Good morning.
My name is Terence Young. I'm the founding chair of Drug Safety Canada, a former Ontario MPP, and the author of the book, Death by Prescription, which will be published by Key Porter this coming September.
Drug Safety Canada promotes the safe use of prescription drugs. We accept no money from any corporations. As chair of Drug Safety Canada, I am party to the CanWest MediaWorks Inc. lawsuit in the Ontario Superior Court of Justice in support of Health Canada's continued ban on direct-to-consumer advertising of prescription drugs.
We focus on serious adverse drug reactions, those that are fatal, life threatening, disabling, incapacitating, or result in prolonged hospitalization, the ones that the pharmaceutical industry, which we call big pharma, want you to believe almost never happen. The term “big pharma” refers to the world's largest international drug companies as a group.
This morning I'll briefly summarize the results of six years of research begun after we lost our 15-year-old daughter Vanessa to the Johnson & Johnson prescription drug Prepulsid in March 2000.
We believe prescription drug safety will be enhanced with proposed mandatory adverse drug reaction reporting. A previous Minister of Health, Ujjal Dosanjh, went as far as announcing he would do it, and nothing followed.
About 1% of adverse drug reactions are currently reported, and yet the big pharma companies frequently publish the 1% on their drug labels as if that's all that occur. Big pharma tracks worldwide drug deaths centrally but generally does not report adverse drug deaths to Health Canada that occur in 192 other countries. They normally blame those deaths and serious reactions on overdose, contraindicated drugs, and conditions the patients might have, and change the fine print on the label that no one ever reads. They almost never admit their drug caused deaths, even after it has been pulled off the market, because the insurance they buy against drug crashes would therefore not pay.
First, we recommend that the new legislation empower and require Health Canada to demand all studies done on prescription drugs and all adverse drug reaction reports from the world market to be delivered immediately or within 48 hours, and not be held up, as they are now, from six months to a year.
We congratulate Minister Clement for introducing legislative change to implement this measure in hospitals, and we hope it will lead to a robust reporting system to which all health care professionals contribute. It will provide an early warning system for dangerous drugs and a living database from which to identify dangerous drugs and no doubt save lives.
Every decision to take a prescription drug should be based on an informed and objective appraisal of one thing: will the benefits outweigh the risk for this patient?
Here is the scope of our current problem. All drugs cause adverse reactions—not some, all—and many are deadly. The president and founder of Eli Lilly once said, “Any drug without toxic effects is not a drug at all.” “Rare” means between one out of one thousand and one out of ten thousand, so take no comfort with rare side effects. Three million Canadians are currently taking SSRI antidepressants, so between 300 and 3,000 will suffer any rare reaction.
To quote Dr. Andrew Weil, “The only difference between a drug and a poison is dosage.” So every drug has a potential to harm patients. For example, 16,000 to 17,000 people die every year in the U.S. alone from ordinary over-the-counter aspirin, ibuprofen, and naproxen.
Prescription drugs are the fourth leading cause of death in the U.S. and Canada, behind only cancer, heart disease, and strokes. Most of these deaths are covered up, which is why you will not find them recorded by StatsCanada. But three University of Toronto professors did a very comprehensive mega-study in 1998, in the United States, that showed 104,000 deaths in U.S. hospitals caused by prescription drugs administered as prescribed—not in error, but as prescribed. Many observers believe there could be as high as another 100,000 deaths caused by prescription drugs outside hospitals. That would be the equivalent of about 20,000 deaths a year in Canada.
One out of five new drugs in the U.S. is taken off the market for harming or killing patients or will have the highest level of warning placed on their label, and half of new drug withdrawals occur in the first two years.
One out of four adult hospital admissions to medical wards in Canadian hospitals is drug related, mostly adverse reactions, improper drug selection, or non-compliance.
So the human cost is staggering. What is the financial cost?
According to the Canadian Pharmacists Association, approximately $2 billion to $9 billion a year in Canada is wasted on inappropriately prescribed drugs. Inappropriate prescribed drugs injure hundreds of thousands of patients every year in Canada. Some estimates put the cost to our medical system at $10 billion a year.
Adverse drug reactions are really like an epidemic. How did it get to be that way? How high is our current standard for approving prescription drugs?
They have to be effective. What does that mean? Effective means slightly more effective than nothing. There is no regulatory requirement to show that any new drug is more effective than the current top-selling drug on the market for the same condition. All they have to do is prove that the drug works 1% better than nothing, which is a placebo. Even that is a major challenge for many of the drugs the big pharma companies have unloaded on trusting patients.
For example, in the U.S., it's shown that the drug Vytorin simply doesn't work. The drug companies that produce the two drugs that combine to make it covered that up for 18 months while they sold another $7 billion worth to unsuspecting American patients.
