An Iron Curtain Has Descended Upon Psychopharmacology
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In practice, of course, some of the rejected drugs aren't explicitly rejected by the FDA but rather rejected by the system because they are never put through the FDA screening in the first place, but the principle is the same.
One would ideally want to set the difficulty of getting through FDA testing to maximize some quantity, such as the average effect of an approved drug on people's Quality Adjusted Life Years. But it's clear that this is not actually what happens. When the FDA rejects a drug people never hear about the lives that were not saved by it, but if even a single person is killed by a drug that was let through FDA screening. Every study on the matter that I've seen says that the FDA is actually way too restrictive in how it regulates drugs. And I should mention that this is in contrast to other countries such as most of Europe or Canada or Japan which have much saner drug regulation regimes.
I should also say that this is only a criticism of the FDA in it's role as a drug regulator. It seems to do a pretty good job as a food regulator. I suppose the number of voters involved in food production dwarfs those involved in drug production.
[1] You get more type 1 errors for each type 2 error. http://en.wikipedia.org/wiki/Type_I_and_type_II_errors
The pendulum swings back and forth. A decade ago, the FDA got hammered for being too cautious. Then Vioxx happened and they got hammered for being to lenient. I think the FDA does a dam good job to be honest. Mistakes are made, but I'd give them an A- overall.
The other thing to keep in mind is that the US has pretty lenient "supplement" regulations. As long as you can prove it's safe and don't make efficacy claims you can't backup the FDA will often leave you alone. I'm often amazed at what the FDA allows regular citizens to buy.
That's the big problem.
In addition, the public has little appetite for conversations that start with "We balance risk so only a handful of Americans die..." The public has zero tolerance for any mistakes the FDA makes, which I think is unfair, but that's the world the FDA lives in.
... because it wasn't safe for use by pregnant women? Am I not understanding part of what you're saying?
I wouldn't consider that to be truly "effective" when the side-effects are quite serious. And by the nature of the medication, all pregnant women taking the drug are necessarily at risk of these side effects.
The scandal did lead to FDA drug testing reforms, but that was after the fact.
(Also, there were US victims of thalidomide birth defects. There were human clinical trials and the American distributor aggressively distributed "free samples" to employees.)
My argument is that that situation bred a lot of cautiousness at the FDA after the fact.
Except for example, Canada tends to just accept whatever the FDA accepts.
FDA could not do anything to protect her dear US citizens. She couldn't sue the manufacturer or ask them to do further research or impose black box warning or pull the drug out of the market because it was simply beyond their jurisdiction. Doing any of that would constitute a version of the Iron Curtain.
So FDA is doing the right thing to prevent this from even happening by requiring the manufacturer to have everything in place before the drug sees the market.
Furthermore, a randomized controlled trial is no synonym of "drug is good to use". Do they work on US populations? How big is the sample size? Is the methodology sound? What is the side effect profile? Is there any long-term data (like 1 year after using the drug)? These are answered for FDA-approved drugs, but not necessarily for non-approved ones, especially if you are not a healthcare professional that speak Russian (even then, they have teams of professionals looking at drug applications, are you sure you're not overlooking anything?).
The more barrier you place for drug approval, the safer it will be. It is a classical risk-versus-benefit trade-off. If there is an option that may be slightly more effective than current practice but has unknown (or perceived less certain) side effect profile, healthcare industry mindset prefers the status quo.
"First, do no harm." http://en.wikipedia.org/wiki/Primum_non_nocere
Consequently I take a bit of a more libertarian perspective on pharmaceuticals. You can't really trust the government or most doctors anyway. So people might as well be more free to find helpful chemicals.
If you think you can find helpful chemicals on your own, you are either very confident to use your own body as a guinea pig or suffering from http://en.wikipedia.org/wiki/Dunning%E2%80%93Kruger_effect .
There is no reliable government organization out there stopping harmful medical treatments. I just want to acknowledge that as fact rather than pretend otherwise and deny people choices.
