In September last year Merck & Co. pulled its popular and effective arthritis pain
medication, Vioxx, from the market because researchers investigating the possible
efficacy of heightened doses of Vioxx in the treatment of problems other than arthritis
discovered that, at those heightened doses, the drug increased the probability of
cardiovascular harms (heart attacks and strokes). In December one group of researchers
investigating another popular and effective arthritis pain medication, Pfizer's Celebrex,
again in heightened doses, and again for uses other than arthritis pain relief, also
discovered a (very small) increased probability of cardiovascular harms. Another group
of investigators doing the same research on Celebrex found no such heightened risk.
Pfizer did not pull Celebrex from the market, but it did suspend all advertising of the drug
Both Vioxx and Celebrex are COX-2 inhibitors, pain relievers that carry a
significantly lower risk of causing gastro-intestinal bleeding than other arthritis pain
medications such as Tylenol and aspirin. Arthritis sufferers who are very susceptible to
gastro-intestinal bleeding have no place to turn for arthritis pain relief except to COX-2
This has set off a maelstrom of negative commentary among journalists about
COX-2 inhibitors, with the more dimwitted among them calling on the federal Food and
Drug Administration (FDA) to ban all drugs in that class. Others worry that the FDA
drug approval process is "broken" and conclude that it must be changed to make it much
more difficult for drugs that later turn out to have harmful effects to be approved in the
first place. The FDA (also known as the Federal Delay Administration) has scheduled
hearings for February 16 -18 to consider the safety of all COX-2 inhibitors. Given the
personal incentives to which FDA regulators respond, they well might decide to ban the
drugs. That would be a disaster for many arthritis suffers.
FDA regulators can make two types of errors in making decisions about whether
to approve a drug for the American market. Statisticians call them Type I and Type II
errors, and they apply to most decisions people make. They are false positives and false
negatives. FDA regulators can approve a drug that turns out to be harmful (a false
positive) and can refuse to approve a drug that actually would be beneficial (a false
negative). FDA regulators are more afraid of the false positive than the false negative
error. Why? Because if they approve a drug that later turns out to be harmful, the harms
become visible; photographers and journalists can chronicle the harms to identifiable
victims and trace the harms back to the specific regulators that committed the error.
Regulators are personally at risk of public ridicule or worse. If regulators decide to
disapprove a drug that would have been beneficial, some people will be harmed, but
photographers and journalists cannot chronicle the harm. One cannot take a picture of
what doesn't happen. Who will ever know of the people who are not benefited because of
a blunder by FDA regulators? In such cases regulators are likely to be applauded as
Letting a person take a bad drug can kill. Prohibiting a person from taking a good
drug can also kill. When FDA regulators decrease the probability of committing a Type I
error (approving a good drug) by making it more difficult to approve any drug, they
thereby increase the probability of committing a Type II error (blocking a good drug).
FDA regulators should balance one type of error against another, but their personal
incentive is to prefer Type II over Type I.
There is risk attached to taking any medication. Some risks are known and some
aren't. It is our lot in life to make decisions under uncertainty. Adults of normal mental
capacity should be allowed to make such decisions for themselves. In the case of
prescription medications physicians should be free to make decisions about whether to
prescribe a drug, and patients should be free to decide whether to take it. Prudent
decisionmakers seek appropriate knowledge before making decisions, but there is no such
thing as perfect knowledge. We are not obviously better off by letting distant third
parties, biased in favor of a particular type of error, make such decisions for us.
Alas, the COX-2 inhibitor scare is likely induce the FDA do more harm than it
otherwise would. FDA regulators will likely ignore the fact that the newly discovered
harms associated with Vioxx and Celebrex resulted from doses far above those safely
used for effective arthritis pain relief. When the game is CYA, the regulators don't give a
damn about victims of Type II errors.
EURODREAM S.r.l. – Salute e Ambiente SERVIZI E SISTEMI, INFORMAZIONE E PREVENZIONE- OLTRE IL PROZAC STILI DI VITA TOSSICI PER IL CERVELLO, ANTIDOTI NATURALI & ANTIDEPRESSIVI DELL'ULTIMA GENERAZIONE "Un esame profondo e stimolante dei trattamenti alternativi e aggiuntivi per la depressione" (Norman E. Rosenthal, M.D. - Istituto Nazionale per la Salute Mentale, autore