Showing posts with label Complaints. Show all posts
Showing posts with label Complaints. Show all posts

Thursday, 4 February 2010

International Day in Memory of SSRI Fatalities

Motivated initially by the death of Traci Johnson, a healthy volunteer in a Cymbalta trial, at one of Eli's facilities, Ana has chosen the 6th anniversary of Traci's suicide by hanging to inaugurate a day in memory of all those who have suffered such extreme adverse reactions to this class of psychoactive drugs that they have taken life - either their own, or that of others. I'll leave Ana to explain the full rationale behind the Event:

February 7 - International Day in Memory of SSRI Fatalities

You can link to the Bloggers Unite Event page via the link, below, or by clicking on the ribbon in the sidebar, at the top of this page. You will need to join Bloggers Unite as part of the process of joining the Event (a 30 second operation, if my experience is anything to go by).

Bloggers Unite - International Day in Memory of SSRI Fatalities

I am aware that the standard line in such cases is to blame these reactions on the underlying condition of any given patient, but plenty of these cases have been acknowledged by official sources as being at least exacerbated by drugs - the Donald Schell case, for example, which involved Paxil (Seroxat). Be under no illusions: there is an issue, here, and it's regrettable that post-marketing reports of adverse reactions tend to be treated with the same kind of selective approach as those emerging during clinical trials.

Sunday, 31 August 2008

The Risks Outweigh the Benefits - An Interview with Bob Fiddaman

Robert Fiddaman(1), Gary L. Hart(2), Michelle Hart(3), Matthew Holford(4)



Foreword

As doctors, we sell our services under the banner of science. Many patients have begun to question the quality, transparency and honesty of our science. Unfortunately, they are doing so with good reason.

When our patients lose trust in the integrity of the science we may never be able to recover our status as a profession. We ignore questioning patients at our peril.

Bob Fiddaman is a question-asker. He is persistent and he is angry. He is also right.

We need to start listening.

Aubrey Blumsohn
MBBCh, PhD, MSc, BSc(hons), FRCPath





Q: Bob, your blog "Seroxat Sufferers" seems to have become a flagship in the ongoing war of words with GlaxoSmithKline, (“GSK”)(5), the Medicines and Healthcare products Regulatory Agency, (“MHRA“)(6), the Department of Health, and so on, concerning GSK's SSRI antidepressant(7), Seroxat(8). You've built yourself a reputation as being belligerent and irritating; or forceful and determined, dependent upon which side of the fence one is sat. Your interest in Seroxat is well-documented, on your blog, as being consequent to personal experience. Why don't you start by telling us a bit about that?

Well thanks for the 'big-up' on the blog, there are others that blog just as well... if not better than I. Personally I think it is because I add my name to most of my rants that the blog has become infamous with all those connected with GSK, the MHRA et al... at least I like to think it has. 'Seroxat Sufferers Stand Up And Be Counted' is quite a mouthful, most people now refer to it as “Fiddaman's blog” - People could call it Leticia's blog for all I care... The main objective was, and still is, to create awareness.

I don't often touch on my own personal experience with Seroxat, particularly on my blog as there are far more important issues to come across.

Basically, I was prescribed Seroxat by my GP(9) due to 'depression' - it was work-related and kind of spiralled when my former employers put me on to a 'Long Term Absence Register' because I had developed an illness that didn't allow me to perform the job I was employed for (Osteoarthritis of the hips). The 'Long Term Absence Register' was basically set up to leave employees without pay and without being able to claim for benefits. It had a strain on family life and Seroxat was deemed to 'fix' that problem.

Seroxat took away the pain of not being able to provide for my family, in fact I didn't really care much about anything. I became devoid of any human emotion other than sadness, it was an unexplainable sadness though, you know bouts of crying when I really didn't know what I was crying about.

I first noticed withdrawal symptoms when my family and I went on holiday - an annual trip to the mother-in-laws caravan. At the time I thought I had sunstroke - strange shooting sensations across my head and a feeling of nausea. However, victims of sunstroke suffer because they get too much sun I had been on holiday for two days, two days in June where it had rained constantly. I actually wrongly thought that there would be no need to take my dose as I was away on holiday and away from everything that reminded me of the employment thing. It was my wife (now divorced) who asked if I had taken my medication. Once I realised that the zaps were caused by me missing a dose, I immediately started again. The zaps then stopped.

