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FDA Issues Dietary Supplements Final Rule

The FDA issues rules that will finally make dietary supplement manufacturers conform to some rules in the manufacturing of the products.

Which ones?

  1. Accurate potency and labeling – 30 mg glucosamine will now contain something close to 30mg
  2. Impurities Testing – All the raw materials will now be tested for impurities/contaminants. They will probably follow USP guidelines.
  3. Adverse event reporting – Manufacturers/sellers will need to report adverse events. This is after the fact safety testing, wholly inadequate, but better than what we had previously.

See something missing? Efficacy!! You do not have to prove that your product actually works! Basic safety? What is the overdose level? Interactions with other medicines/supplements? Is your dosing form actually bioavailable? Meaning, if you swallow a pill, will it actually get into your bloodstream and reach the intended target?

Who knows, but standardizing, cataloging and auditing manufacturing processes is a start, I guess. 1.5 cheers for the FDA!

I would be curious to find out how these companies are going to get audited by the FDA to prove that they’re following the quality control measures they’re supposed to implement. Guess I have to read the 815 pg bundle of joy that is the actual rule to find out more. A cursory word search on audits suggests that the manufacturers do audits on their suppliers, that the quality control unit of manufacturer perform audits on their manufacturing process, but nothing about the FDA conducting audits. Of course, calling yourself a GMP (good manufacturing processes) manufacturer is usually enough to trigger an FDA audit if you’re in pharma. I wonder how the FDA will deal with this one.

FDA Issues Dietary Supplements Final Rule

The U.S. Food and Drug Administration today announced a final rule establishing regulations to require current good manufacturing practices (cGMP) for dietary supplements. The rule ensures that dietary supplements are produced in a quality manner, do not contain contaminants or impurities, and are accurately labeled.

“This rule helps to ensure the quality of dietary supplements so that consumers can be confident that the products they purchase contain what is on the label,” said Commissioner of Food and Drugs Andrew C. von Eschenbach, M.D. “In addition, as a result of recent amendments to the Federal Food, Drug, and Cosmetic Act, by the end of the year, industry will be required to report all serious dietary supplement related adverse events to FDA.”

The regulations establish the cGMP needed to ensure quality throughout the manufacturing, packaging, labeling, and storing of dietary supplements. The final rule includes requirements for establishing quality control procedures, designing and constructing manufacturing plants, and testing ingredients and the finished product. It also includes requirements for recordkeeping and handling consumer product complaints.

“The final rule will help ensure that dietary supplements are manufactured with controls that result in a consistent product free of contamination, with accurate labeling,” said Robert E. Brackett, Ph.D., director of FDA’s Center for Food Safety and Applied Nutrition.

Under the final rule, manufacturers are required to evaluate the identity, purity, strength, and composition of their dietary supplements. If dietary supplements contain contaminants or do not contain the dietary ingredient they are represented to contain, FDA would consider those products to be adulterated or misbranded.

The aim of the final rule is to prevent inclusion of the wrong ingredients, too much or too little of a dietary ingredient, contamination by substances such as natural toxins, bacteria, pesticides, glass, lead and other heavy metals, as well as improper packaging and labeling.

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    Fun with maps: BC Smart meters and the 2013 election

    SmartMeterVotingMapI have been MOOC’ing this summer and learning how to do maps. Geography as an adult is much more fun than my 10th grade geography class.

    Chad Skelton over at the Vancouver Sun intrigued me with his data retrieval and mapping of British Columbia’s Smart Meter uptake. if you’re not from BC, here’s a short intro (#BCpoli-aware feel free to skip the next two paragraphs).

    BC Hydro is the government owned (Crown Corporation) utility that produces and distributes electricity for the province of British Colombia in Canada. In 2011, BC Hydro announced its intention to spend $$$ upgrading all its electricity meters to “smart meters”. These meters are capable of being read via wifi by meter readers, and potentially also give BC residents the ability to monitor their electricity usage in near-real time.

    Many concerns were raised about the smart meters. One was about the costs of the program vs. perceived benefits. The others, which gained traction were around an emerging movement in BC connecting wifi, cell signals and wifi-enabled smart meters with a whole variety of health effects. While few, if any of these health concerns have been actually causally linked to smart meters, or even to the amorphous descriptor “wifi radiation”, these health concerns have gained traction even among official bodies such as the Union of BC Municipalities, municipal councils and school boards. The BC provincial election in 2013 was a chance for people to voice their concerns. The opposition parties all brought the issue up during canvassing.

    For my peer assessment mapping project, I wanted to see if areas of relatively high smart meter refusal were correlated or co-located in any way with voting against the ruling BC Liberals.

    This is the map I made, my first ever map not scrawled on paper.


