Latest Drugwonks' Blog

Gottliebenstraum

  • 03.13.2006

Remember the character-assasination job that Alicia Munday did awhile back in the Seattle Times? Well here’s what one of their own editorial writers had to say about it. And all I can add is “well done!”

Our Man at the F.D.A.

The Times’ page one story on Scott Gottlieb, the Wall Street analyst hired by the Food and Drug Administration is an editorializing story — a story with a message. We can tell the story straight — and our reporter, Alicia Mundy, tells it pretty straight, but the premise of it, the definition of it as a story, carries a message of the fox guarding the henhouse or “regulatory capture,” meaning an industry influencing its regulator.

Our reporter has put in a resume of Mr. Gottlieb, and so we can have a rough measure of his attachments to Wall Street. He ran a Forbes investment newsletter for about half a year, also participating as a policy guy at the American Enterprise Institute, a right-of-center policy shop. He has previously worked for the FDA in medical policy under the Bush administration. He has worked for George Gilder, who writes about investments and policy from a pro-technology view. He has been a medical internist at a hospital. In the Clinton years he wrote for the Journal of the American Medical Association and worked in the investment firm Alex. Brown. His degree is in economics.

My question is: For a policy job, would it have been preferable to hire a person who had been in the bureaucracy for an entire career? Certainly there are people like that, and probably lots at the FDA. Probably the lifetime regulators are more pro-regulation than Mr. Gottlieb will be. The unspoken assumption of this story is that that’s what the public should want.

It’s not what I want. I want innovation, I want information, and I want choice. I want new drugs to be tested and reviewed, but I don’t want the system to be so safety-conscious that I can’t get the drugs I need. The fact is, people are suffering and dying now. New medicines may be able to help them. If you insist on a drug-approval system of near-zero risk, you delay the new medicines and more people suffer and die. You can die from taking a drug that should have been studied longer and you can die from not getting a drug that should have been approved earlier.

There is also the question of whether people who are sick should be allowed to make these choices themselves. If you have cancer, and it’s going to take five years to review a new drug to a zero-risk standard, maybe you don’t want to wait five years. Maybe you want the drug now. I think the system should allow that — and (judging from one newspaper article) Mr. Gottlieb is more likely to consider that point of view than someone who has been a regulator all his adult life.

Bruce Ramsey, Editorial Writer, The Seattle Times

I’ll be speaking in Brussels on how Europe can begin to embrace and then help to educate the empowered 21st century health care consumer. Here’s more information …

The Amigo Society invites you to discuss:
“Consumers and Health Information: Is knowledge really power?”

Featuring:

Peter J. Pitts
Former Associate Commissioner
Food and Drug Administration (USA)

Commentators:

James Copping,
European Commission
(High Level Pharmaceutical Forum)

Colin Webb
Vice-President, European Patients’ Forum

A recent consumer survey in Europe asked people in eight old and new EU member countries what reforms would most likely increase their quality of care. In every nation, by a large margin, “giving patients more information about their illness” was the preferred solution.

Health care education is the consumer’s Rosetta Stone. Public policy institutes, pharmaceutical companies, health care professionals and patient advocates, along with government must be allied in the drive to deliver information to patients, for it is, ultimately, about saving lives and saving our health care systems. Moreover, increasing information to patients will improve disease awareness and aid in defeating patient non-compliance estimated to cost billions of euros a year in increased emergency room visits, unnecessary surgeries, expensive hospital stays, and lost productivity.

To debate and discuss the value of these arguments, please join us on:
Tuesday 21 March 2006
7-8:30 pm (cocktails to follow)
Hotel Amigo, Rue de l’Amigo 1-3, Brussels
To RSVP visit
http://www.stockholm-network.org/conferences/events/signup.php

Bob Goldberg asks a tough question …

Is it suprising that the return of the MS drug Tysabri was scarcely covered by the mainstream media or that Senator Charles Grassley — who just a week ago was red-faced about the dangers of ADHD drugs — did not hail the fact that a drug demonstrably effective for so many patients was once again available? Media coverage of the withdrawal of Tysabri outweighed the coverage of it’s return by 6-1… and while the articles about the horrors of the drug ran on and on and were on the front page of major papers, those about the FDA advisory panel recommending that it be brought back to market were under a paragraph and tucked into the back of the business section. The New York Times and the Boston Globe were notable and laudatory exceptions to this trend. Shame on the Wall Street Journal for sensationalizing the withdrawal and then consigning its return to a few sentences a year later. “Hate the drug companies” bias persists.