The two week holiday was a respite from the problems on the work front, however I didn't feel I was myself on the holiday. I didn't drink alcohol and couldn't get into the spirit of things. Eventually the sun did come out but sitting in it seemed to increase my agitation. Sudden loud noises were beginning to irritate me - unavoidable when you are sitting around a pool and kids are screaming and splashing around, basically enjoying themselves much to the increasing annoyance of myself.

I'd go for walks alone instead of sitting at the beach or around a pool - I didn't like the feelings I was getting at these loud noises - I would clench my fist and hold in the feeling of anger. I became very tired way too easily - one minute I was wide awake, then next I was 'comatose'. I was waking but not feeling that 'refreshed' feeling one does after 8, 9 sometimes 10 hours sleep! Sure, when we are depressed our bodies tend to shut down and sleep is a common trait in the depressed... so I've been told. But this was more than sleep, this was literally like hibernation!

The early days of taking Seroxat have become a blur, there isn't much I can remember.

I started to become violent in my sleep. I remember my then wife telling me that I had woken next to her in the middle of the night. I had climbed on top of her and placed my hands around her throat, with all her strength she threw me off - I, she said, rolled over and continued to sleep. I had no recollection that this event had taken place when I woke in the morning. On another occasion I lashed out at her during sleep. Again, I had no recollection of this incident. Things were strained between us and it was decided that I sleep elsewhere, the couch downstairs was the obvious choice as I didn't want to get into the same bed as my children through fear of attacking them whilst I slept.

Sudden loud noises became a real problem for me, with three children in the house I found it intolerable and would have to leave the room, sometimes house, just to get away from the noise. I started to feel alienated (distanced) from my own family. The children tried their best but how can children play without making noise. They are grown up now and my eldest recently told me 'Dad, it was like literally walking on egg shells'. That saddened me because it was something that was out of my control and something that had only started when I took Seroxat.

As the nightmare continued, my employers agreed to finish me off and an agreement was reached for a retirement package. One would think that a sudden windfall of cash would have brought me back into reality. It didn't. I was numb and at times I thought I was on a different planet with back-to-front time zones. Night sweats, confusion, lack of empathy and blurred or delayed vision became common. I felt like a prisoner in my own home. People complain about Seroxat withdrawal... all of the above happened when I was not withdrawing.

Things came to a head and I tried to take my own life by swallowing 20 or so Seroxat tablets. My then wife was on holiday with a friend. I just wanted out, I didn't care for anything, I had put weight on, my marriage was a sham, my children would take a wide berth when walking past me and would rarely talk with me for fear of me 'snapping'. I just did not care about anything, a complete lack of empathy for everyone and everything. I wanted the old me back, wanted my children to have a dad again. I couldn't see how that could happen. Here I was with a lump sum of money yet I was considerably withdrawn from reality. My world seemed my own and nobody else's. I didn't want anyone else to come into my world because I knew they wouldn't like it.

After I swallowed the tablets I phoned a friend who lived nearby - it was one of the rare occasions where reality had dawned and I realised that I had made a huge mistake. My friend phoned an ambulance and I was admitted to hospital and kept in for observation overnight.

A few months went by and my GP had prescribed me the liquid form of Seroxat, a sickly orange liquid administered with an oral syringe. As I recall, I think I had told him that I wanted [needed] to come off Seroxat as it was making my life a complete misery. I think I had tried tapering by halving the tablets or taking one instead of two. It's all quite blurry. Basically, I had no guidance, nobody could tell me how to slowly taper and what programme to follow. The manufacturer [GSK] offered no guidance on the patient information leaflet, I think the only guidance they offer to day is that 'you must taper slowly' or words to that effect.

I moved out of the marital home, leaving my 3 sons behind me. Again, I felt no emotion. I moved across the city to live with my sister. She educated herself on withdrawal problems and made things really comfortable for me. I owe her a great debt. I lived with her and her two children for about 5 months before being given keys to a one bedroom council flat just around the corner from her. In fact, part of the reason I was able to live so close to her was because the Housing Department had agreed that I needed someone close by to help me through withdrawal. I guess I have GSK to thank for my one bedroom council flat.

