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	<title>Comments on: Promises, Promises: What Post-Marketing Studies?</title>
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	<pubDate>Fri, 10 Feb 2012 22:47:56 +0000</pubDate>
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		<title>By: Just A Thought</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-319745</link>
		<dc:creator>Just A Thought</dc:creator>
		<pubDate>Mon, 28 Apr 2008 18:49:03 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-319745</guid>
		<description>I'm thinking there is no answer to be had concerning a time table. Maybe if a Senator's child is on an offending drug...</description>
		<content:encoded><![CDATA[<p>I&#8217;m thinking there is no answer to be had concerning a time table. Maybe if a Senator&#8217;s child is on an offending drug&#8230;</p>
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		<title>By: truthman30</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-314881</link>
		<dc:creator>truthman30</dc:creator>
		<pubDate>Fri, 25 Apr 2008 23:47:23 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-314881</guid>
		<description>The post marketing reports of drug side effects by the MHRA (UK regulator) is deeply flawed and inadequate, I presume the FDA system is just as bad if not worse... 

Just because you report a side effect or an adverse reaction, doesn't mean the regulators actually give a damn..

There are many drugs which have caused life threatening reactions in recent years and they remain on the market...

Avandia, Paxil, Zyprexa to name but a few...

It is not in the regulators interest to pull drugs even if they are killers...
They stall for as long as they can and even then the drugs are rarely pulled...</description>
		<content:encoded><![CDATA[<p>The post marketing reports of drug side effects by the MHRA (UK regulator) is deeply flawed and inadequate, I presume the FDA system is just as bad if not worse&#8230; </p>
<p>Just because you report a side effect or an adverse reaction, doesn&#8217;t mean the regulators actually give a damn..</p>
<p>There are many drugs which have caused life threatening reactions in recent years and they remain on the market&#8230;</p>
<p>Avandia, Paxil, Zyprexa to name but a few&#8230;</p>
<p>It is not in the regulators interest to pull drugs even if they are killers&#8230;<br />
They stall for as long as they can and even then the drugs are rarely pulled&#8230;</p>
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		<title>By: Skeptic</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-314593</link>
		<dc:creator>Skeptic</dc:creator>
		<pubDate>Fri, 25 Apr 2008 21:02:31 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-314593</guid>
		<description>"Just a Thought"

My intentions were good but I don't think I can get back to you today.  Apologies.  I won't forget to post what I find.</description>
		<content:encoded><![CDATA[<p>&#8220;Just a Thought&#8221;</p>
<p>My intentions were good but I don&#8217;t think I can get back to you today.  Apologies.  I won&#8217;t forget to post what I find.</p>
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		<title>By: Just A Thought</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-314517</link>
		<dc:creator>Just A Thought</dc:creator>
		<pubDate>Fri, 25 Apr 2008 19:49:00 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-314517</guid>
		<description>I would appreciate that, Bob.
 
It sounds like you're saying that the simpler the problem the less time it takes for an alert to be sent out. Makes sense. It's easier.

Alternately, a larger problem, based on the time required for possible additional testing and investigation, leaves no alert for a longer period of time, while the public continues to suffer ill effects. That seems more than a little worrysome and backwards.

When any danger is reported you would think some pretty rapid reaction would come about. After all, if the FDA (and whatever pharmaceutical company is involved) is not going to respond quickly to adverse post-marketing reports, then post-marketing studies seem nothing more than marketing at the cost of the public's well-being.

I'm just trying to understand and I do thank you for trying to find the answer.</description>
		<content:encoded><![CDATA[<p>I would appreciate that, Bob.</p>
<p>It sounds like you&#8217;re saying that the simpler the problem the less time it takes for an alert to be sent out. Makes sense. It&#8217;s easier.</p>
<p>Alternately, a larger problem, based on the time required for possible additional testing and investigation, leaves no alert for a longer period of time, while the public continues to suffer ill effects. That seems more than a little worrysome and backwards.</p>
<p>When any danger is reported you would think some pretty rapid reaction would come about. After all, if the FDA (and whatever pharmaceutical company is involved) is not going to respond quickly to adverse post-marketing reports, then post-marketing studies seem nothing more than marketing at the cost of the public&#8217;s well-being.</p>
<p>I&#8217;m just trying to understand and I do thank you for trying to find the answer.</p>
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		<title>By: Bob Freeman</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312933</link>
		<dc:creator>Bob Freeman</dc:creator>
		<pubDate>Fri, 25 Apr 2008 01:57:14 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312933</guid>
		<description>Hi, Just A Thought,

