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	<title>Comments on: You Can Report Side Effects To The FDA?</title>
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	<pubDate>Sat, 20 Mar 2010 18:47:18 +0000</pubDate>
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		<title>By: Grieving</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-293035</link>
		<dc:creator>Grieving</dc:creator>
		<pubDate>Fri, 18 Apr 2008 17:22:06 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-293035</guid>
		<description>Medwatch?  A joke.  I've gone through many Medwatch reporting data for Zyprexa, which killed my son.  Some are very succinct and thorough, especially those written by doctors.  Since my son's doctor disappeared, I don't know what he might have reported other than the nothing he did report.  I reported the death of my own son and never even received a standard email to tell me it had been received.  And of course the FDA did nothing until three front page newspaper articles embarrassed them to place a warning in early 2004 - for all atypicals.  No singling out the one with the worst reported side effects.

I like Consumer Union's idea but can see Pharma working around it and the FDA doing nothing..as usual.</description>
		<content:encoded><![CDATA[<p>Medwatch?  A joke.  I&#8217;ve gone through many Medwatch reporting data for Zyprexa, which killed my son.  Some are very succinct and thorough, especially those written by doctors.  Since my son&#8217;s doctor disappeared, I don&#8217;t know what he might have reported other than the nothing he did report.  I reported the death of my own son and never even received a standard email to tell me it had been received.  And of course the FDA did nothing until three front page newspaper articles embarrassed them to place a warning in early 2004 - for all atypicals.  No singling out the one with the worst reported side effects.</p>
<p>I like Consumer Union&#8217;s idea but can see Pharma working around it and the FDA doing nothing..as usual.</p>
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		<title>By: Dr R.D.Steinbaum</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-260578</link>
		<dc:creator>Dr R.D.Steinbaum</dc:creator>
		<pubDate>Tue, 08 Apr 2008 01:39:14 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-260578</guid>
		<description>One thing is for sure.The answer to this problem is not more statistics.
The problem is clear:patient are taking chemical drugs that are dangerous and toxic for the organism.
The Pharm Industry are far away from honesty,close to greedy.You can expect from them more and more [dirty]tricks to fill their pockets
The solution for this problem in not existing.Only partial answers is what we have.Reporting can be one,but leave us with a feeling of futile</description>
		<content:encoded><![CDATA[<p>One thing is for sure.The answer to this problem is not more statistics.<br />
The problem is clear:patient are taking chemical drugs that are dangerous and toxic for the organism.<br />
The Pharm Industry are far away from honesty,close to greedy.You can expect from them more and more [dirty]tricks to fill their pockets<br />
The solution for this problem in not existing.Only partial answers is what we have.Reporting can be one,but leave us with a feeling of futile</p>
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		<title>By: HorusCat</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-251304</link>
		<dc:creator>HorusCat</dc:creator>
		<pubDate>Fri, 04 Apr 2008 01:50:44 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-251304</guid>
		<description>JaT,
You bring up a valid point.  I think it comes down to one of those pornography things:  I know it when I see it.  If a doc says he gave a patient Zoloft and the patient had mild loose stools, that is a nuisance side effect.  If the doc says the patient had diarrhea for a couple of days, that seems reportable.  You are right, we should report absolutely every mention of anything adverse in conjunction with our drugs.  In real life, that just isn't going to happen.  In the case you mentioned above, the AED, that doesn't seem to me to be nuisance side effects.  Nuisance with gabapentin is drowsiness.  Serious is patient having trouble waking up.  Numb lips, etc., are not one of the 2-3 most common side effects.  

We don't call MedWatch--most companies have a reporting mechanism.  We can report minor events through our computer system; or we can make a phone call.  Whoever is on the other end gets as much data from us as possible (we don't have patient name and all that, because that would be HIPAA violation, but we can give doctor name, phone number, fax number, etc).  I have had doctors report that they received a phone call from the company to clarify events, and even, in the case of one serious event, pretty extensive follow-up from both the company and the FDA.