I was elated when I got my own place, it meant I could see my children again, more importantly show them how their dad was getting better because I was tapering - and had been during my time spent living with my sister.

The zaps were still with me as was the irregular sleep patterns but I was happy in myself that I was 'getting there'.

18 months from 40mg to 22mg and I was reading comments on the internet from GSK employee, Mary Anne Rhyne, claiming that “discontinuation reactions” last for about 2 weeks. Hmmm, longest two weeks I have ever known!'

Enough was enough, so I decided against my GP's wishes to go cold turkey. He told me to keep in touch on a regular basis and we did via email. My GP had sometime previously stopped prescribing Seroxat to new patients because he had witnessed what I had gone through and had read documents that I had read on the internet and printed for him.

I still allowed my children to come see me for the first few days but then things got really bad. I became violent in my thoughts - I yearned confrontation.

Days and nights passed and I would control the zaps jolting through my body by wrapping a soaking wet ice cold towel around my head. I'd also wrap ice cubes in a smaller towel and place this on the back of my neck. This helped somewhat with the zaps. I'd go for walks in the middle of the night - As I recall this was during the months of Feb/March and it was a particularly cold year. I would walk with just a t-shirt on - the cold biting at my naked arms - I didn't care - anything to take away the zaps – Anything!

I was living in a nightmare, although I had no fear, no fear at all, quite the contrary. I would walk through a country park that backs on to where I live, walk through during the early hours of the morning. I didn't care if I was stopped by gangs of youths, I would 'let them have it' - this was my mindset - I wanted violence.

It was a rough journey and one that I would never recommend to anyone. I've lost friends because of Seroxat, I've lost the woman I married, more importantly [to me] I lost a very precious moment in any father's life - I had missed my children growing up. I locked myself in my flat and after a period of about 3 months [cold turkey] the demon had finally been banished. The clouds had parted and for the first time in six years I felt like Bob Fiddaman again.

The withdrawal hell of Seroxat doesn't look like much when reading about it. One has to experience it at first hand to fully understand just how debilitating it can be.

So there you have it, Matt. GSK messed my life up and are continuing to mess with other people’s lives. I don't want them to do that so I write about them.

In all I was on the liquid Seroxat for a total of 18 months, weaning down from 40mg per day to 22mg per day - it was a long process but It was something I needed to do. This drug had control of me, my thoughts, my emotions, dare I say it, my whole life.


Q: The issue of side effects is an extremely controversial one - you mentioned withdrawal and suicidality, there, which I know are regarded as issues with the drug, now, even though it is still denied that suicidality, for instance, impacts the over-30s, and that it is still claimed, officially, that the severity of withdrawal is overstated. You mentioned that you connected your withdrawal symptoms with the drug, almost instantly. What made you think it was the drug, and not, say, a virus, or something you ate?

Well my initial reaction to the feeling of 'sun-stroke' as mentioned in my first answer to question 1 was that it was just that - Sun stroke. It was only when I added the dots and crossed the T's that I realised that here had been no sun at all, therefore sun stroke could be ruled out. At the time I was 35 or 36 I think and had gone through life as your average Brit, contracting the usual minor ailments, Influenza, Chickenpox, the common cold, et al. This feeling of an electric-like sensation was very strange indeed. I could have been wrong, it could have been something far more sinister like a brain tumour but here I am 8 years on. What occurred after that [the 6 years on Seroxat] would lead me to believe that it was an adverse reaction to Seroxat. If, at that given time, it would have been listed on the patient information leaflet (“PIL”)(10), I doubt very much if I would have had to experience it because I would have been very careful not to miss a dose. The PIL back then was vague - it has slightly improved but is still of little use. Today GSK suggests that a patient taper slowly. That's all well and dandy but how can one taper slowly from a single tablet? GSK should amend the PIL and tell it like it is, something along the lines of 'Patients may experience head zaps and jolts through the body, this is a result of your brain crying out for more serotonin, do not attempt to ride the storm because there have been many instances of patients who have completely gone berserk when experiencing these types of reactions. Your GP must prescribe you the liquid suspension form of Seroxat, a form that we manufactured initially because people had trouble swallowing tablets, Using the liquid is the only way to come off Seroxat for some patients and we, as a caring company don't wish to see patients suffering anymore that what they should'

I of course jest. The chances of GSK admitting they have a defective drug are very slim. The whole withdrawal issue, if you pardon the pun, grinds my teeth. Little is being done about it by our regulator [MHRA]. They tout the yellow card system but have they themselves seen the flaws in it? Nowhere does it ask the patient about what level of depression they have. The patient is asked what they are taking their drugs for. If someone were to fill one of these yellow cards in they would probably say -

DRUG: Seroxat -

SIDE EFFECT - Zaps -

YOUR ILLNESS - Depression.