I'll see if I can get a time estimate for you.  If it's a slight labeling change I imagine it doesn't take that long.  (That's the form the majority of Alerts take.)  Following entry of your MedWatch report into the data base, a case series analysis is usually performed.  They aren't really that useful in establishing causality but may give hypotheses that can be explored in epidemiology studies (clinical studies, patient registries, prospective cohort studies).  Clincal studies, as you know, require time and involvement of the manufacturer.  Cohort studies from third-party data bases are easier to do, all things considered.

I realize I'm not answering your question adequately but the specific nature of the serious adverse event and its association with the drug will drive what the FDA requires and its time frame. Drugs associated with death and permanent disability will likely cause the FDA to move much faster.

Regardless, I'll get back to you tomorrow with what I can find.</description>
		<content:encoded><![CDATA[<p>Hi, Just A Thought,</p>
<p>I&#8217;ll see if I can get a time estimate for you.  If it&#8217;s a slight labeling change I imagine it doesn&#8217;t take that long.  (That&#8217;s the form the majority of Alerts take.)  Following entry of your MedWatch report into the data base, a case series analysis is usually performed.  They aren&#8217;t really that useful in establishing causality but may give hypotheses that can be explored in epidemiology studies (clinical studies, patient registries, prospective cohort studies).  Clincal studies, as you know, require time and involvement of the manufacturer.  Cohort studies from third-party data bases are easier to do, all things considered.</p>
<p>I realize I&#8217;m not answering your question adequately but the specific nature of the serious adverse event and its association with the drug will drive what the FDA requires and its time frame. Drugs associated with death and permanent disability will likely cause the FDA to move much faster.</p>
<p>Regardless, I&#8217;ll get back to you tomorrow with what I can find.</p>
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		<title>By: Just A Thought</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312890</link>
		<dc:creator>Just A Thought</dc:creator>
		<pubDate>Fri, 25 Apr 2008 01:28:37 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312890</guid>
		<description>Thank you, Bob

I'd be cool with that. How long do you suppose it takes to put out a notice?</description>
		<content:encoded><![CDATA[<p>Thank you, Bob</p>
<p>I&#8217;d be cool with that. How long do you suppose it takes to put out a notice?</p>
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		<title>By: Bob Freeman</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312817</link>
		<dc:creator>Bob Freeman</dc:creator>
		<pubDate>Fri, 25 Apr 2008 00:35:44 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312817</guid>
		<description>Tom, your point about difficulty in recruiting patients is very important.  I've experienced similar difficulties.

to Just a Thought--you're not going to get any feedback.  Alterts, when they are issued, are posted on the FDA MedWatch web site, communicated electronically to health care providers who have signed up for e-Alerts, and to Partners (mostly health care provider associations) and to health and medical media.</description>
		<content:encoded><![CDATA[<p>Tom, your point about difficulty in recruiting patients is very important.  I&#8217;ve experienced similar difficulties.</p>
<p>to Just a Thought&#8211;you&#8217;re not going to get any feedback.  Alterts, when they are issued, are posted on the FDA MedWatch web site, communicated electronically to health care providers who have signed up for e-Alerts, and to Partners (mostly health care provider associations) and to health and medical media.</p>
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		<title>By: Just A Thought</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312781</link>
		<dc:creator>Just A Thought</dc:creator>
		<pubDate>Fri, 25 Apr 2008 00:16:35 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312781</guid>
		<description>When you are the victim of a post-marketing study (a consumer), when the drug is not performing as intended, you report to the FDA, via MedWatch, and get the following letter.

In my experience, the words May and Might mean 'not gonna happen'.

Thanks for the automated form letter though, I feel all better now.

