A
Flaw in the System: The FDA
This is not going
to be a treatise on the Food and Drug Administration. I haven’t the facts
or the desire to write such a treatise. The FDA is in this book because
of its relation to PHT. The FDA was established, in the best tradition
of good government, to help American citizens in matters of health, in
ways they can’t help themselves. But it was conceived as a defensive unit.
If it were a football team it would have six tackles and five guards,
and no one to carry the ball. All that was expected of the FDA was defense—to
protect us from dangerous substances and unwarranted claims of effectiveness.
Understandably the
founding fathers of the FDA presumed that the drug companies, with their
profit incentives, would furnish the offense. It could hardly have entered
their minds that a drug company would leave a great medicine “lying around.”
Nor would they have been able to figure out how to equip the FDA against
such an eventuality unless the FDA were put into the drug business, which
is a far cry from the original premise—and is not being recommended here.
The FDA has done nothing
about PHT. That is to be expected when a drug company doesn’t play its
role. Unfortunately this does not leave the FDA in a neutral position.
Through no fault of the FDA’s, PHT’s narrow listing has a negative effect.
Absence of FDA approval is thought of by many as FDA disapproval—or at
the least that something is lacking. The system of drug company through
FDA to physician has become such a routine that the physician, with other
things on his mind, waits for the system to bring him PHT. It’s been a
long wait.
The real purpose in
establishing the FDA was to improve the health and well being of the citizens
of the United States. The neglect of a great drug certainly falls into
that category. If a man were drowning and a doctor was prepared to throw
him a life preserver that had more lead than cork, the FDA would say,
“Hold it! That thing might hit him and kill him, and even if it doesn’t
it can’t help him.” Nice work, FDA. But suppose the FDA knew there was
a good life preserver under a tree, which the doctor didn’t see. Shouldn’t
they say, “Try that one, Doc”? Of course they should.
It is not suggested
that the FDA go into the drug business. It is more than suggested, in
this extraordinary case, where thousands of physicians have furnished
us with many times the evidence required to get approval of a new drug
(keep in mind this drug has been approved for comparative safety and has
stood the test of over forty years of use), that the FDA should no longer
take a hands-off policy. It’s a sure thing our public shouldn’t suffer
any longer because Parke-Davis stayed in bed after Rip Van Winkle got
up.
Let us understand
the magnitude of what we’re talking about. The non-use of PHT has been
a catastrophe. We are not accustomed to thinking of the non-use of a medicine
as a catastrophe. We think of a catastrophe as a flood, a famine, or an
earthquake. Something tangible, overt, something in the positive tense.
But something passive, such as the non-use of a great medicine that can
prevent suffering and prolong lives, is also a catastrophe.
Something must be
done. How it is done is for the government to decide. But here is a suggestion.
It would seem a waste of time, and thus to the disadvantage of the American
public, for the FDA to attempt to approve the many clinical uses of PHT
separately. That could take forever. It would be far simpler for the FDA
to address itself to the basic mechanisms of action and give PHT a listed
indication-of-use as a stabilizer of bioelectrical activity, or as a membrane
stabilizer. Certainly the published evidence for this is overwhelming.
Such a listing would stimulate the physician to think of clinical applications
of PHT and to refer to the existing medical literature.
Even a nod from the
FDA to the physician would help. It could take the form of a letter to
the physician, calling attention to the literature of his colleagues,
and reminding him that since PHT has been approved for safety he is permitted
to use it for whatever purposes his judgment suggests. Certainly the FDA
would never try to tell the doctor how he should use PHT. That’s always
the doctor’s decision. But such a letter would lift the cloud of negativism,
and the physician would get an unobstructed view of PHT and the work of
his colleagues.
I’m sure the problem–agriculturists
will say that if the FDA takes any action in this matter it will set a
precedent. Fine. Good. If this happens again, if another established drug
is found useful for fifty or more disorders by thousands of physicians,
then the FDA should take this as a precedent.
Every once in a while,
routine or no routine, a little common sense should be permitted. This
is an extraordinary matter, vital to our health. If the FDA was set up
to help the American public, here’s a chance to do something great for
them—with no one’s feelings hurt except routine’s.
Next
Section: Evidence
Advisory
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