medication safety

No Medication is Perfectly Safe

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A few weeks ago, I was accused of being biased and unscientific for acknowledging that all medications carry risks; that no medication was, in contrast to this commenter’s perception, ‘perfectly safe’. In her view, some medications were perfectly safe, even during pregnancy.

I went on to suggest that while no medication was perfectly safe, certainly some medications were safer than others and some medications were quite necessary for either maternal or fetal health, despite their potential risk for side effects. Sometimes those risks are minimal, and other times, they are not so minimal but necessary nevertheless. Medication use, whether during pregnancy or not, is never without risk. This commenter would have nothing of it. Certain medications were perfectly safe and I was biased and unscientific for suggesting otherwise.

The accusation was in response to the suggestion that meds should not be taken during pregnancy, posted alongside a press report about a recent study delineating the newly recognized side effects to male fetal development when mom takes of paracetamol, (acetaminophen – Tylenol in the US), during pregnancy. Up until recently, the safety of this over-the-counter drug was not contended (aside from the liver damage) and so generations of women took this medication believing it was perfectly safe. It wasn’t until researchers began investigating a broader range of outcome variables than is traditionally considered that these issues with fetal development became apparent. In other words, it wasn’t until we asked the right questions, until we knew what to look for, that we found the right answers.

When one studies maternal health long enough, a common pattern emerges. Drugs once considered perfectly safe are seemingly overnight recognized as not so safe. In reality, this recognition took years, sometimes decades before bubbling to the surface. Across the entirety of pharmacology we see this happen with great frequency, but in maternal health, the presumption of safety has always been spurious at best. More often than not, the research to determine safety is never conducted, and when it is, the studies suffer from serious methodological flaws, including small sample size and overly narrow range of outcome variables.

This happens across maternal health research. For example, a recent, very well-funded and highly touted study of blood pressure medications during pregnancy didn’t even ask whether or which medications to lower blood pressure during pregnancy were safe or safer. It simply asked whether high dose or low dose, aggressive or not so aggressive treatment of high blood pressure during pregnancy was more effective. Since all of the women studied were taking medications, the complications were similar. Since the women in the study were on multiple medications during pregnancy, tying any one complication to a specific medication was impossible. This allowed the researchers to avoid the side-effect/complication discussion altogether and avoid it they did. Beyond simply carrying the pregnancy to term, how did these medications affect overall maternal health, fetal health and infant development? We don’t know, these questions were not asked.

Conventional outcome measures for most maternal/fetal health research include only the most easily observable signs of maternal complications and fetal distress and development, generally within a short time frame of birth. Since those variables often show no apparent connection to the medication (because of design flaws in the research as in the blood pressure study above), the medication is deemed safe. But is it?

This brings us back to the absurd notion that any medication can be perfectly safe. When evaluating research on any topic we have to realize that how we frame the questions and what questions are asked determine what we can know about a given subject. With medical research this is not well understood, except perhaps by those who benefit from an incomplete knowledge set. In women’s health we see this pattern all the time, poorly designed studies fail to ask the right questions or, more often than not, there is no research at all. In both cases, the absence of evidence about a medication’s ill-effects is then transformed into evidence of an absence of any ill-effects e.g. that the medication is perfectly safe. And once the label of perfectly safe becomes entrenched, it is very difficult to disprove.

In the case of the paracetamol research, it wasn’t until the notion of endocrine disruption became more commonplace that researchers expanded their scope of side-effects. Kudos to the researchers for connecting paracetamol to male genital development, but if we’re honest with ourselves, not many of us, even if we are researchers, would have thought to ask that question. We couldn’t have considered questions connecting male or female genital development (notice, they did not concern themselves with female genital aberrations) to acetaminophen until recently, until the notion of endocrine disruption became more firmly established in medical research. When we don’t know what questions to ask (or tacitly ignore certain questions as in the blood pressure research) the answers returned are inadequate.