(one... two... shoot, I lost count. one... two...)

~~~~~~~~~~~~~~~~~~~~~~~~

Dear Reporter:

Thank you for submitting your report to MedWatch, The FDA Safety Information and Adverse Event Reporting Program.  

This acknowledgement confirms that your report was received.  Reports are added to a postmarketing safety database with similar reports and reviewed by the FDA’s postmarketing safety staff.  Voluntary reports are essential for ensuring the continued safety of FDA-regulated products.  One or two well-documented case reports may provide an early signal of unexpected problems and lead to additional evaluation.  This may result in FDA regulatory actions that improve the safety of the products used in patient care each day.  

You might be contacted by an FDA staff member if additional information on your report 
is needed.

Again, thank you for taking the time to submit your report.


Sincerely yours,

MedWatch</description>
		<content:encoded><![CDATA[<p>When you are the victim of a post-marketing study (a consumer), when the drug is not performing as intended, you report to the FDA, via MedWatch, and get the following letter.</p>
<p>In my experience, the words May and Might mean &#8216;not gonna happen&#8217;.</p>
<p>Thanks for the automated form letter though, I feel all better now.</p>
<p>(one&#8230; two&#8230; shoot, I lost count. one&#8230; two&#8230;)</p>
<p>~~~~~~~~~~~~~~~~~~~~~~~~</p>
<p>Dear Reporter:</p>
<p>Thank you for submitting your report to MedWatch, The FDA Safety Information and Adverse Event Reporting Program.  </p>
<p>This acknowledgement confirms that your report was received.  Reports are added to a postmarketing safety database with similar reports and reviewed by the FDA’s postmarketing safety staff.  Voluntary reports are essential for ensuring the continued safety of FDA-regulated products.  One or two well-documented case reports may provide an early signal of unexpected problems and lead to additional evaluation.  This may result in FDA regulatory actions that improve the safety of the products used in patient care each day.  </p>
<p>You might be contacted by an FDA staff member if additional information on your report<br />
is needed.</p>
<p>Again, thank you for taking the time to submit your report.</p>
<p>Sincerely yours,</p>
<p>MedWatch</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312573</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Thu, 24 Apr 2008 21:24:38 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312573</guid>
		<description>Tom - Appreciate the point.  Surely, if FDA has the will to do anything at all in this regard, they will be selective - _very_ selective.

In the past, they've made much the same kind of points that you do here to explain why a number of these studies don't happen.</description>
		<content:encoded><![CDATA[<p>Tom - Appreciate the point.  Surely, if FDA has the will to do anything at all in this regard, they will be selective - _very_ selective.</p>
<p>In the past, they&#8217;ve made much the same kind of points that you do here to explain why a number of these studies don&#8217;t happen.</p>
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		<title>By: Tom</title>
		<link>http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312226</link>
		<dc:creator>Tom</dc:creator>
		<pubDate>Thu, 24 Apr 2008 18:28:34 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/promises-promises-what-post-marketing-studies/#comment-312226</guid>
		<description>I have no doubt that some companies drag their heels on post-marketing studies.  However, some trials are delayed or never happen because of the difficulty in recruiting patients.  One drug I was involved with got approved by FDA with the caveat that the company had to conduct a large study of high-dose usage in pediatrics.  Trouble was, very few children actually required high doses of the drug, it was impossible to identify them prospectively, doctors had an excellent alternative treatment to high-dose use (combining two separate meds, in this case)and parents refused to choose high-dose when presented with multiple treatment options.  After several years of continuous recruitment efforts, there simply weren't enough patients available.  Some post-marketing studies simply involve difficult or very small patient groups, such as those with kidney or liver disfunction. Hopefully, FDA's public list of industry "violators" will somehow differentiate those who won't meet their regulatory obligations from those who  can't.</description>
		<content:encoded><![CDATA[<p>I have no doubt that some companies drag their heels on post-marketing studies.  However, some trials are delayed or never happen because of the difficulty in recruiting patients.  One drug I was involved with got approved by FDA with the caveat that the company had to conduct a large study of high-dose usage in pediatrics.  Trouble was, very few children actually required high doses of the drug, it was impossible to identify them prospectively, doctors had an excellent alternative treatment to high-dose use (combining two separate meds, in this case)and parents refused to choose high-dose when presented with multiple treatment options.  After several years of continuous recruitment efforts, there simply weren&#8217;t enough patients available.  Some post-marketing studies simply involve difficult or very small patient groups, such as those with kidney or liver disfunction. Hopefully, FDA&#8217;s public list of industry &#8220;violators&#8221; will somehow differentiate those who won&#8217;t meet their regulatory obligations from those who  can&#8217;t.</p>
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