You say this as if it were bad, but the net effect is to save lives (at a cost of money and increased diagnoses of diabetes). Statins are an example of the FDA and the industry actually doing the job they are supposed to do.
If you want to evaluate the safety of a prescription, I hope you have the right degree for that. Things can look safe on one paper and not safe on another. Or your condition may warrant a risk of greater side effect with the upside of better efficacy. It's true that doctors and FDA can make mistakes, but they are the best people you have.
Uh oh... Didn't know that your AMA is such a place. Do you have a association that represents all prescribers? Prescribing habits should be looked over by them.
The problem isn't (only) that US drug standards are strict. The problem is that the financial burden of testing a new drug, which is significant, lies solely on the manufacturer, who can only recoup those costs by selling patented drugs at high prices. This means that the incentives don't line up for drugs not covered by US patents: because there's no profit in selling them, no manufacturer can justify funding the clinical trials to get them approved. This despite the fact that society would, as a whole, benefit from having those studies done.
One obvious solution would be a government program whose mission is to identify promising treatments for which private incentives don't line up, and shepherd them through the approval process by funding clinical trials and so on. You could also imagine a free-market variant, in which the government just auctions off US patent rights for foreign drugs; the auction winner gets exclusive rights to sell the drug in the US for some limited period of time in exchange for agreeing to fund FDA approval.
You already have this. It's called Orphan Drugs in the US. http://en.wikipedia.org/wiki/Orphan_drug
> a free-market variant, in which the government just auctions off US patent rights for foreign drugs
This will probably work. But once the barrier is too low, a lot of "useless" drugs will show up (i.e. providing more choices to prescribers but in reality does not really give much benefit) - and you need to fund those too using the taxpayers' money.
Actually if the market is potentially quite large, big pharmas should already be researching it. The problematic ones are those that are in-between orphan drug and market-quite-large drug. The society probably needs less of these drugs (there should be alternatives at the other ends), but if it's still needed, maybe expanding the scope of the Orphan Drug Act can be a good solution.
Its hubris, American regulatory groups sticking their fingers in the affairs of other countries. And its beyond their charter to try to regulate what Americans do; they're supposed to regulate what American manufacturers do, not private citizens?
Every so often they get the front pages of nature for essentially finding anti-gravity: http://www.nature.com/news/2008/012345/full/news.2008.1185.h...
Or you find actually build computer architectures and languages which American theoretical computer scientists rediscovered 30 years later as the most efficient possible: https://en.wikipedia.org/wiki/Setun
If setun , the ternary computer was so efficient - how is ithat today we use binary machines(and that in general the russians didn't have a moore's law ) ?
One thing people in the West don't understand is that the Soviet Union after Stalin believed it was a second rate power and acted like one. In many ways the Politburo was a US cheerleader, they only challenged the US tactically while strategically accepting most of the propaganda more uncritically than US dissidents.
Not true. He said that "they seem to have pretty good evidential support", and that russian study was used only as an example. Also while comparison tu room temperature superconductivity might be a hyperbole, apparently drug having "both stimulant and anti-anxiety properties" that "millions of Russians have been using for decades and are by and large still alive" is something really big in the field of medicine.
* US pharma is developing a me-too / copycat drug that has very similar molecular structure
* US pharma has tried and it failed before public announcement (oh there are so many of them)
* US pharma negotiated contract and found that the Russians are non-negotiable :)
But if a company spends decades and billions of dollars fighting for the approval of a drug they do not hold the patent on, they are by no means guaranteed making even a single penny of that investment back, even in the best case scenario where it succeeds in getting through the FDA.s
(Trivially searchable, for example here: http://adage.com/article/special-report-pg-at-175/procter-ga...)
If the same thing happened to the tech industry, it would work like this... you create an awesome new gadget and a competitor creates a copy. The gov't certifies this copy as "exactly the same". When you go to purchase the fancy gadget at the store, the clerk automatically gives you the cheaper copy without even asking.
Again, not something marketing can help a whole lot with.
Most of those laws are on the books because gov't funded health insurance (Medicare, Medicaid) don't like to pay brand name prices when generics are available.
