2005N-0345 Drug Approvals: Circumstances under which an active ingredient may be simultaneously marketed in both a prescription drug product and an over-the-counter drug product
FDA Comment Number : EC1018
Submitter : Ms. Jennifer Olenchek Date & Time: 10/27/2005 10:10:08
Organization : Ms. Jennifer Olenchek
Category : Individual Consumer
Issue Areas/Comments
As someone who is concerned about women's access to safe and medically necessary contraceptives, I urge the FDA to end its egregious delay of the decision to switch Plan B's drug status to over the counter (OTC). The FDA's latest move of issuing a request for public comments on such self-explanatory issues such as whether the FDA has the authority to approve a drug in both prescription and OTC form and whether such a limitation would be enforceable is merely a stall tactic that compromises women's reproductive health options.

Birth control is basic health care for most sexually-active women of childbearing age. Plan B is a safe and effective form of contraception and decreases the risk of unintended pregnancy resulting from unprotected sex or contraceptive failure by 89%. For Plan B to be effective, women must be able to take it quickly, as the efficiency rate decreases dramatically after 12 hours following unprotected sex, birth control failure or sexual assault. Because it is often not possible to quickly schedule an appointment with a health-care provider who will write a prescription, making the drug available OTC is essential to the many women who would not otherwise be able to access it.

Plan B should be made available over the counter to women of all ages. The claim that easier access to young women will result in increased rates of unprotected sex among adolescents is simply unsubstantiated. Moreover, the FDA has always treated all women of childbearing age the same when evaluating reproductive health products, making the option of restricting OTC drug status by age an unjustified aberration.

The FDA has long been hailed as an independent entity that promotes public health through science and evidence, not ideology and politics. The fact that women have had to wait for more than two years for the FDA to issue a decision on the Plan B application is unacceptable. Please make women's health the FDA's first priority by ending this undo delay.