From: Titus, Sandra L Sent: Monday, April 23, 2001 9:38 AM To: Butler, Jennie C Subject: FW: Claritin Docket May 11 -----Original Message----- From: IFinegold@aol.com [mailto:IFinegold@aol.com] Sent: Saturday, April 21, 2001 9:44 PM To: tituss@cder.fda.gov Subject: Claritin Sandra Titus CDER FDA Dear Ms. Titus: I am sending you this letter as a response to the contemplated change from prescription drug to over the counter status for Claritin. I am a physician and Board Certified in Allergy and Immunology. I have practiced allergy for over 30 years. I am currently Chief of the Division of Allergy at St. Luke's-Roosevelt Hospital in New York City and a Past President of the American College of Allergy, Asthma and Immunology. I am opposed to making the switch from prescription to O-T-C status for Claritin for the following reasons: 1) while allergic disease is very prevalent in the population, self-medication with antihistamines will lead to inappropriate therapy for those patients with non allergic conditions such as common colds, or non allergic rhinitis 2) self medication will either delay or eliminate the physician's role in taking a full history and performing an appropriate physical examination in order to make the correct diagnosis 3)self medication for allergic diseases will delay appropriate allergic therapy such as removing pets and delay or eliminate more effective therapy 4) some allergic diseases such as asthma may be fatal, and inadequate treatment with antihistamines may delay appropriate diagnosis and treatment and thereby add to the morbidity and mortality of that disease Yours truly, Ira Finegold, MD