It seems like it might be useful (assuming it isn't already) to separate the rights concerning drug discovery and those demonstrating efficacy/safety to allow costs to be recovered.
Then again, it needs to be weighed against the inevitable rent-seeking that pharma has a name for.
[1] but don't have any evidence handy to back it up, so ICBW.
Um, no, it doesn't. What's the FDA going to do if they have additional questions or want additional studies done?
The FDA doesn't approve these drugs for the exact same reason the author doesn't prescribe them.
Lament the situation, sure, but pointing fingers at the FDA seems dumb.
The fda doesn't allow them because they are (argues the author) run by big pharma.
The author argues that "big pharma" doesn't seek the FDA approval because there's no way to recoup the expense.
To quote,
"Absent an extremely strong patent on the drug there’s no reason a drug company would want to go forward with all of this. I don’t know what the legalities of buying Russian drug rights from Russian companies are, but I expect they’re complicated and that pharmaceutical companies have made a reasoned decision not to bother."
Note the reasoned decision part. The author's actual point is summarized in the N-2th paragraph:
Everyone follows their own incentives perfectly, and as a result the system as a whole does something insane. Classic multipolar trap..
If I'm desperate for medicine and am willing to take a risk by taking a non government-tested drug, then shouldn't that be my right? Also, it's not even entirely clear whether on the whole, the FDA saves more lives than it harms. Sure, it's prevented many bad drugs from going to market, but the astronomical costs (both time/money/energy) associated with getting drugs approved by the FDA 1) slows down good pharma companies and 2) discourages many people from starting good pharma businesses at all.
A free market solution to this would be to have FDA and/or commercial enterprises vet the drugs with open, transparent standards, and the pharma companies can choose at will whether or not they want to be certified by these companies (and list whatever certifications they received on their products). The consumers can then choose at will whether they want to buy products with only these certification(s), or they can take a gamble and buy completely uncertified products.
Entrusting a government agency to retain totalitarian, opaque control over what drugs can make it to the market is just a bad idea.
Herbal infusions, Homeopity, and a host of other 'options' still, but if you call yourself a doctor and not just a 'faith healer' they effectively don't which is a good thing.
That would be handy. I did take an American anti-anxiety drug for a short while during a painful divorce, but I went from someone who gets hours of work done on the bus to work every day to someone who just stares out the window. Sure, I was happy and not worried and not desperate, but I wasn't getting half the amount of work done either.
But a medication that disrupts the anxious cycles of thought while at the same time stimulating the motivation/energy to complete tasks... well, that sounds almost like magic to me, especially if it doesn't involve the retrograde amnesia associated with benzos like alprazolam, lorazepam, etc.
If drugs are social goods then, in theory you put the well being of the masses above anything else.
If drugs are just goods to be marketed, then there's no need to bother. Either the financial aspect is lucrative (e.g. reasoned) or you can't have legal access to the drug.
ps. The fact that the US has the worst and most expensive health system in the world of course, says something about healthcare.
Admittedly it's for a different indication, but the Medivation experience with dimebon, which is a drug used in Russia as an antihistamine for decades, which had "pretty good evidential support" that the drug might work for Alzheimer's disease is, unfortunately, more likely to be par for the course.
Singapore has this provision because the market is too small for lots of drugs to come in.
Interesting how do doctors end up bearing "full responsibility"? It seems like something has to work differently in civil court or current culture most be different enough that the doctor is not run out of business after a few patients die after importing and taking responsibility for a drug.
Importing a drug under exemption is "serious business" and is usually only done by the most senior doctors (or by approval from a committee of senior doctors). They must exhaust all registered options first before moving to exemption drugs, and the pharmacists play a role in ensuring that (another incentive to do that is the paperwork can be rather significant).
Because you need a pharmacist to do this, it usually happens only in larger establishments like hospitals, where pharmacists are readily available and cooperative.
Most of the drugs mentioned in the article can be purchased by people in the US through the internet.
No Adderall, Xanax or Provigil for me either - the only things I can get right now are Tofranil from a friend (which is technically illegal) and racetams from eBay.
However, if I was suffering anxiety, or any other disorder, to the point where I wanted to take medication, I would see a doctor. I would not trust myself to diagnose myself, let alone prescribe a course of treatment.
Depending on severity, OP may be stupid in this desire. But it is one's right to make stupid decisions for themselves, and produces better long-term outcomes than binding people to the stupid decisions of others.
Does your distrust of yourself mean you abstain from caffeine (for alertness) and alcohol (for social disinhibition), etc?
And again, I was not asking anybody to justify anything. You read some "strong assumptions" into my question, Ms. Rand.
From experience, shrinks will prescribe whatever they want instead of what I ask for, since they know better and I'm a dumb foreigner who can't even explain things properly.
Are you dealing with EDS as a significant symptom in addition to anxiety? ADHD?
Very eye-opening article. I remember coming in contact with the Chinese pharmaceutical/medical system through a discussion with a our Chinese guide. After the discussion I was left with the impression that Chinese medicine is still in the dark ages and for some reason doesn't wanna join the 21st century. Then our "History of Pharmacy" teacher let me know that Chinese medicine is as good as ours although their approach is strange to us, works extremely well for them hence there even might be many things worth to copy there. I still remember how stunned I was.
So long as we administer drugs based only on their effect on symptoms but without understanding root causes, there will be all kinds of abuse and fads.
So is recovered memory therapy, with thousands of satisfied customers, each of which made a false outrageous claim about an imaginary sex crime, then went on to sue their parents, or boyfriends, or therapists -- and in some cases, all of them.
Your conception of science is below that required for astrology. No one knows what ADHD is or how to treat it. Therefore, there is no therapy for ADHD.
> verified in most of the hundreds of double blind studies ...
You mean the double blind studies you earlier claimed were unethical? There are no double-blind studies carried out with respect to ADHD, because there is no science taking place. And now that the NIMH has pulled the plug, such studies can no longer even be proposed for funding.
> you are refusing to acknowledge...
I did the research, and you are lying. Do your own research:
http://www.childmind.org/en/posts/articles/2013-4-9-most-com...
The linked article says the number one misdiagnosis among children is ... wait for it ... ADHD. The reason is that it's all based on symptoms, not causes, and this is part of the reason for the diagnosis rate and the many errors that are made.
In short, no science, no reliable diagnosis.
http://www.sciencedaily.com/releases/2010/08/100817103342.ht...
Quote: "Nearly one million children in U.S. potentially misdiagnosed with ADHD, study finds"
"Nearly one million children in the United States are potentially misdiagnosed with attention deficit hyperactivity disorder simply because they are the youngest -- and most immature -- in their kindergarten class, according to new research."
"ADHD is the most commonly diagnosed behavioral disorder for kids in the United States, with at least 4.5 million diagnoses among children under age 18, according to the Centers for Disease Control and Prevention. However, there are no neurological markers for ADHD (such as a blood test), and experts disagree on its prevalence, fueling intense public debate about whether ADHD is under-diagnosed or over-diagnosed ..."
You need to realize that the professional literature absolutely disagrees with your claims about ADHD, this has been brought to your attention, you have ignored the information readily available at your fingertips, which makes you a liar.
No there is ONE KIND OF SCIENCE, it is defined in the law, and it is why the DSM is being discarded. Science is not a matter of opinion as you seem to think, it is a matter of evidence and discipline.
> I'm giving up...
Your ignorance is astounding. There is ONE PROPERTY that all science must have, it is non-negotiable, and every freshman science student knows what it is. I asked this already, you ignored it out of embarrassment, NOW ANSWER THE QUESTION.
It can be expressed in a single word, science requires it, psychology doesn't possess it, what is it?
ANSWER THE QUESTION OR STOP POSTING.
How science is defined in the law (why Creationism cannot be taught in high school science classrooms):
http://arachnoid.com/building_science/index.html#Science_Def...
http://en.wikipedia.org/wiki/List_of_chemical_elements_namin...