Dr. Allen Roses, the worldwide vice-president of GlaxoSmithKline, has said that the vast majority of drugs—more than 90%—only work in 30% or 50% of the people. He said that cancer drugs work 25% of the time, Alzheimer's drugs work 30% of the time, and many others only 50%. It's because of the powerful placebo effect that patients are often unable to determine when a drug is working. Millions of patients are put at risk of nasty or dangerous side-effects with no benefit, and billions are wasted.
Recommendation number two is, because governments are the largest customers for pharmaceuticals—about $8 billion a year—we believe new drugs should be tested for effectiveness against not just placebos but existing proven drugs. Governments should not pay for new drugs, which are always more expensive and offer new risks to patients, unless they are proven more effective for patients in the same condition.
Safe. What does safe mean? Safe does not mean safe as most patients think. Safe is relative to the drug and condition it is treating. Safe often means just less harmful than the current drug. If a new drug is approved, the one you are currently taking may no longer be safe.
Off-label prescribing. Three out of four doctors prescribe drugs off-label, a practice widely promoted by stealth in the industry. This means prescribing a drug for a condition for which it is has not ever been proven safe and effective. It is illegal for drug companies to promote it, but they do it in a myriad of ways anyway, using financial relationships and debts of gratitude to our doctors who do it for them.
A good example is Vioxx. It was originally approved around 2000 for arthritis and short-term pain. Merck promoted it off-label for many other kinds of pain and drove its use up to $2.4 billion before it was pulled off the market in 2004. Between 55,000 and 65,000 people died of heart attacks and strokes after taking Vioxx, about as many Americans as were killed in the Vietnam War.
Phase four of testing. We test drugs on the public without telling them. Phase four of testing is selling them on the open market. Any patient taking a new drug becomes a guinea pig in a giant drug trial. Doctors have no legal obligation to tell patients this, and most don't.
Our third recommendation is that doctors should be required to obtain truly informed consent for prescriptions and explain to patients that, by taking a new drug, they are in a trial, and that when they take a drug off-label the true risks are not known. This is currently done, by the way, for the acne drug Accutane.
Misleading communications. Patients are not informed of the risks they are taking. Big pharma risk communications are written by lawyers for lawyers in tiny print and cryptic euphemisms to encourage sales and confuse the reader. Drug labels, which patients never see and doctors rarely check, are up to 60 pages long, with safety information often on the last page, making sure few people ever read them.
Patient information leaflets handed out in drug stores are dangerous because they create a false sense of security, almost never mentioning serious adverse reactions. For example, the 29-page drug label for Viagra mentions side effects of vision loss, permanent damage to your penis, hearing loss, heart attack, stroke, and death on page 28. The truth is that hundreds of men have died within five hours after taking Viagra. Viagra, by the way, is also dangerous with grapefruit juice.
Recommendation number four is that patients should be getting independently written patient information leaflets—like the U.S. MedGuide—with each prescription that states up front, in plain language, all serious adverse reactions, all contraindications, the true safety record of the drug, and possible alternative therapies.
In 1997, Health Canada was directed to partner with big pharma, the pharmaceutical industry, but 41 drugs had been pulled off the market in Canada from 1963 to 2004 for safety reasons, often—like Prepulsid—for injuring and killing patients. In 1997 Health Canada's testing labs were closed in the budget to save $10 million. Let's look at what Health Canada has been doing since then. They did not even keep a list of drugs that had been withdrawn from the Canadian market or why. They did not routinely try to assign causality when evaluating adverse drug reaction reports; so they take the report and they don't try to find out what caused the patient's death. We could find only one occasion when Health Canada actually ordered a drug off the market, and that was Prepulsid, the drug that killed my daughter.
Post-market studies, which are promised in order to get drugs approved, are routinely left undone by big pharma. No one at Health Canada ever follows up.
Recommendation five is that new legislation should ensure that Health Canada officials collect important safety information and use it to order post-market studies and get dangerous drugs off the market. Health Canada will need the budget to hire and train more drug reviewers and safety officers to do that.
Big pharma view Health Canada as a client. By 2002, 82% of the therapeutic products directorate budget was being paid by international drug companies in exchange for faster drug approvals. This makes drug reviewers' jobs dependent on the industry.
No regulator should partner with those they police. The pharmaceutical companies are there to make money; Health Canada's mandate is to protect patients. We believe there should be no relation whatsoever between the jobs and investment in the pharmaceutical industry and what drugs we allow to be given to vulnerable patients. Health Canada should have no mandate to assist the pharmaceutical industry to make money, which is a clear conflict of interest for a regulator. Aircraft tire inspectors should not be worried about jobs at Michelin or Goodyear.
This ongoing problem could be resolved by establishing an arm's-length independent drug agency to handle all regulatory matters. This idea was germinated in 1964 by Justice Emmett Hall's Royal Commission on Health Services, expanded in 1992 in the Gagnon report, and recommended in 2002 by the Romanow commission.
Faster drug approvals can only be justified for 5% of new drugs.