The system is, as you say, a passive system that relies on human judgment.  The big obstacle is how to sort through all the static and find the signal. Maybe a computer-sort program where adverse events get scanned into a program, which sorts for commonalities with drug names and adverse event symptoms.  So if Drug A came up in conjunction with symptoms X, Y and Z with a certain frequency, a flag came up and brought human inspection into play.  One problem with that is sometimes a really serious side effect may occur very rarely (like PML with Tysabri)--another problem would be the lack of commonality of language with how people describe adverse events.  One person's sedation is another person's good night sleep.</description>
		<content:encoded><![CDATA[<p>JaT,<br />
You bring up a valid point.  I think it comes down to one of those pornography things:  I know it when I see it.  If a doc says he gave a patient Zoloft and the patient had mild loose stools, that is a nuisance side effect.  If the doc says the patient had diarrhea for a couple of days, that seems reportable.  You are right, we should report absolutely every mention of anything adverse in conjunction with our drugs.  In real life, that just isn&#8217;t going to happen.  In the case you mentioned above, the AED, that doesn&#8217;t seem to me to be nuisance side effects.  Nuisance with gabapentin is drowsiness.  Serious is patient having trouble waking up.  Numb lips, etc., are not one of the 2-3 most common side effects.  </p>
<p>We don&#8217;t call MedWatch&#8211;most companies have a reporting mechanism.  We can report minor events through our computer system; or we can make a phone call.  Whoever is on the other end gets as much data from us as possible (we don&#8217;t have patient name and all that, because that would be HIPAA violation, but we can give doctor name, phone number, fax number, etc).  I have had doctors report that they received a phone call from the company to clarify events, and even, in the case of one serious event, pretty extensive follow-up from both the company and the FDA.</p>
<p>The system is, as you say, a passive system that relies on human judgment.  The big obstacle is how to sort through all the static and find the signal. Maybe a computer-sort program where adverse events get scanned into a program, which sorts for commonalities with drug names and adverse event symptoms.  So if Drug A came up in conjunction with symptoms X, Y and Z with a certain frequency, a flag came up and brought human inspection into play.  One problem with that is sometimes a really serious side effect may occur very rarely (like PML with Tysabri)&#8211;another problem would be the lack of commonality of language with how people describe adverse events.  One person&#8217;s sedation is another person&#8217;s good night sleep.</p>
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		<title>By: Just A Thought</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-250892</link>
		<dc:creator>Just A Thought</dc:creator>
		<pubDate>Thu, 03 Apr 2008 22:08:54 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-250892</guid>
		<description>Just saying because "the most common nuisance side effects" may be different from one drug to another.</description>
		<content:encoded><![CDATA[<p>Just saying because &#8220;the most common nuisance side effects&#8221; may be different from one drug to another.</p>
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		<title>By: Just A Thought</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-250852</link>
		<dc:creator>Just A Thought</dc:creator>
		<pubDate>Thu, 03 Apr 2008 21:43:09 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-250852</guid>
		<description>HorusCat,
 
Interesting comments because my above post started out much longer and I edited out the part where I asked if the drug companies have to report adverse reactions to the FDA verbatim. I didn't think so. And I do not mean to sound nasty at all, but...

A drug company rep is not a doctor or a licensed pharmacologist (am I wrong?). By not reporting some or all of the symptoms that are reported to you, you may well be hiding a grouping of common symptoms that might represent a bigger problem. No?
 
IE: AEDs (anti-epileptic drugs). A person refills his medication or switches to a new one. In doing so he gets fuzzy headed, numb face and lips, tunnel vision and hearing, auras (partial seizures), tremors, and a rash.
He goes to his doctor because he is sick, but any of these things CAN occur with AEDs. So what would you report? The rash? Maybe there is something really wrong with that drug to cause such an onslaught of adverse reactions. Could be a bad lot, could be the NMP (new manufacturing process) of an older drug, could be a change in one of the excipients.

All symptoms should be reported to MedWatch. In fact, it would be nice if the drug reps reported them to MedWatch personally. Of course the rep would probably lose his job. It is scary that one might assume that the patient may just have something else going on and not report his adverse reactions. 

