MR. SINCLAIR: "Good afternoon.
My name is Bob Sinclair. My wife, Jane, and I are from West
Bloomfield, Michigan. We are here with our colleague, Jean
Townsend from John's Island, South Carolina. We'd like to
thank the CVM for the opportunity to attend this meeting
and offer some views.
As consumers and dog owners,
we feel strongly that the communication efforts of the FDA
can be improved so that users of animal health products
can have better access to understandable and timely information.
The quality of life of the hundred million-plus American
companion animals and their owners and households will benefit
when the agency treats information about animal health products
the way it treats information about human health products.
Question 2 in the March 22nd
Federal Register notice, let me offer two comments. First,
FDA can improve the timeliness of publishing adverse drug
experience reports, particularly when new drugs are introduced
in the market. Delays in the exchange of information between
the FDA and consumers can have serious implications for
the companion animals that they care for.
Many manufacturers are required
to submit ADAA reports to the Agency. Availability of evaluations
of these reports to the general public, in our view, should
not await preparation and subsequent publication of annual
summaries.
An example, Pfizer introduced
Rimidil Purprophen for dogs in January 1997. Clearly ADE
reports were received during the '97 calendar year, but
the '97 FDA summary of ADE reports on veterinary drugs was
not published until October 29, 1998. Dog owners were denied
access to this important information for an unacceptably
long period of time, in our view. For months during which
the volume of ADE reports about Rimidil was building, owners
were purchasing and administering the drug to their pets
with little knowledge about adverse effects. Dear Doctor
letters may be issued, and they were, and label changes
may occur, and they did, but there is no assurance that
balanced risk/benefit information is available to consumers.
Lack of information about Rimidil's potentially toxic side
effects seriously affected the quality of life of our toy
poodle, Misty, and caused the death of Jean Townsend's chocolate
lab, George.
We detailed Misty's story in
reports submitted last October, and in February Georgia's
necropsy report was sent to Pfizer and to the FDA/CVM.
Second, various means can be
employed to disseminate balanced information about animal
health products to consumers. Internet web site updates
plus post read line bulletins to veterinary facilities and
other communication techniques come to mind.
In view of the time, I'm going
to edit this on the fly and go right on to the next point.
Question 3 in the notice asks,
"What actions do you propose for educating the public
about the concept of balancing risks against benefits in
public health decision-making?" We have several responses
to this question.
Direct to consumer so-called
DTC advertising posts, we believe FDA can re-institute its
earlier policy requiring that DTC advertising of human and
animal prescription drugs in all media include a brief summary
-- quote, "a brief summary" -- of hazards and
contraindications.
After broadcast advertising restrictions
were eased on August 8th, 1997, it became apparent that
procedures are not in place to assure that balanced information
is, in fact, delivered in all media.
Unbalanced TV commercials encourage
animal owners to unknowingly demand drugs like Rimidil that
may cause their pets to suffer lethal or sublethal side
effects. Coupled with unavailability of label information
or patient information leaflets, animal owners hoping to
help their pets cannot evaluate the risks versus the benefits
and make informed decisions.
We suggest a new regulation.
We suggest that FDA can initiate rule-making towards a federal
regulation requiring that consumer information prepared
and supplied by the manufacturer must absolutely be delivered
to animal owners when prescription drugs are purchased.
Drugs suppliers and veterinary
practitioners who fail to provide such information to animal
owners would be held in violation of this regulation. And
obviously means to monitor compliance and enforce the proposed
regulation would be required.
Blister pack and tube packaging
include inserts that do provide information, but many animal
prescription drugs are dispensed in small vet-supplied containers
without either label information or PILs, containing balanced
risk/benefit information. Typically these containers indicate
the name of the drug, the dosage and the condition for which
it was prescribed. Animal owners are not assured receipt
of accurate guidelines advising that their animals should
be carefully and objectively monitored.
We -- Jean and I -- we never
received such guidance about Rimidil. The only information
that was provided verbally to us was that Rimidil is, quote,
"safer than aspirin and has less GI effects."
Something clearly is wrong in the risk/benefits communication
process between the manufacturer/distributor, the veterinarian,
and the consumer/owner of the animal receiving the drug.
A veterinary drug database.
Many users don't understand possible risks without personally
conducting exhaustive research which they may or may not
be able to pursue. Information about new human drugs is
readily accessible by consumers from the FDA home page,
a database of veterinary prescription drug information that
can be accessed from the CVM home page we recommend should
be created. The FOI summaries don't answer the need. Consumers
cannot readily access information about a new animal drugs
like Etogesic as they can about a new human drug like Celobrex
(phonetics).
U.S. approval status reports.
We believe the FDA can do a better job of informing the
public about the U.S. approval status of drugs approved
and being used successfully in other countries. Cartofovet,
penicillin polysulfate sodium (phonetics), for example,
has been available in Australia, New Zealand, Canada, the
United Kingdom and Ireland for years. This therapy for osteoarthritis
in dogs is not available in the United States, and we do
not know how to determine its status.
We think the public needs to
know. We think the CVM could explain its position on fighting
this promotional advertising works advising material to
the American public.
Here are four copies -- or copies
of four letters from the Agency to Pfizer dated April 4,
October 8, December 19 and December 21, 1998. Each of these
letters discussed fair balance and advised that Pfizer was
found in violation of the FFDC act and applicable regulations.
The public, we believe, deserves to know the results of
these actions. Pfizer has claimed Rimidil is safer than
aspirin. This is a bogus claim.
And I'll skip. I'm getting signs
telling me to stop talking. So I'll again edit further on
the fly.
The claim that Rimidil is safer
than aspirin is wrong. That was documented in the October
'98 summary of '97 ADE reports highlighted in the January-February
issue of the FDA Veterinarian and discussed in articles
appearing in recent issues of APC Veterinary News and Dog
World.
The Pfizer commercials continue.
The golden retriever is still jumping over garbage cans,
leaping to the second floor and sliding down banisters.
We think that and merchandising materials, toy dogs, desk
pads, calendars, lack fair balance of risk/benefit information.
We'd also like to know why --
we'd like CVM to comment on why the U.S. Dosage for Rimidil
after one week is twice that in Australia, the United Kingdom
and Europe where adverse experiences seem to be less than
in this national market.
Let me close by describing a
personal experience that occurred in March at a specialty
show the day before the Detroit Dog Show. A lady that we
met brought her six-year-old dog for obedience trials and
a beautiful fourteen-year-old along for the ride. In conversation,
the owner said that her vet had just put the older dog on
Rimidil. We asked why. Her answer? "Oh, no symptoms.
She just slowing down a little and the vet said Rimidil
is very popular now."
Jean, Jane and I are here in
part seeking closure and for those who record the remote,
statistically insignificant judgment, I say that for Misty
and George and many others, it was a hundred percent. As
you people in CVM well know, the premarket testing rarely
indicates the full range of problems. Our plea is simply
one for better communications, improvements in the exchange
of information about animal drugs. The so-called action
plan for the provision of useful prescription medicine information
approved for human drugs by Secretary Shalala January 13,
'97, we recommend be adopted for animal drugs.
What we miss today is the guarantee
that information about the drugs we give to our animals
is timely, accurate, up-to-date, unbiased, specific, and
comprehensive and is presented in an understandable and
legible format and is useful.
Thank you very much for your
time."