1978N-0065 Skin Bleaching Drug Products
FDA Comment Number : EC113
Submitter : Dr. ROBERT ROSENBERG Date & Time: 12/07/2006 11:12:13
Organization : ST. JUDE HERITAGE MEDICAL GROUP
Category : Health Professional
Issue Areas/Comments
GENERAL
GENERAL
Food and Drug Administration

ATTN: Division of Dockets Management

5630 Fishers Lane, Room 1061, HFA-301

Rockville, MD 20852

re: docket number 1978N-0065, RIN 0910-AF53

Hydroquinone is one of the most effective molecules for the treatment of dark discoloration over the past 40-50 years and has been used in millions of people. It is used to treat the top concerns among our patients including melasma, photo-aging, post-inflammatory hyperpigmentation, medically and cosmetic disfiguring dyschromias.
Since 1961, hydroquinone has demonstrated a safe and effect profile among clinicians prescribing or recommending hydroquinone products. In spite of humans exposure to natural sources of hydroquinone in wheat, pears, berries, coffee, tea, onions, rice and red wine, there is not an association with carcinogenicity. There have been no reported cases of related malignancies in more than 50 years of manufacture and use of HQ.

To remove this substance from the dermatologist's armamentarium will be deleterious to patient care and will not improve safety.

Thank you very much.

Very truly yours,

Robert M. Rosenberg, M.D.
Chief, Dermatology
St. Jude Heritage Medical Group
Fullerton, California