As it is, the FDA gets the information 5th hand after everyone else makes their assessment.
1st) patient, 2nd) doctor, 3rd) drug company rep, 4th) the drug company (lawyers?), and 5th) the FDA.
What are the chances the FDA is going to get accurate information if everyone in between sees fit to omit what they believe to be a minor incident?</description>
		<content:encoded><![CDATA[<p>HorusCat,</p>
<p>Interesting comments because my above post started out much longer and I edited out the part where I asked if the drug companies have to report adverse reactions to the FDA verbatim. I didn&#8217;t think so. And I do not mean to sound nasty at all, but&#8230;</p>
<p>A drug company rep is not a doctor or a licensed pharmacologist (am I wrong?). By not reporting some or all of the symptoms that are reported to you, you may well be hiding a grouping of common symptoms that might represent a bigger problem. No?</p>
<p>IE: AEDs (anti-epileptic drugs). A person refills his medication or switches to a new one. In doing so he gets fuzzy headed, numb face and lips, tunnel vision and hearing, auras (partial seizures), tremors, and a rash.<br />
He goes to his doctor because he is sick, but any of these things CAN occur with AEDs. So what would you report? The rash? Maybe there is something really wrong with that drug to cause such an onslaught of adverse reactions. Could be a bad lot, could be the NMP (new manufacturing process) of an older drug, could be a change in one of the excipients.</p>
<p>All symptoms should be reported to MedWatch. In fact, it would be nice if the drug reps reported them to MedWatch personally. Of course the rep would probably lose his job. It is scary that one might assume that the patient may just have something else going on and not report his adverse reactions. </p>
<p>As it is, the FDA gets the information 5th hand after everyone else makes their assessment.<br />
1st) patient, 2nd) doctor, 3rd) drug company rep, 4th) the drug company (lawyers?), and 5th) the FDA.<br />
What are the chances the FDA is going to get accurate information if everyone in between sees fit to omit what they believe to be a minor incident?</p>
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		<title>By: HorusCat</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-248718</link>
		<dc:creator>HorusCat</dc:creator>
		<pubDate>Thu, 03 Apr 2008 10:24:09 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-248718</guid>
		<description>Justice,
Point well taken.  
HC</description>
		<content:encoded><![CDATA[<p>Justice,<br />
Point well taken.<br />
HC</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-246625</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Thu, 03 Apr 2008 02:41:04 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-246625</guid>
		<description>I gues one other lesson implicit in the others.  A passive reporting system like Medwatch is doomed to failure - whether one is relying on docs, companies, or pts to report.  This needs to supplemented by more active surveillance based on what one already might anticipate as class effects and the like.  My own situation could easily have been predicted from the basic science, had anyone cared to pursue it.  

There have been a few such programs in the past.  But when FDA started throwing things out of the window to make their half of the PDUFA payments, these were some of the first programs to go.</description>
		<content:encoded><![CDATA[<p>I gues one other lesson implicit in the others.  A passive reporting system like Medwatch is doomed to failure - whether one is relying on docs, companies, or pts to report.  This needs to supplemented by more active surveillance based on what one already might anticipate as class effects and the like.  My own situation could easily have been predicted from the basic science, had anyone cared to pursue it.  </p>
<p>There have been a few such programs in the past.  But when FDA started throwing things out of the window to make their half of the PDUFA payments, these were some of the first programs to go.</p>
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		<title>By: Justice in Michigan</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-246590</link>
		<dc:creator>Justice in Michigan</dc:creator>
		<pubDate>Thu, 03 Apr 2008 02:31:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-246590</guid>
		<description>One anecdote doesn't make an argument, but here goes ... I had a significant AE related to an eye med I was taking some years ago.  It was confirmed on three rechallenges (the third of which I barely got through).  

HC writes, " If a side effect truly is bad enough to push a patient to the doctor, the doc will probably mention it to the rep."  In my own case, I am quite sure this never happened.

Turns out, a few years later, a well-known (worldwide) opthamologist got intersted in the issue.  I had seen him once; he ended up contacting me, more because of a shared professional connection than the fact that I had been his pt..  A number of other cases suddenly came out of woodwork (wherever that is), mainly because he and some fellow researchers actively searched for them.  Article about it appeared in relevant journal, but label has still not been changed.

