From: PPSI@aol.com
Sent: Wednesday, July 23, 2003 3:08
PM
To: BechtelC@cder.fda.gov; fdadockets@oc.fda.gov
Cc:
lsasich@citizen.org
Subject: Testimony for July 31, 2003 and for the
Federal Record
Dear Christine:
Enclosed is my testimony for the July
31st meeting; unfortunately, I cannot attend but ask that Larry Sasich, Pharm.D.
be allowed to read my testimony and to submit it into the official record.
He will bring duplicate copies.
I do hope time permits Larry to
read my testimony. He will skim through it so that it fits into the five
minute time slot allowed.
Thanks,
Fred
Mayer
July 23, 2003
Food and Drug Administration
(FDA)
c/o Christine Bechtel
Center for Drug Evaluation and Research
(HFD-006)
5600 Fishers Lane
Rockville, MD 20857
RE:
Docket No. 03N-0168
Current
Status of Useful Written Prescription
Drug
Information for Consumers
Public Meeting, Friday,
July 31, 2003; Request for Comments
I am Fred S. Mayer, R.Ph.,
M.P.H., President and CEO of Pharmacists Planning Service, Inc. (PPSI), a 501 C
(3) nonprofit, public health, consumer, pharmacy education organization. I
also am Past President of the California Public Health Association and have
served for ten years as a member of the USP Consumer Health Education Advisory
Board in Washington, D.C.
The FDA wants the following questions
addressed:
1. What steps are the private sector taking to
improve the usefulness of written information patients receive with prescription
drugs and to meet the year 2006 goals?
a. It has been over twenty years since PPSI has been studying and
discussing useful written drug information for consumers. PPSI as a national
pharmacy group feels that the current situation is not improving. In fact,
the information should be taken over by the FDA and guidelines used by the FDA
currently in its black box program should be adhered
to.
b. A couple examples of why PPSI
feels so strongly about the FDA’s role are that currently commercial
organizations put out the written prescription drug information through
computers and most of the needed information and the most important part of the
information is buried instead of the leaflets instead of being
highlighted.
c. In the case
of two new arthritis drugs, Celebrex and Bextra, both of these drugs have
sulfonamide structures and patients allergic to sulfa’s should be notified about
this problem. Some of the patient information leaflets do not mention this
at all. Although only one out of one thousand patients may be allergic to
sulfa’s, it is a major problem, but for some strange reason the commercial firms
have not picked up this information. If they have, it is buried in the
leaflet and patients never see it.
d. With the increase of
prescription drugs in 2000 at 2 billion prescriptions, to 2003, three billion,
to 2004, four billion prescriptions, it is mandatory that all pharmacies have
prescription drug information for consumers especially since there is a shortage
of pharmacists and there is an increase in pharmacists’
workload.
e. As a
practicing pharmacist with fifty years of experience in the community pharmacy
where I work, the second computer because of the increase of prescription
volume, is hooked up to produce labels for the prescriptions instead of printing
out the written prescription drug
information.
f. In lieu of handing out prescription information, pharmacists
counsel all patients; however, because of the workload many useful information
pieces in the patient information leaflets, (PILs), which is of value is not
transmitted.
g. Because of some of these problems, pharmacists have seen patient harm.
As an example, a patient was not told about codeine allergies when a Vicodin
prescription was dispensed and patient ended up
hospitalized.
h. Again, the FDA must regulate these PILs with the most important
information being imparted to the patient/consumer.
2. What barriers exist for the private sector to meet the year 2006 goal
and what plans exist to overcome these
barriers?
a.
In 1998 Lucien Leppe, M.D., Professor, School of Public Health, Harvard
University, stated in a research paper that the fourth leading cause of death in
the United States after heart, cancer and stroke is adverse drug events, wrong
pills for the wrong patients, and misdiagnosing of prescription drugs.
b.
Barrier No. 1 is the shrinking prescription drug fees by HMOs, managed care
organizations (MCOs) and pharmacy benefit manages (PBMs) for most pharmacists to
do their job
correctly.
c. Because of these shrinking fees, pharmacists do not have time to
consult properly and look at the patient’s history on the computer screen to
pick up adverse drug events (ADEs), allergies, drug interactions and other side
effects.
d. The barrier in this case is "time is money". It takes an average of
three to five minutes to counsel the patient properly, hand out the PILs and go
over some of the side effects including the ones not listed, look at the
computer screen for ADRs, and do a professional job. THIS IS NOT BEING
DONE AS REIMBURSEMENT IS ONLY FOR COUNTING, POURING AND TYPING, NOT FOR USING
THE PHARMACISTS’ BRAIN. UNTIL THIS SYSTEM IS FIXED, THE ISSUE OF PILs AND
WHAT’S IN THE PILs is academic. However, PILs must be accurate and have
oversight by FDA especially for off label use where PILs are not used and
compounding pharmacists where PILs are not being
used.