    View Larger Map

    Reading the Map

    The electoral districts are colour-coded by BC Liberal Party percentage, darker means higher vote for the BC Liberals. I chose this rather than “who won” because I was looking more for an anti-BC Liberal effect. I will, at some point in time, try to overlay “who won” as well. The smart meter refusal data is in three different coloured and sized circles. Large and red means higher refusal, and small and green means low refusal. This is a hybrid of a graduated circle symbol scheme and a diverging colour scheme. Clearly, using points to represent areas is a big limitation, but it is sufficient for a quick peek.

    Anything to See?

    • An overwhelming majority of people had smart meters installed, > 90% in most places. So, BC Hydro’s brute force, no options, default installation plan was mostly successful
    • Places of higher than normal refusal tended to vote against the BC Liberals. I believe this had more to do with existing anti-BC-Lib tendencies influencing smart meter refusal rather than the other way around.
    • Urban centres like Victoria and Vancouver had relatively low rates of refusal. Is this because of higher apartment proportions, or because smart meter refusal was restricted to a small number of high information, highly motivated individuals whose number varied by location and whose numbers in places like Victoria were muted by larger populations?. Note that my home area of Victoria had the most (7300) rejected smart meters, even though the percentage is small. The ageing white (l)iberal enclave of Saltspring Island (Ganges), aka hippieville, Canada had by far the highest refusal percentage. So, is this smart meter refusal map mostly a hippie population distribution map?

    The take home message for me was that the anti-smartmeter movement had little influence on the election, which was most likely won on the usual and mundane issues of the economy, trust and corruption.

    Methods

    1. I downloaded data on smart meter refusal from the Chad Skelton’s post and Tableau public
    2. The data from BC Hydro is categorized using their division of BC into distinct geographical billing areas. I used billing area names to geotag the information. The site http://www.findlatitudeandlongitude.com/ has a feature where addresses can be uploaded in bulk via a text interface, and the site returns the place, and latitude longitude. I added province and country to the place names, and edited ambiguous names to make the search more effective.
    3. I uploaded this table to arcgis to form one layer. Arcgis is a big and expensive GIS software, with a limited free online playpen where this map is displayed. I used graduated circles and natural breaks to represent the different levels of smart meter refusal. A big limitation to this approach is that the BC Hydro billing areas are just that, areas, not points on a map. However, the area boundaries are not available as a shape file, and geographical areas vary widely. So, the points correspond to the centre of the nearest big population area mentioned in the BC Hydro billing area description
    4. I downloaded BC electoral district shape files from Paul Ramsey of Open Geo. These shape files are an improved version of those available from Elections BC, again, thanks to Chad Skelton for pointing me in this direction
    5. Elections BC lists 2013 provincial election results information by party by district. However, there is no publicly downloadable mapped source for the election data results. I used the open source GIS desktop software QGIS to open the shape file and add the attribute of BC Liberal percentage to the shape file. I uploaded this shape file to arcgis and layered it with the smart meter refusal rate graduated circles to look for patterns.

    Maps are fun to play with, and I know very very little about them, which is a great combination. Every minute I spent making this map was a learning experience. Comments and feedback, please. I think I will slowly incorporate mapping into my skill set. But I think I will use open source/free solutions in the future.

  • Drug makers and the FDA don't want you to find out about adverse trials

    if you have not been following the Avandia story, an article published in the New England Journal of Medicine revealed that Avandia, a popular drug used in diabetes control significantly increased the threat of heart attacks and heart failure. A couple of things to note here, firstly, this fact was known to the FDA in 2002 per this memo obtained by Public Citizen. So, why the FDA (and GSK) thought that no one would notice, is beyond me. Secondly, when the drug was introduced in Europe, it was contra-indicated for people with heart disease. This fact must have been known to the FDA and GSK as well. It is one thing for GSk to not want to run long term epidemiological and safety studies on their drugs, but other people did the work, and the FDA just stood by and watched until the work was published in the US. The European Drug agency had acted on this information quite a while back.

    So, when I come across this article in the NY Times about a “downside” to full disclosure, I don’t really know what to say. I don’t care whether there is a downside to GSK or not. If I work as a waiter in a restaurant, there is a “downside” to reporting my tip income to the IRS (yes, higher taxes!). This does not mean I should not pay my taxes! This is a matter of life and death for people. Diabetes and heart disease go together in thousands of people, they needed to know if the drug they were taking to control one disease would kill them off with the other disease.

    For Drug Makers, a Downside to Full Disclosure – New York Times

    This week, GlaxoSmithKline learned what that greater disclosure could mean.

    A cardiologist at the Cleveland Clinic, Dr. Steven Nissen, stumbled onto the Glaxo Web site while researching Avandia last April. He and a colleague quickly analyzed the data, and on Monday, The New England Journal of Medicine released its finding that Avandia posed a heightened cardiac risk.

    “It was a treasure trove,” Dr. Nissen said about the Web site.

    GlaxoSmithKline has disputed the journal’s interpretation. Officials with the Food and Drug Administration said they were reviewing whether to take any action on Avandia.

    Also, note this “concern” from the FDA, no less:

    “I would be very concerned about wholesale posting of thousands of clinical trials leading to mass confusion,” said Dr. Steven Galson, the director for the Center for Drug Evaluation and Research at the F.D.A.

    Yes, respond to results in a very prestigious peer reviewed journal by pretending that some dude with a computer in his basement (yes, all computers reside in basements) randomly picked up a couple of clinical trials and created “mass confusion”. The FDA should at least pretend to care…

    The risks and benefits involved with taking a drug to control a chronic condition are completely different from those you would take for an acute, immediately life threatening condition. If you are treating cancer, you expect side effects, and deal with them because the alternative is certain death. When you’re dealing with diabetes, you have alternatives that will not kill you. In addition, millions of people have diabetes and use Avandia. So, a small percentage increase in a side-effect can affect thousands. And, they need to know because there are alternatives that would work for them.

    GSK is not going to tell them because there is an obvious conflict of interest. They need to sell their new and expensive drug even if other alternatives work. This is why we have the FDA, and full disclosure of all clinical trials, not just the ones that worked for you.

  • FDA to add warnings on Anemia Drugs

    Oncologists are being bribed to over-prescribe these drugs, which seem to cause more harm than good when over-prescribed. The FDA is going to add a “warning” label. Let’s see what it does.

    FDA panel urges curbs on 2 anemia drugs – The Boston Globe

    Best-selling anemia drugs from Amgen Inc. and Johnson & Johnson should have their use restricted because of dangerous side effects, a US advisory panel said. Amgen shares fell the most in five years.

    The panel of expert advisers to the Food and Drug Administration voted 15-2 in favor of new prescribing restrictions and 17-0 for new clinical trials during a meeting yesterday in Silver Spring, Md.

    Shares of Amgen fell $5.77, or 9.1 percent, to $57.33 in Nasdaq Stock Market composite trading. J&J shares fell $1.61, or 2.5 percent, to $62.50 on the New York Stock Exchange.

    The drugs raised the risk of heart attacks, strokes, and death when used at high doses, studies released in the last six months showed. An FDA warning in March prompted the US health program for the elderly and disabled to stop paying for treatments in certain patients, and doctors cut back on use. The products accounted for $6.6 billion, or 47 percent, of Amgen revenue in 2006.

    “Many of us are concerned on the committee and have a lot of questions,” said Gail Eckhardt, an oncologist at the University of Colorado in Aurora, and the advisory panel’s chairwoman.

    The questions concerned the design of trials, why regulators have limited access to results from company studies, and why the drugs have been marketed for improving quality of life if there isn’t sufficient evidence for the claim, Eckhardt said.

    The FDA usually follows the recommendations of its advisory panels, although it isn’t required to do so.

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    An off patent miracle cancer cure?

    Interesting news coming out of Canada from a Dr. Anselm at the University of Alberta about a well known chemical dichloroacetic acid (like vinegar with two chlorines!).

    Cheap, safe drug kills most cancers – health – 17 January 2007 – New Scientist

    It sounds almost too good to be true: a cheap and simple drug that kills almost all cancers by switching off their “immortality”. The drug, dichloroacetate (DCA), has already been used for years to treat rare metabolic disorders and so is known to be relatively safe.

    It also has no patent, meaning it could be manufactured for a fraction of the cost of newly developed drugs.

    Here’s the PubMed citation for the article, filled with biology I will have no hope of understanding! I read the press release on sciencedaily a few days back and did a little background digging.

    A clinical trial conducted by Colombia University studying the effects of dichloroacetate on MELAs (stroke like symptoms) was halted early because everyone taking the medication showed significant effects of neural toxicity. This study was commented on by Dr. Anselm who theorized that the effect could be caused by a specific gene mutation not seen in a lot of the patients he works with.

    So, there is some reason for caution on this wonder drug, it may be toxic at certain doses to certain people. Most chemotherapetic drugs are horrendously toxic too. But if this is not a concern, Dr Anselm, meet Sunil Shaunak and his wonderful proposal to setup an alternative pipeline for drug approval that does not involve big/small pharma. I Am sure between Bill Gates, or George Soros, a few million bucks can be rustled up for a cancer cure.

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    Bill could block some ads for new drugs – Not so Fast!

    Bill could block some ads for new drugs – Yahoo News

    Pharmaceutical companies could be prohibited from advertising new drugs directly to consumers for the first two years they are on the market under a bill moving through Congress this week.