This took five years and an almost perfect storm of fortuitous circumstances.  I conclude the following: we probably never seen more than the tip of the iceberg, even with serious AEs; there is no "natural process" in which they will inevitably become known; becoming known is only tangentially related to a label change; the whole reporting process needs to be rethought at all ends.  It won't happen either automatically or by a few tweaks here and there.</description>
		<content:encoded><![CDATA[<p>One anecdote doesn&#8217;t make an argument, but here goes &#8230; I had a significant AE related to an eye med I was taking some years ago.  It was confirmed on three rechallenges (the third of which I barely got through).  </p>
<p>HC writes, &#8221; If a side effect truly is bad enough to push a patient to the doctor, the doc will probably mention it to the rep.&#8221;  In my own case, I am quite sure this never happened.</p>
<p>Turns out, a few years later, a well-known (worldwide) opthamologist got intersted in the issue.  I had seen him once; he ended up contacting me, more because of a shared professional connection than the fact that I had been his pt..  A number of other cases suddenly came out of woodwork (wherever that is), mainly because he and some fellow researchers actively searched for them.  Article about it appeared in relevant journal, but label has still not been changed.</p>
<p>This took five years and an almost perfect storm of fortuitous circumstances.  I conclude the following: we probably never seen more than the tip of the iceberg, even with serious AEs; there is no &#8220;natural process&#8221; in which they will inevitably become known; becoming known is only tangentially related to a label change; the whole reporting process needs to be rethought at all ends.  It won&#8217;t happen either automatically or by a few tweaks here and there.</p>
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		<title>By: HorusCat</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-245726</link>
		<dc:creator>HorusCat</dc:creator>
		<pubDate>Wed, 02 Apr 2008 22:52:21 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-245726</guid>
		<description>And one thing I didn't think of...how many of those side effects occur with generics?  No reps to report those.  And some, like rash with penicillin, are important and warrant a trip to the doc, if only to be warned never to take penicillin again.</description>
		<content:encoded><![CDATA[<p>And one thing I didn&#8217;t think of&#8230;how many of those side effects occur with generics?  No reps to report those.  And some, like rash with penicillin, are important and warrant a trip to the doc, if only to be warned never to take penicillin again.</p>
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		<title>By: HorusCat</title>
		<link>http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-245721</link>
		<dc:creator>HorusCat</dc:creator>
		<pubDate>Wed, 02 Apr 2008 22:51:06 +0000</pubDate>
		<guid isPermaLink="false">http://www.pharmalot.com/2008/04/you-can-report-side-effects-to-the-fda/#comment-245721</guid>
		<description>You all make excellent points.  What I would proffer is 1) what a consumer interprets as a side effect may be totally unrelated to the medication--thus this poll isn't necessarily accurate.  What kind of side effect sends you to the doctor or hospital? A rash may send someone to the doctor, yet as a side effect to medication (except for a few exceptions like Lamictal) it's a non-event. I'd like a little more information before I gasp in dismay.
2) If a side effect truly is bad enough to push a patient to the doctor, the doc will probably mention it to the rep, and the rep has to report it.  I don't call in every report of drowsiness I get with my med, but anything beyond the most common nuisance side effects, I call in.</description>
		<content:encoded><![CDATA[<p>You all make excellent points.  What I would proffer is 1) what a consumer interprets as a side effect may be totally unrelated to the medication&#8211;thus this poll isn&#8217;t necessarily accurate.  What kind of side effect sends you to the doctor or hospital? A rash may send someone to the doctor, yet as a side effect to medication (except for a few exceptions like Lamictal) it&#8217;s a non-event. I&#8217;d like a little more information before I gasp in dismay.<br />
2) If a side effect truly is bad enough to push a patient to the doctor, the doc will probably mention it to the rep, and the rep has to report it.  I don&#8217;t call in every report of drowsiness I get with my med, but anything beyond the most common nuisance side effects, I call in.</p>
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