Docket Management
Docket: 01N-0256 - Use of Opiate Analgesics in Various Patient Populations, Including Pediatric Patients
Comment Number: EC -210

Accepted - Volume 4

Comment Record
Commentor Dr. Michael Whitworth Date/Time 2001-12-16 15:47:21
Organization Pain Center of Southern Indiana
Category Health Professional

Comments for FDA General
1. General Comments The use of opiates in the chronic pain population is well accepted in our society and I incorporate them into my chronic pain practice. However, I believe there should be tighter controls available to circumvent self destructive patient behaviors. A recent study published in Pain Physician demonstrated a 25% incidence of abuse in a practice very much like my own. The incidence in my practice has been reduced to approximately 6-10% by narcotic contracting and very rigorous controls on availability including refill policies and urine drug screens. But we can do even better if we had the capability to have every schedule II or III drug prescription filled entered into a state or even better, national pharmacy databank that could be queried to screen for multiple narcotic physician and other practitioner prescribers, frequency of refills, monthly dose of acetaminophen, etc. Information concerning multiple prescribers could be forwarded to each prescriber in order to better the communication between physicians unscrupulous patients use during doctor shopping. Also, it is time to enhance the penalties for street sale of prescription narcotics. This should be a felony in every state. Also, unlike current police practices which often permit multiple known buys from undercover agents until an arrest is finally made, there should be no second and third buys of these substances permitted before enforcement of the law. I believe the availability of prescribing of prescription opiates should not be curtailed by actions of the FDA. However, it is obvious better controls on enforcement of proper use of such need be implemented. Finally, as a protective device, I believe congress should exclude physicians from litigation from opiate uses if they are dropped from the physician's prescribing program for documented narcotic abuse. This would permit physicians to more fully participate in the enforcement of the law.

EC -210