Returning to my biases about perfectly safe medications: I do have biases. Everyone does. I begin from the standpoint that nothing in life, but especially in medicine, is perfectly safe. This presumption is then colored by the understanding that most research is necessarily flawed, sometimes by economic interests, sometimes by poor design and sometimes just by the limitations of the knowledge base within which the investigators were operating. An absence of evidence is never evidence of absence. The lack of evidence means only that we have yet to ask the right questions. Does that mean medications are never warranted? Certainly not. It just means that I accept that all medications carry risks, many of which we have yet to understand. Those are my biases.

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This article was published on Hormones Matter originally on July 1, 2015. 

SCOTUS Decision on Medication Safety: No Product Liability

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Over two years ago, amidst the DOMA and Voting Rights cases, the Supreme Court of the United States (SCOTUS) quietly ruled in favor of pharmaceutical companies indicating that generic drug makers have no legal obligation to update labeling and warn patients of nasty side-effects should those reactions occur post FDA approval. The case, Mutual Pharmaceutical Co. v Bartlett is a decision that will affect medication safety, healthcare responsibility and states rights for years to come, but few in the media bothered to cover the ruling.

Background of the Case: Mutual Pharmaceutical Co. v Bartlett

In 2004 Karen Bartlett was prescribed a topical NSAID pain-reliever called Sulindac for her shoulder pain. Sulindac is generic version of Merck’s Clinoril that is manufactured by Mutual Pharmaceutical. Shortly thereafter she developed toxic epidermal necrolysis (TEN) – a severe, life threatening and debilitating adverse reaction to the drug. Sulindac caused her skin to peel away from her body, a gruesome, flesh-eating reaction that spread over most of her body.

According to documents discovered later, the drug makers, Merck originally and Mutual for the generic version, knew about the potential for TEN but failed to label it. (Merck has since changed their labeling). Ms. Bartlett sued Mutual under New Hampshire’s design-defect law and was awarded $21 million. Mutual appealed under the auspices that they were not responsible for labeling because that rested with the federal government and the FDA. Since the FDA had not, in its original approval of the drug included the warning, the generic company could not change the labeling without violating federal law. Moreover, even though not labeling the drug violated New Hampshire state law, under which the case was originally brought, state law was in conflict with federal law.

Ms. Bartlett’s case before SCOTUS rested on the fact that Mutual knew about the ‘defect’ and failed to warn consumers. In state court she won. But in the appeal, Mutual contended that even though they knew about the dangers of the drug, as a maker of generic drugs, which are essentially copies of the name-brand drugs, they were not only not responsible for the labeling, Merck and FDA were, Mutual could not change the labeling under federal law. The state’s remedy, and upon which much of the SCOTUS case rested, was to not permit the sale of the ‘defective’ product – the drug – in New Hampshire. In other words, to abide by state law, Mutual should not have sold and not be allowed to sell the product in New Hampshire. SCOTUS again disagreed, effectively forcing the sale of ‘defective’ products’ in states.

There was no question that the drug was responsible for Ms. Bartlett’s injuries, but the since the case rested on the eminence of federal versus state law and the work-around proposed by the state, there was ample precedence for SCOTUS to overturn the lower court’s ruling and they did so, 5-4, mostly along party lines.

SCOTUS documents:

We must decide whether federal law pre-empts the New Hampshire design-defect claim under which respondent Karen Bartlett recovered damages from petitioner Mutual Pharmaceutical, the manufacturer of sulindac, a generic nonsteroidal anti-inflammatory drug (NSAID). New Hampshire law imposes a duty on manufacturers to ensure that the drugs they market are not unreasonably unsafe, and a drug’s safety is evaluated by reference to both its chemical properties and the adequacy of its warnings. Because Mutual was unable to change sulindac’s composition as a matter of both federal law and basic chemistry, New Hampshire’s design-defect cause of action effectively required Mutual to change sulindac’s labeling to provide stronger warnings. But, as this Court recognized just two Terms ago in PLIVA, Inc. v. Mensing, 564 U. S. ___ (2011), federal law prohibits generic drug manufacturers from independently changing their drugs’ labels.

In an opinion written by Justice Alito:

Accordingly, state law imposed a duty on Mutual not to comply with federal law. Under the Supremacy Clause, state laws that require a private party to violate federal law are pre-empted and, thus, are “without effect.” Maryland v. Louisiana, 451 U. S. 725, 746 (1981) .

The Court of Appeals’ solution—that Mutual should simply have pulled sulindac from the market in order to comply with both state and federal law—is no solution. Rather, adopting the Court of Appeals’ stop-selling rationale would render impossibility pre-emption a dead letter and work a revolution in this Court’s pre-emption case law.

Accordingly, we hold that state-law design-defect claims that turn on the adequacy of a drug’s warnings are pre-empted by federal law under PLIVA. We thus reverse the decision of the Court of Appeals below.

Why This Matters

SCOTUS ruled that manufacturers of generic drugs have no safety or labeling obligations beyond what was expressly given by the brand name company and the FDA approval. If the FDA approved a particular label and adverse events appear later, even when associated with the generic drug, the manufacturer of the generic drug is not liable. The makers of the brand name drug are still liable, but only for their brand name drugs. When an individual is given the generic version rather than the brand name version, even if those two compounds are exactly the same, the individual cannot sue the generic manufacturer per this new ruling, nor can he/she sue the brand name manufacturer, because the adverse event occurred with the generic and the brand name company is not responsible for the generic.

Since the majority of all prescriptions are for generic medications, this ruling effectively absolves drug manufacturers of responsibility for adverse events, once FDA approved.  What’s more, where states could have stepped in and prevented the sale of defective products within their boundaries, this ruling preempts that protection as well. If the federal agencies say it is safe, the states can do nothing. For a conservative court, this is a pretty big usurping of states rights.

Can we sue the FDA for failing to protect consumers?

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Medication Safety and Efficacy Studies: Share Your Experience

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Is this Medication or Vaccine Good for Me?

That is the question on everyone’s mind; is this medication good for me? How does one decide? The mandated medication package inserts tell one story. The online drug reaction and interaction lists are long and complicated. Adverse events data are incomplete and patient stories reflect individual reactions. Where are the reports that put numbers to the side-effects and adverse reactions? Where are the real world data that show risks for patients of different age groups, men versus women, or on multiple medications? Lucine Health Sciences and Hormones Matter are collecting those data and you can help.

Understanding Side Effects

While we cannot make your medication decisions for you, we can collect more complete side-effect data from patients like you, from around the world and we can offer those data reports to patients, physicians and industry. We think everyone deserves to know the frequency, severity, and chronicity of side-effects. We think everyone deserves to know whether a the benefits of a medication or vaccine outweigh the risks. Don’t you?

How You Can Help

Take a Health Survey

Take a few minutes to complete a survey about the medications and surgical procedures you have utilized. Take as many health surveys as are applicable and share the surveys with your friends. All surveys are anonymous and completely voluntary. We’re adding more surveys every month, so check back frequently or sign up for our weekly newsletter to keep abreast of the latest research news.

Take one of our health surveys:

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Hormones Matter – Legal Structure

Hormones Matter is the health media arm of Lucine Health Sciences. We leverage the broad educational and social media reach of Hormones Matter to crowdsource critical, direct-to-patient research. Lucine is a C-corporation by federal standards, a B-Corp (for benefit corporation) in the state of Nevada. What this means is that any money you contribute, either through the donate or the subscribe buttons, is not tax deductible; for that we would have to be a not-for-profit enterprise.

For more information about our research philosophy, data ethics commitment or business model, follow the links or just click on our home page: Lucine Health Sciences and snoop around.

If you’d like to support or commission a study on a specific medication or surgical procedure, we can do that too. Simply contact us here.

Lucine neither collects nor distributes personally identifying patient information, see our Ethics and Privacy for more details. We will, however, publish trended reports for open access and custom reports for industry. For more information, see Research Services.

  • In February of 2016, Lucine received a grant to conduct a multi-phased study on the risks for blood clots with hormonal birth control. All other research remains unfunded.

Are Safer Vaccines Possible?

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Perhaps, but only if we can admit that some vaccines cause injury and rework the entire vaccine development and monitoring system.