This bias harms patient health and amounts to fear mongering on the part of the media. When editors decide that the return of life enhancing drug is less important than it’s removal from the market — that a public has less of a right to know about the former than the latter — then the legitimacy of the media as an arbiter of what is in the public interest should be openly and vociferously debated. And so should the judgement of the politicians that see the media as their platform.

On February 23, Bob Goldberg blogged on the half-truths Liberally sprinkled throughout a report issued by the Democrat minority staff of the House Government Reform Committee. Dr. Goldberg’s argument was based 100% on fact. The report by the minority staff was based on politics, sound bites, and fuzzy math. As my grandmother used to say, a half truth is a whole lie.

Now it seems that Democrats in Congress are taking the same half-truth strategy, customizing its fallacies to fit local constituencies and taking it on the road. Consider the case of Northern California.

Here’s how the San Francisco Chronicle reported it …

Bay Area Democrats in Congress released a survey earlier this week concluding that prices for 10 top-selling drugs purchased through Medicare were higher than those paid by Canadian consumers or Costco customers … For its part, the study by Bay Area Democrats found the average costs of 10 common brand-name drugs offered by 10 plans in the Bay Area were 75 percent higher than prices negotiated by the federal government for agencies such as the Veterans’ Administration, 60 percent higher than prices in Canada, nearly 5 percent higher than prices available online through Drugstore.com and almost 2 percent higher than those at warehouse club retailer Costco.

Yep — it’s the exact same story that ran in the national press in late February. How soon the media forgets. And I fear it is selective memory loss.

So let me repeat what Bob said only a few short weeks ago — the Bay Area Dems deliberately omitted drug plans that allow patients to pay a fixed low price for all the drugs they survey. There are many drug plans that allow consumers to pay $30 for a month’s supply of each drug (or $25 a month if purchased through mail order). All these prices are substantially lower than any of the average prices cited by the Democrat staff. Not decimal dust.

Maybe we should call these representatives the new Bay City Rollers.

FYI — I did not write this, I am only sharing.

Wonder Drug Inspires Deep, Unwavering Love of Pharmaceutical Companies

THE ONION
March 6, 2006


NEW YORK — The Food and Drug Administration today approved the sale of the drug PharmAmorin, a prescription tablet developed by Pfizer to treat chronic distrust of large prescription-drug manufacturers.

Pfizer executives characterized the FDA’s approval as a “godsend” for sufferers of independent-thinking-related mental-health disorders.

PharmAmorin, now relieving distrust of large pharmaceutical conglomerates in pharmacies nationwide.

“Many individuals today lack the deep, abiding affection for drug makers that is found in healthy people, such as myself,” Pfizer CEO Hank McKinnell said. “These tragic disorders are reaching epidemic levels, and as a company dedicated to promoting the health, well-being, and long life of our company’s public image, it was imperative that we did something to combat them.”

Although many psychotropic drugs impart a generalized feeling of well-being, PharmAmorin is the first to induce and focus intense feelings of affection externally, toward for-profit drug makers. Pfizer representatives say that, if taken regularly, PharmAmorin can increase affection for and trust in its developers by as much as 96.5 percent.

“Out of a test group of 180, 172 study participants reported a dramatic rise in their passion for pharmaceutical companies,” said Pfizer director of clinical research Suzanne Frost. “And 167 asked their doctors about a variety of prescription medications they had seen on TV.”

Frost said a small percentage of test subjects showed an interest in becoming lobbyists for one of the top five pharmaceutical companies, and several browsed eBay for drug-company apparel.