The MHRA then go away and log it into their system of adverse reports about the drugs they 'regulate'. The suited scientists stuck in the 60's, 70's and 80's will merely pass the 'zaps' off as part of the illness. It's absurd, it's deeply flawed and is basically regulating bugger all.


Q: Yes, this issue of patients being told that what they believe to be withdrawal is in fact their "condition" is one that I've seen mentioned, before. Despite the prevalence of these "electric zaps", do you think that this is a matter of ignorance, on the part of frontline physicians? Incidentally, can you illustrate the zapping sensation, for us - can you think of something more mundane that non-patients might understand?

Well ignorance is bliss... or so they say. The MHRA, NHS, Physicians and GlaxoSmithKline won't recognise withdrawal because it does not affect them. It will only affect them if they acknowledge it because they will have a lot of angry people banging down their doors saying 'We told you so'.

Passing withdrawal off as part of the illness is a classic example of this facade. 'Hey mate you are ill, deal with it because we don't want to help you get better' kind of attitude. The risk-benefit propaganda is something you write about, Matt. They [MHRA, GSK, NHS] cannot tell us what the benefits are of taking Seroxat, yet with a whim can say that the balance of Seroxat helping the patient is better than Seroxat causing the patient damage or adverse reactions. To recap: They all know about the severity of withdrawal but choose to ignore it because of stubbornness rather than ignorance and, in GSK's case, it would damage sales... bit late for that now seeing as one only has to Google the word 'Seroxat' to find blogs such as yours, Seroxat Secrets, GSK Licence To Kill and a host of many others.

'ELECTRIC ZAPS'

Imagine a light bulb 'fizzing' because it has a loose connection. Now put that light bulb inside your head. Basically, Matt, it feels like your brain is frying. It affects your vision and your balance. Many times, my attention was distracted, to which I responded by turning my head so my eyes could see what that distraction was. My head would get there a split second before my eyes, thus causing dizziness. There would be times when I was supping on a cup of tea and my whole body would 'twitch' - it felt like someone had prodded me with an electrical charge. All of these whilst that bulb was still fizzing inside my head. I used to walk around the room waiting for the next jolt. I didn't want to turn my head because of the whole eye movement thing. To try and sit still while all this was going on was nigh on impossible. It would have been easier to stick pins in my skin, at least I could have anticipated the pain - with the zaps you could never tell when they were coming. Many hot drinks were spilled as yet another ripped through me. I have never known a depressed person (without medication) to complain of zaps ripping through his body - have you?



Q: So, if I held onto an electric stock fence, with an irregular, unpredictable pulse, and played white noise at high volume, that would give me some idea? Going back to what you were saying about withdrawal - doesn't GSK acknowledge that 30% of all Seroxat patients experience withdrawal, now? Do you think that's an accurate figure?

I'd be more prone to think that it was like being poked by a cattle prod only not so severe. I couldn't estimate the level of 'Voltage' I got but it was enough to make me drop things I happened to be holding. You know when you wet the rim of a wine glass and rub your finger around it? Think about the noise when it reaches its highest pitch... now imagine how irritating that noise is. You got it? Well, triple that feeling, add a series of random muscle spasms and you have a dose of the zaps. Throw a sudden loud noise in and imagine your head caving in.

Yeh 30%. Quite where they get their figures from baffles me though - unless they are reacting to MHRA yellow card reports? Put it this way, if a product works we [the public] sing its praises. The manufacturer covers itself in garlands and reap the rewards [money]. Glaxo have it both ways. I would estimate that the negativity about this drug in the media and over the Internet far outweighs the positivity about it. Glaxo still reap the rewards, though the garland wilters - the money kind of comforts that blow though.