Vaccine Safety

Vaccine safety is a controversial topic, almost as controversial as politics or religion. In polite company, it is best not to bring up the subject, lest an all-out shouting match ensue.  On the one side, we have the pro-vaccine camp, who believes wholeheartedly that every vaccine is necessary and safe – ‘why else would they be on the market?’ is a common refrain. On the other, the anti-vaccine crowd, who for various reasons, are against vaccines. Some among the anti-vaxers are fundamentally against all vaccines as a matter of religious or libertarian principle. In their eyes, vaccination represents the worst of big government subjugation. It is an attack on their very freedom. Others in the anti-vax crowd come to their views experientially, through injury or tragedy.  Somewhere in the middle, the rest of us, parents, scientists, doctors and health advocates who are neither for nor against vaccines in principle, but who just want our kids to be safe and healthy.

Beyond For or Against

Much like the polarization of politics, the polarization of the vaccine safety and efficacy, all but nullifies reasoned concerns. One is either for or against vaccines. There is no grey area. This is fantastic for vaccine manufacturers because every concern, every injury can be written off by simply de-legitimizing the claimant – placing them in the nutty anti-vax camp, while correspondingly and overwhelming flooding the media with pro-vaccine marketing. Money does indeed buy power and power protects profits. With virtually all vaccines licensed manufactured by just five companies and revenues exceeding $25 billion annually and growing, the money and power are highly concentrated.

Stepping back though, away from the money and marketing, why anyone with a brain would believe that any vaccine or medication was universally safe and effective defies logic, not to mention the inherent variability of human physiology. To be entirely and ardently pro-vaccine as many are, one has to choose to ignore that basic fact – that for some people, some vaccines and medications either will not work or worse, will cause great injury. To ignore that fact, especially when there are no direct financial incentives to do so, one has to invalidate the tragedies that are in front of them; to convince oneself that the injured person before them is either lying to gain attention or simply is not credible and therefore not to be taken seriously. Either way, the net result of de-legitimizing injury, is to shutter the possibility of additional research, research that might find a connection. It’s quite a deft bit of cognitive dissonance, more so as the evidence of injury mounts.

De-legitimizing a claim of vaccine injury is easy; attack the person, not the claim, label the mom (because it is almost always moms making these claims) as irrational (hysterical), ignorant, and best of all, as anti-science; as if science is infallible and all-knowing rather than dynamic and changing. Ironically, bolstering the certitude of science, especially that which comes from organizations whose fiduciary or political obligations demand results remain in their favor, does more to reduce the credibility of the scientific endeavor and the public trust than simply admitting that sometimes the science is wrong or not nearly as clear as we once had believed. Polarization is more than just annoying and inconvenient. It is dangerous.

Skewed Development and Evaluation Process

As with the drug industry, especially after the recent Supreme Court decisions, the entire infrastructure of the vaccine industry is skewed in favor of finding vaccines safe and effective. There is very little space or motivation to find a vaccine dangerous. According to a recent report on Conflicts of Interest in  Vaccine Safety Research:

Fixing the Vaccine System – The Long Game

There is no easy or quick fix. The systems and barriers to vaccine, and indeed, drug safety are deeply entrenched in organizational and legal frameworks. The pendulum has swung so far away from consumer safety in favor of corporate protections that efforts to fix these problems must be viewed in terms of a long game; one that recognizes institutional and policy change has to take place over the next 10-20 years. The first step, however, is to recognize there is a problem and that vaccine injuries are likely within a system where there is little transparency and even less accountability for injuries.

The second and more difficult phase includes the major policy and infrastructure changes.
Those are a mess. Many are discussed in the piece Conflicts of Interest in  Vaccine Safety Research.  Many more need to be added. I will be writing a piece on this topic over the coming weeks. If you would like to contribute your thoughts on removing conflicts of interest from the vaccine safety and indeed, the entire drug development and review process, send me a note. In the mean time, we’re doing our part to understand Gardasil and Cervarix, vaccine safety and injury.

We Need Your Help

More people than ever are reading Hormones Matter, a testament to the need for independent voices in health and medicine. We are not funded and accept limited advertising. Unlike many health sites, we don’t force you to purchase a subscription. We believe health information should be open to all. If you read Hormones Matter, like it, please help support it. Contribute now.

Yes, I would like to support Hormones Matter. 

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