PharmAmorin, available in 100, 200, and 400-mg tablets, is classified as a critical-thinking inhibitor, a family of drugs that holds great promise for the estimated 20 million Americans who suffer from Free-Thinking Disorder.

Pfizer will also promote PharmAmorin in an aggressive, $34.6 million print and televised ad campaign.

One TV ad, set to debut during next Sunday’s 60 Minutes telecast, shows a woman relaxing in her living room and reading a newspaper headlined “Newest Drug Company Scandal Undermines Public Trust.” The camera zooms into the tangled neural matter of her brain, revealing a sticky black substance and a purplish gas.

The narrator says, “She may show no symptoms, but in her brain, irrational fear and dislike of global pharmaceutical manufacturers is overwhelming her very peace of mind.”

After a brief summary of PharmAmorin’s benefits, the commercial concludes with the woman flying a kite across a sunny green meadow, the Pfizer headquarters gleaming in the background.

PharmAmorin is the first drug of its kind, but Pfizer will soon face competition from rival pharmaceutical giant Bristol-Myers Squibb. The company is developing its own pro-pharmaceutical-company medication, Brismysquibicin, which will induce warm feelings not just for drug corporations in general, but solely for Bristol-Myers Squibb.

“A PharmAmorin user could find himself gravitating toward the products of a GlaxoSmithKline or Eli Lilly,” BMS spokesman Andrew Fike said. “This could seriously impede the patient’s prescription-drug-market acceptance, or worse, Pfizer’s profits in the long run.”

“Brismysquibicin will be cheaper to produce and therefore far more affordable to those on fixed incomes,” Fike added.

The news of an affordable skepticism-inhibitor was welcomed by New York physician Christine Blake-Mann, who runs a free clinic in Spanish Harlem.

“A lot of my patients are very leery of the medical establishment,” Blake-Mann said. “This will help them feel better about it, and save money at the same time.”

PharmAmorin’s side effects include nausea, upset stomach, and ignoring the side effects of prescription drug medication.

IMPACT's Impact

  • 03.09.2006

Europe is today where FDA was two years ago. But we’re standing still while the WHO is moving forward. It’s time for some trans-Atlantic harmonization.

CONCLUSIONS AND RECOMMENDATIONS OF THE
WHO INTERNATIONAL CONFERENCE ON COMBATING COUNTERFEIT MEDICINES
DECLARATION OF ROME
18 FEB 2006

The participants of the WHO International Conference
‘Combating Counterfeit Drugs: Building Effective International Collaboration’,
gathered in Rome on 18 February 2006

DECLARE

1. Counterfeiting medicines, including the entire range of activities from manufacturing to providing them to patients, is a vile and serious criminal offence that puts human lives at risk and undermines the credibility of health systems.

2. Because of its direct impact on health, counterfeiting medicines should be combated and punished accordingly.

3. Combating counterfeit medicines requires the coordinated effort of all the different public and private stakeholders that are affected and are competent for addressing the different aspects of the problem.

4. Counterfeiting medicines is widespread and has escalated to such an extent that effective coordination and cooperation at the international level are necessary for regional and national strategies to be more effective.

5. National, regional and international strategies aimed at combating counterfeit medicines should be based on:

a) Political will, adequate legal framework, and implementation commensurate to the impact of this type of counterfeiting on public health and providing the necessary tools for a coordinated and effective law enforcement,
b) Inter-sectoral coordination based on written procedures, clearly defined roles, adequate resources, and effective administrative and operational tools,
c) Creating an awareness about the severity of the problem among all stakeholders and providing information to all levels of the health system and the public,
d) Development of technical competence and skills in all required areas,
e) Appropriate mechanisms for ensuring vigilance and input from healthcare professionals and the public.

6. The WHO should lead the establishment of an International Medical Products Anti-Counterfeiting Taskforce (IMPACT) of governmental, non-governmental and international institutions aimed at:

a) Raising awareness among international organizations and other stakeholders at the international level in order to improve cooperation in combating counterfeit medicines, taking into account its global dimensions
b) Raising awareness among national authorities and decision-makers and calling for effective legislative measures in order to combat counterfeit medicines
c) Establishing effective exchange of information and providing assistance on specific issues that concern combating counterfeit medicines
d) Developing technical and administrative tools to support the establishment or strengthening of international, regional and national strategies
e) Encouraging coordination among different anti-counterfeiting initiatives.

The IMPACT shall function on the basis of existing structures/institutions and will in the long term explore further mechanisms, including an international convention, for strengthening international action against counterfeit medicines.

Sing it with me

  • 03.09.2006

OOOOOOOOOOOklahoma, where the drugs comes sweepin’ in from Spain.
And Latvia and Crete, can be discete
While the parallel traders all will gain.

OKLAHOMA CITY — The Oklahoma Senate on Monday passed a bill that would allow state pharmacists and wholesale drug distributors to reimport prescription drugs from Canada, Switzerland and European Union member states.


The bill also would require the Oklahoma State Board of Pharmacy to certify foreign suppliers in those countries to distribute prescription drugs within the state, provided they meet certain conditions such as allowing inspections of their facilities and reviews of their safety protocols by the board.


The bill would become effective July 1. Under the measure, the state Department of Health would establish and maintain a prescription drug Web site by Jan. 1, 2007, to allow residents to buy prescription drugs online.


A similar bill has passed out of an Oklahoma House of Representatives committee and will proceed to the floor for a vote.

Andy's Enemy

  • 03.09.2006

Dr. Bob Goldberg on Dr. Andy Von Eschenbach …

Andy Von Eschenbach has only one enemy: disease. He has beaten in personally and as physician and administrator proven to be a powerful and compassionate advocate for faster cures and better science at NCI and now at the FDA. Holding up his nomination as the next commissioner is like holding up progress against illness. Holding him and his appointment hostage to politics will only delay the necessary changes the FDA is seeking that will make drug evaluation as scientific and as cutting edge as the science shaping drug discovery. Just as a drug should not be held up for political purposes, nor should the nomination of a critical public health position be delayed because of election year posturing from either side of the aisle.

Will President Bush nominate Andy Von Eschenbach to be the next commissioner of the FDA? It would be a smart choice. Now’s the time to put aside partisanship and get this done with all due speed. A confirmed Commissioner must be everyone’s Plan A.


As a former member of the FDA’s Counterfeit Drugs Taskforce I am pleased to report that the agency continues to tell it like it is. And it’s serious — despite what some members of Congress may think.

Speech before
Parenteral Drug Association’s Pharmaceutical Counterfeiting Conference

Remarks by
Scott Gottlieb, MD
Deputy Commissioner for Medical and Scientific Affairs

March 3, 2006

I want to thank you all for coming today to share your ideas and views on how we can do as effective a job as possible of keeping the American drug supply safe and secure. The United States has a very safe prescription drug supply, and FDA is working hard to keep it that way.

This is not something that we can take for granted. If you look around the world, in many countries a quarter or even a half or more of the prescription drugs that people take are not legitimate products. They may not work as intended, and that’s a real public health concern.

Studies by the World Health Organization estimates counterfeit drugs to be a $32 billion-a-year business. Counterfeit drugs have found their way into developed and developing countries alike.

In developed countries, counterfeiters target brand name drugs that are used in high volume and are high priced. In developing countries, the counterfeiters also target generic drugs that are used in high volume for widespread diseases that plague the public health in those countries.

It has been estimated in the press that 8 to 10 percent of the global medicine supply chain is counterfeit — a figure that rises to 25 percent or higher in some countries. Quantifying the problem is difficult because the counterfeiters do such a good job copying the genuine product and hiding their tracks, that it is hard to identify what is real and what is fake.

Here in The U.S., counterfeiting of drugs is much less common. Part of that stems from our closed drug supply system, which makes our borders less porous to the counterfeit medicines.

Our high confidence that we and the American public have about the integrity of the distribution system for U.S. drug products also stems from an intricate web of federal and state laws that protect our drug supply.

But despite our confidence, FDA has been concerned that the drug supply is under increasing threat of attack from more sophisticated and well financed counterfeiters. We know that there have been increased efforts to introduce counterfeit drugs into the U.S. market.

The Agency has also witnessed an increase in counterfeiting activities and a greater capacity to introduce finished dosage form counterfeits into legitimate drug distribution channels. Illicit wholesale drug diverters and others in the supply chain provide the window through which most counterfeit drugs have historically entered legitimate distribution channels.

To deal with these concerns, we have been engaged in an increasing number of anti-counterfeiting activities here in the U.S. and at FDA. The number of newly initiated counterfeit drug cases has risen sharply from just a few years ago, although still preliminary data from fiscal year 2005 suggest a decline relative to the peak reported for fiscal year 2004.

In fiscal year 2004, for example, FDA’s Office of Criminal Investigations initiated 58 counterfeit drug cases, a significant increase from the 30 cases initiated in fiscal year 2003 and up sharply from an average of less than 10 in the four years before 2001. Even more worrisome, we are seeing an increase in the sophistication, the cleverness, and the technical capabilities of counterfeiters that are trying to get drugs into the U.S. distribution system.

Let me stress that these are estimates of the number of newly initiated counterfeit drug cases being investigated. And since these are ongoing cases, we have no estimate of the volume of counterfeit drugs involved in each case — it could vary from dozens to thousands.

The increasing number of cases we’re involved in is a poor proxy to suggest that more counterfeit drugs are actually making it into the U.S. market. We believe that the unusually high number of cases in 2004 is in part due to an increased awareness and vigilance at all levels of the drug distribution chain. Moreover, we believe that one factor contributing to this increased awareness and vigilance is the Counterfeit Drug Report that FDA issued in February 2004. A second is increased referrals from, and coordination with other state and federal law-enforcement agencies, such as the DEA and the FBI, and communications with drug manufacturers.

And fortunately, most of the counterfeit drugs at issue did not reach consumers because we focused our resources and developed proactive investigations. We believe that this strategy enabled us to identify components of counterfeit products and interdict finished counterfeit drug products before they entered retail distribution.

But make no mistake — the prevalence of drug counterfeiters around the world presents a real public health threat, and the rising number of cases weç©©e getting involved in should be taken as an unmistakable sign of our resolve in the face of that threat. As we have seen from the counterfeit cases that we’ve already encountered and in many cases that we’ve solved and where we have put people in jail, counterfeit drug products may contain only inactive ingredients, they may contain incorrect ingredients, improper dosages, sub-potent or super-potent ingredients, or they may be contaminated.

The result is risks to patients’ health — either risk to their safety directly if the products are dangerous, or risks from people suffering from complications from the many diseases that prescription drugs can treat today. So this is a serious concern at FDA and it is a serious public health threat.

At FDA, we recently re-convened the Counterfeit Drug Task Force. This internal task force originally assembled to explore the use of modern technologies and other measures such as stronger enforcement to make it more difficult for counterfeit drugs to get distributed with — or deliberately substituted for — safe and effective drugs.

More than three years ago, when we first convened this task force, it culminated in a report that laid out a number of goals for making the drug supply more secure.

One of our proposed remedies was to strengthen our system for tracking drugs from the assembly line to the dispenser, by replacing the paperwork that now certifies who has had the drug at all times with an electronic track and trace system that cannot be easily forged or forgotten.

Electronic track and trace technology can include tiny chips that go on the individual drug packages, also known as radio-frequency identification (RFID), or it can include certain types of barcodes. New technology would allow for less costly compliance, and better controls.

We gave manufacturers time to deploy this kind of technology, and put a stay on a rule that would effectively require some kinds of tracking measures in order to give people opportunities to move from paper pedigrees which would not provide the same kinds of protections to electronic pedigrees, which would.

I was at FDA, working as a senior advisor to then Commissioner Mark McClellan, when that first report was issued, and I think it is fair to say that since that first report was released, the progress that has been made toward the implementation of an electronic pedigree has been disappointing. It has certainly been far slower than many envisioned when we set out on this original course.

I know there are many complicated reasons for this. For one thing, there is still no agreement about who would pay for what parts of the new RFID system, and who would own the data and provide it to other parties under what circumstances. And practical realities, including the diversity and sheer number of establishments involved in handling drugs as they move through the supply chain, as well as the cost of deploying new systems for electronically tracking medicines, have all remained factors.

But I think time is short to get such a system in place. The original pedigree rule is written broadly enough so that electronic track and trace could be used in place of paper pedigree. We plan to make a decision soon on this stay, which is in place until December 2006, and we could reach a decision well before that.

The bottom line is this: To continue to ensure the safety of the U.S. drug supply in the face of the mounting threats I talked about here today and the increasingly sophisticated criminals, we must pursue these new measures. This must be a public health priority for all of us.

To these ends, FDA held a two day workshop and vendor display in February 2006 solely dedicated to the use of radio-frequency identification (RFID) to combat counterfeit drugs. More than 400 registrants were in attendance to hear both Acting Commissioner Dr. von Eschenbach and Assistant Secretary for Health, Dr. Agwunobi discuss RFID as a way of fighting counterfeit drugs.

There were three main goals of this meeting:

The first was to identify incentives and obstacles for widespread adoption of RFID throughout the U.S. drug supply chain, as well as to discuss ways of overcoming any impediments to the adoption of these tools.

The second was to solicit comment on the implementation of the pedigree requirements of the Prescription Drug Marketing Act. The current provisions of that law were written largely with a paper pedigree, but I think we’d all agree, we need to be moving toward the adoption of a fully electronic, e-pedigree.

And the third was to learn about the state of technology development related to electronic “track and trace” and e-pedigree technology solutions.

During the public meeting we heard that vendors, wholesalers, and some manufacturers agree that the RFID pilot projects conducted to date showed that providing real-time electronic pedigrees is already feasible in a production environment with single wholesalers. But no pilot projects were presented that provided a pedigree for a drug product sold by one wholesaler to another before being sold to a retail pharmacy.

As our colleagues at other agencies who are also experts on counterfeiting technology have told us, there is no single magic bullet. Instead, we need layers of technology, much like paper money has many different technologies embedded in it to thwart counterfeiting.

Our money supply, just the paper money, has more than 20 embedded technologies, both overt and covert and some that are only known to the Treasury Department. We need multiple layers like that to build more safety and security in prescription drugs as well, and we’re going to be working to bring forward proven technologies, and to develop the proof for these other technologies. RFID is the most promising, and most advanced of these technologies, but we still need to continue to pursue other remedies.

To these ends, we also heard some vendors describe hybrid technologies, such as two-dimensional bar codes combined with RFID that might provide both identification and electronic pedigrees even without RFID being universally adopted.

We have also seen new applications of bar code labeling, new approaches to doing track and trace technology so that we can reliably — in ways that cannot easily be fraudulently faked — identify whether a product really is a legitimate one, whether it comes from a legitimate source and has not been tampered with along the supply chain.

We’ve seen new technologies for packaging, new color-based technologies that embed multiple different layers of protection. We’ve seen new anti-tampering technologies for drug packaging. Even the tops of injectable drugs that can help keep the product secure. And we’ve seen new technologies that can be used on the drugs themselves, from new color technologies to embedded bar codes embedded — not just unit-dose packaging but actually on the drug. And we have seen other “taggant” and chemical technologies that are not harmful for patients but that can make it very easy to determine whether a product is safe or not.

As a result of the information garnered from this workshop, as well as the information we gathered from comments placed in the workshop’s public docket, at FDA we’re in the process of preparing a summary report and we expect to have that publicly available in May 2006.

That report will address whether or not we issue another stay on implementation of the pedigree rule. But as I said, we have already waited a long time for this technology to come along, since the stay was issued at the time of our first task force report on drug counterfeiting. We believe that we can take steps, working with technology developers and all of those involved in the supply chain, to accelerate the development, the feasibility testing and the adoption of many of these technologies that are in development today. And as we are trying to do in other areas of FDA activities where there are new technologies that can be valuable, we want to bring them to benefit patients as soon as possible.

While some of these technologies do seem just a short time away from widespread application, others have not been fully developed yet and demonstrated to be feasible. We will continue to work with the private sector to foster advances in this field. Not only do many of these technologies need to go through some further developmental steps, counterfeiters are very sophisticated today, so this is a moving game.

Finally, it’s clear that despite the promise that these security technologies offer, electronic track and trace, including RFID, alone is not the solution to combating counterfeit drugs. A multi-layer approach, using other technologies to secure the product and packaging, increased vigilance and awareness, increased penalties and State efforts, just to name a few, are also important in this effort.

We constantly need to be finding ways to update our technologies. We constantly need to be thinking about whether we’ve got enough layers in place. We need to think simultaneously about a coordinated approach that involves tracking and tracing and product packaging and product-embedded technologies and others. In short, we need multiple layers to keep our drug supply safe.

One of the things that are evidenced to us in this work is that all of the participants in our drug distribution system, from manufacturers to wholesalers and distributors, to pharmacies, to patients, have a responsibility to help us prevent and detect the introduction of counterfeit drugs into our drug supply. In particular, the businesses that are involved in the pharmaceutical manufacturing and distribution industry can help by adopting and adhering to secure business practices.

We think from what we’ve seen so far that some of the business practices in existence today can be improved as a means of deterring and detecting counterfeit drugs.

We’ve heard from and we’ve gotten a lot of feedback out to wholesaler organizations, for example, that are moving forward with developing more secure business practice models as a standard for their industry. And we’re looking forward to working with all of the other stakeholders in the prescription drug distribution system to make sure that we have identified and are doing all we can to encourage the adoption of secure business practices to minimize vulnerabilities to counterfeit drugs.

It is also important that we rapidly receive and are able to disseminate information on counterfeit drug introductions when they do occur. As I said, the number of cases of counterfeiting is on the increase, and an important part of an effective anti-counterfeiting strategy is to be able to identify and limit the damage from counterfeit drug introductions when they do occur.

Our task force has recognized the need to strengthen the systems that are used for reporting suspected counterfeits and for alerting stakeholders and the public when these counterfeit drugs do enter the drug supply. We have partnered with health professional, trade, and consumer organizations to create FDA’s Counterfeit Alert Network. These partners agree to disseminate important information about confirmed counterfeit incidences in a timely manner and to disseminate educational messages about counterfeit drugs.

It is also essential for consumers, pharmacists, and other health care professionals to know how to identify counterfeit drugs and what to do when they believe that they’ve encountered a counterfeit drug. This includes recognizing knowing the warning signs for identifying suspect counterfeit drugs. We are working on tips for pharmacists and other health professionals on how to identify counterfeits, how to counsel patients who suspect that they have a counterfeit drug, and where to report if a counterfeit drug is suspected. FDA’s MedWatch system is the mechanism that should be used these reports.

Finally, counterfeit drugs are a global problem. We’re seeing an increasing number of cases that involve not just a few people manufacturing a fake product in their garage, but well-organized international criminal operations that are trying to make use of the latest technologies for making a product that looks like the real thing but isn’t. We work with international law enforcement, health and regulatory authorities, as well as private stakeholders internationally to help us address this problem effectively.

To those of you who are working on ways to combat the growing traffic in counterfeit drugs, at FDA we want to thank you for your contribution to dealing with this significant emerging public health threat. We’re confident that working together we can stay ahead of those who are out to make a fast buck at the expense of the health of Americans.

And we are sure that we will be able to work together to keep our drug supply safe and secure and the safest in the world if we do remain vigilant through steps like this.

Thank you all for your contributions.

CMPI

Center for Medicine in the Public Interest is a nonprofit, non-partisan organization promoting innovative solutions that advance medical progress, reduce health disparities, extend life and make health care more affordable, preventive and patient-centered. CMPI also provides the public, policymakers and the media a reliable source of independent scientific analysis on issues ranging from personalized medicine, food and drug safety, health care reform and comparative effectiveness.

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