Glaxo may acknowledge that some patients experiencing withdrawal. A single word on a patient information leaflet is just not good enough. It needs to go into more detail or at least they need to set up a special hotline that deals specifically with Seroxat withdrawal, after all it is their product that causes the withdrawal. The upshot, Matt, is that Seroxat is addictive and nobody can convince me otherwise, not Glaxo, not the NHS nor the MHRA.

18 months to taper from 40mg per day to 22mg per day? C'mon. I've read stories of heroin addicts weaning off their poison more quickly than it took me to wean off Seroxat.


Q: In answer to your earlier question, "no I've never heard of unmedicated depressives experiencing these zaps," though I confess that I've carried out no polls! Now, you mention "addiction," which is another bone of contention, isn't it? The official line (ie, the recent Committee on the Safety of Medicines Expert Working Group report(11)), is that no SSRI is addictive, but that they do give rise to withdrawal, which is a symptom of addiction, within certain preferred definitions (eg DSM-IV(12)), but not addiction, itself. What's your take on that, and does it really matter what one calls the experience?

Well I can only go by personal experience. I smoke cigarettes and crave one if I go for long periods without one. I actually quit some years ago for the best part of a year, I didn't get side effects apart from the first few weeks of wanting one - more of a habit than an addiction. Yet, the government recognises smoking as an addiction. When my Seroxat tablets were running out I used to collect my prescription and head off to the chemist over the road from the surgery. On one occasion they told me that they were out of Seroxat and could I come back tomorrow? I broke out into a sweat as I knew that I would not be able to get through the night without my 'fix'. I refused to leave the chemists and they sent an employee to another shop down the street to get me 40mg of Seroxat just to help get me through the day. After that experience I used to dread walking into a chemist only to be told that they were 'out of Seroxat'. I can say with hand on heart that if any chemist had ever refused to help me I would have willingly ripped the shop apart until they could give me what I wanted. That Matt, is an addiction problem.

GSK knows there is a problem with Seroxat as does the MHRA, I am convinced of this. To admit that there is an addiction problem now would show up the regulator’s past incompetence. I would be prepared to overlook and I would even shake the hand of the MHRA CEO and thank him for acknowledging what I and others have been saying for years. The semantics used by GSK is purely spin, nothing more, nothing less. What's even more confusing is Alistair Benbow's(13) claim on BBC TV's Panorama -:

"Whilst acknowledging that patients will get symp… or may get symptoms on stopping Seroxat, although we still don’t think – and I'm absolutely certain that Seroxat is not addictive – that language was clearly misunderstood and therefore we have proposed that we will take out that specific wording."(14)

I know it is addictive because I was hooked on it. I guess we will never know unless Grassley gets his way in the United States.



Q: LOL. My Legal Method and Legal Systems professor, Dr Lindsay Farmer, once advised my seminar group that when a judge gets a dictionary out, in order to interpret a statute, then one ought to be prepared for a piece of bad law to be made! I seem to remember that the EWG report was a very dry read, on the question of addiction! I think it was claimed that patients weren't subject to the necessary craving/seeking of the drug, amongst other things, to qualify it as addictive. You mention Benbow, there - he excites a considerable amount of invective - you were threatened by GSK's lawyers(15), earlier in the year, concerning a video that was intended to demonstrate the inconsistencies in his public claims, weren't you? Did anything ever come of that?

Well as you know Matt I publicly apologised for my comment about Benbow and also removed the video from Youtube. I had apparently caused him a great deal of distress with not only the comment, but the video, too. The irony of it was that the video was, in essence, a slide show of comments made by Benbow juxtaposed with news stories. Glaxo's lawyers didn't like me using the GSK logo or pictures of Benbow that were apparently the property of GSK. I never heard whether Benbow accepted my apology. I did find it strange that GSK targeted me yet when the video was re-uploaded to Youtube by someone else they didn't really seem to have a problem with it? The support I got from advocates was quite overwhelming. It was a show of strength and if anything put Seroxat Sufferers on the map. The actual video in question has now been posted on blogs and has received more coverage than it ever would have by remaining on Youtube. My blog was created to raise awareness, occasionally I will sound off. On this occasion GSK lawyers actually directed visitors to my blog. I think they rarely get involved in personal opinions because they know that it will direct traffic to the awareness being raised. They almost definitely made an error of judgment in this instance. