antibiotic has a 1:10,000 risk of fatal blood dyscrasia, but if you don't give it you will die from the infection, then what would you do? I think you will want the antibiotic.

Turning to efficacy, this is normally tested by setting up an a priori statistical model, based on expected difference between the two treatments being compared. This will be based on a change in a parameter, say blood pressure, which is typical of existing treatments. The expected difference will determine the number of patients needed in the trial - this is called a power calculation.

In addition to all this, post marketing surveillance is commonly demanded by regulators. This is because very rare adverse events can't be picked up by clinical trials - they are too small. Trials big enough would be impossibly expensive, so patients receiving the prescribed drug are monitored. Only when we have tens of thousands of cases in the database do we often get a good idea of how common these uncommon problems are. There is really no way round this - to learn anything we have to expose people to the treatment.

As other posters have said, all these processes and many more are scrutinised rigorously by the regulatory authorities around the world. "Alternative" medicine receives no scrutiny whatever.
 
There is an exception. If the drug is a herb or somethign natural you don't have to test any claims.
 
merphie said:
There is an exception. If the drug is a herb or somethign natural you don't have to test any claims.

I mentioned that at the bottom of my long post; well, touched on it anyway. Herbals are considered "dietary supplements" rather than drugs (even though some may contain the same active ingredients as drugs so). Thus, you are correct, they do not have to be tested for efficiency, only safety (http://www.cfsan.fda.gov/~dms/supplmnt.html).
 
Huntsman said:
I mentioned that at the bottom of my long post; well, touched on it anyway. Herbals are considered "dietary supplements" rather than drugs (even though some may contain the same active ingredients as drugs so). Thus, you are correct, they do not have to be tested for efficiency, only safety (http://www.cfsan.fda.gov/~dms/supplmnt.html).

Saefty huh? They why are so many people dying from this crap? I guess they didn't test for long periods of time.
 
I also had info that vaccines are not tested against placebo for safety but rather tested against another vaccine, is this true?

Vaccines like drugs are tested for their integral safety and efficacy. This involves first toxicology studies in animals to show that the individual components of the vaccine are not in themselves toxic at high dose levels. Then there will be testing in animal models to show efficacy (immunogenicity and/or protection from infection) and will include placebo controls; this could be testing the adjuvant alone or the delivery vehicle (saline or oil depending on adjuvant) and probably both.

A vaccines would only be tested against another for reasons to show that one is better (efficacy, safety) or at least no worse than the other in protecting against a specific disease, such as when inactivated polio replaced oral polio.
 
merphie said:
Saefty huh? They why are so many people dying from this crap? I guess they didn't test for long periods of time.

Oh, come on now, the fatalities from properly prescribed drugs far outweighs any from herbs, supplements. and let's not make excuses as to why that is. The numbers are outrageous.
 
Capsid said:
Vaccines like drugs are tested for their integral safety and efficacy. This involves first toxicology studies in animals to show that the individual components of the vaccine are not in themselves toxic at high dose levels. Then there will be testing in animal models to show efficacy (immunogenicity and/or protection from infection) and will include placebo controls; this could be testing the adjuvant alone or the delivery vehicle (saline or oil depending on adjuvant) and probably both.

A vaccines would only be tested against another for reasons to show that one is better (efficacy, safety) or at least no worse than the other in protecting against a specific disease, such as when inactivated polio replaced oral polio.

Capsid - do you happen to know if vaccines are tested in the UK to the same as the US by any chance?
 
Barbrae said:
Oh, come on now, the fatalities from properly prescribed drugs far outweighs any from herbs, supplements. and let's not make excuses as to why that is. The numbers are outrageous.

How do the number of lives saved compare?
 
Capsid - do you happen to know if vaccines are tested in the UK to the same as the US by any chance?

The short answer is yes, although the regulatory bodies for the USA (FDA) and UK/Europe (MHRA) have their own procedures. These procedures are pretty similar although what might get you a license in Europe will not auomatically get you one in the USA and vice versa.
 
I just find it interesting (but sadly predictable) that Barb chose to slice off a short comparative comment relating to real medicine, and start a thread about testing and licensing systems, while totally ignoring the main thrust of the original post, which was the absolute lack of any testing or regulatory processes for homoeopathic remedies, and the complete lack of interest within the homoeopathic community regarding finding answers to the many points of disagreement regarding dose rates, expiry dates, interactions, storage requirements and so on.

Rolfe.
 
Capsid said:
The short answer is yes, although the regulatory bodies for the USA (FDA) and UK/Europe (MHRA) have their own procedures. These procedures are pretty similar although what might get you a license in Europe will not auomatically get you one in the USA and vice versa.

Just to put a finer point on it, the EMEA is the "official" nodding agency in the EU now, not that the MHRA isn't still in effect in England and, depending on the assigned ad hoc committee, may have a large voice in the deciding vote for or against approval.

http://www.emea.eu.int/

-TT
 

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