    The goal, supporters say, is to ensure medicines are safe before allowing industry to promote them to consumers in the hopes they will request prescriptions from doctors.

    But a reduction in TV and print advertising, which helped transform medications for heartburn and arthritis into blockbusters, would be a serious financial blow to drug makers. According to one study, every $1 spent on pharmaceuticals advertising often adds more than $2 in sales.

    While the Food and Drug Administration already screens a small portion of ads voluntarily submitted by drug companies, consumer advocates favor much tougher regulation, arguing that the studies companies use to test the safety of new drugs are not always large enough to spot dangerous side effects.

    “We don’t know, and we won’t know, how truly safe a drug is until it’s been used in millions of people,” said Consumer Reports analyst Bill Vaughan. “The real testing of these drugs takes place after a pill hits the market and that’s why the advertising needs to be regulated.”

    This is pretty significant. Big pharma is increasingly reliant on the blockbuster drug that addresses chronic and/or lifestyle diseases affecting the a large proportion of the affluent adult population. To reach this population, you need to target it with massive advertising blitzes that

    1. Alert you to the fact that you might have a problem – Restless leg syndrome, anyone!. This might be something that may be important, but nothing you might have noticed.
    2. Prod you to get treated for it.
    3. Convince both you and your doctor that the flashy new drug, which is 100 bucks per month is so much better than the other drug that is 10 bucks a month (Not much science is necessary here, just a major advertising blitz and continuous access to doctors through visits, “seminars”. “gifts”, etc.)
    4. Work with insurance companies to make this drug the treatment of choice
    5. Lather, rinse and repeat!

    Note that advertising is a huge part of this circle, and any restrictions to this said advertising will have pharma crying foul, and free speech. Call me old fashioned, but free speech protects an individual from surveillance, imprisonment, torture, execution, etc. by his oppressive government of choice due to views he/she might have and/or express. All corporate speech is regulated by definition because it involves a flow of information from a party that has a knowledge edge to one, that does not. To the extent that corporate speech helps the end user, it is beneficial. To the extent it hurts, it is not. So regulation of this speech should be a line drawn by government/regulating authority based on maximizing the benefit to the consumer, not to the industry.

    Davidson has urged Senate staffers to eliminate the provision on advertising, arguing that the Supreme Court has already struck down similar attempts to regulate commercial speech.

    I do not think that in the current regulatory and judiciary environment, this provision has any chance of passing. As long as “commercial” speech is as free as “individual” speech, we will forever be exploited by organizations that have a knowledge gap on us and use this knowledge gap to make us buy/do things that may not necessarily be in our interest.

  • Abbott Drops AIDS Drug Price in response to Thailand's hardball.

    Moral of the story, you have to play hardball with the drug companies. Use your power as a sovereign country. You are a market to them, their threats to stop selling their drugs in your country cannot be taken seriously because if the drug is made unavailable in your country, that gives you even more right to make it yourself (or better, buy it from India!). I mean what are they going to do, invade you? The worst you will get is a scolding and lecture from the U.S ambassdor on patents and free trade, just ignore it, or better still, protest outside the embassy!

    Chemical & Engineering News: Latest News – Abbott Drops AIDS Drug Price

    Abbott Drops AIDS Drug Price, move follows compulsory licensing decision by Thailand

    Jean-François Tremblay

    Abbott Laboratories will drop its price for Kaletra, a protease inhibitor used to treat AIDS, to the equivalent of $1,000 per patient per year in 40 developing countries.

    The move, facilitated by the World Health Organization, is apparently Abbott’s response to a decision by Thailand earlier this year to resort to compulsory licensing of Kaletra, a practice that reduces health care costs in a way that pharmaceutical companies view as patent infringement (C&EN, Feb. 5, page 11).

    Following Thailand’s decision, Abbott announced that it would stop selling Kaletra and other patented drugs in Thailand, a move that the nongovernmental organization Doctors Without Borders called “a major betrayal of patients.”Abbott had already been under fire for not supplying Kaletra to several other low-income countries.

    The price of $1,000 per year per patient, Abbott says, is 55% less than the average price at which the drug is now sold in the 40 countries. The company says it wants to increase drug affordability while “preserving the system that enables the discovery of new medicines.

    Compulsory licensing is a perfectly legal option underlined by TRIPs (Agreement on Trade-Related Aspects of Intellectual Property Rights) in response to national emergencies (AIDs is a national emergency, isn’t it?). More importantly, governments in poorer countries really should invoke this provision as much as they can. Because every time they invoke it, they make big pharma come to the bargaining table.

    $1000 per patient per year is still a lot of money, though, I would encourage Thailand to play even more hardball!

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