e. In the State of California from May to October 2002, the
California State Board of Pharmacy reviewed under its Cite and Fine Committee,
citations against pharmacists. The number one citation was under Section
1716, Variation from Prescription, 22% of all fines. For pharmacies, the
number one violation was Section 1716, Variation from Prescription, 20%.
f. The second cause of citations under Section 1707.2, Duty to Consult,
19% by pharmacists and 14%, Duty to Consult, by pharmacies.
g. The third cause of the top ten violations by license-types for
pharmacists was Section 1707.3 was Duty to Review Drug Therapy with 7% violation
by pharmacists and pharmacies, 6%. Over 30% of the top ten
violations by licensed pharmacists and pharmacies were a variation from
prescription, duty to consult and duty to review drug therapy. THIS SYSTEM
MUST CHANGE IF PILs ARE TO BE UTILIZED
PROPERLY.
h. The point I am making here is that the system needs to be changed if
the PILs are to be of value to the pharmacist and OF COURSE THE PILs MUST BE PUT
OUT BY THE FDA, NOT COMMERCIAL FIRMS.
3. What should the
role of the FDA be in assuring full implementation of the action plan to meet
the year 2006
goals?
a. The FDA should take over the PILs’ commercial program and put out all
of the written prescription drug information under their direction and
guidelines.
b. Again, accuracy is one of the key issues. As in the case of Cory
Christen who was given misleading, incomplete and often out of date commercially
produced patient information leaflets (PILs) dispensed with prescriptions by
many pharmacists, which resulted in his
death.
c. Cory was treated for attention deficit hyperactivity disorder
(ADHD) with Imipramine and died from a fatal cardiac arrhythmia.
d. If Cory’s parents had been informed by the physician or
pharmacist of the cardiac and other adverse effects of Imipramine, they would
not have administered the drug to their
son.
e. Cory’s parents did receive a PIL from the pharmacy produced by
MediSpan, Inc. of Indianapolis, who omitted the most important information and
only listed the minor "nuisance" effects of the
drug.
f. The scientific literature and the popular media are brimming with
examples of inappropriate prescribing such as off label use as in the case of
Imipramine and dispensing leading to drug induced injury and deaths MOST OF
WHICH COULD HAVE BEEN
PREVENTABLE.
g. Pharmacy nationally has been unable to implement counseling or the DURs
with looking at patient profiles on computers on a large scale. For this reason
factual PILs put out by the FDA would be a bonus.
4.
What other initiatives should FDA consider for providing patients with useful
information about prescription drugs as endorsed by Public Law
104-180?
a. FDA should take over the PILs similar to what they do for black box
warnings for the following
reasons:
1) Many of 107,000 deaths each year are due to mixing prescription drugs with
OTC and herbal supplements.
2) FDA should mandate that all PILs have information on these ADRs, especially
with herbal supplements, which consumers and patients have been told are safe
and
efficacious.
3) A good example of this: seniors who are obese using Ephedra, Ma
Huang, Metabolite, which raise blood pressure, cause heart attacks and increase
the risk of
strokes.
4) On current package information in Coumadin it lists that herbals such
as Ginseng, Garlic, Ginger and Ginkgo, may interfere with INRs and may
cause stroke in patients whom are on Coumadin.
5) This type of warning on herbals needs to be in all PILs in order to
reduce morbidity and mortality and to insure the public of
safety.
6) In AIDS patients 9.6% in a most recent study showed resistance to at
least one of the three types of retroviral drugs which suppress the virus which
causes AIDS.
7) Drug resistant strains appear because the virus in AIDS patients
mutates rapidly and they thrive when patients take their drugs carelessly. This
type of public health warning about adherence to AIDS medication should be
spelled out in all PILs and fortified by pharmacists and healthcare
professionals in oral consultation. THIS IS NOT BEING
DONE.
In summation, the current PILs program, which has been
commercialized, is not working. The information needs to be accurate,
timely and usable for patients.
PPSI strongly recommends that the Food
and Drug Administration (FDA) take over the PILs program making the program
meaningful to consumers and patients and to help protect the public from
preventable drug induced injuries in a fragmented profit driven health
system.
Finally, the new FDA regulated PILs program must be incorporated
into the new Medicare Prescription Drug Plan so that patients and consumers
benefit and public health and safety are overseen by the federal government for
accuracy and quality.
Sincerely,
Fred S. Mayer, R. Ph.,
M.P.H.
President, Pharmacists Planning Service, Inc. (PPSI)
101 Lucas
Valley Road, Suite 210
San Rafael, CA 94903
Telephone: 415
479-8628; Fax: 415 479-8608
Email: ppsi@aol.com; Website:
www.ppsinc.org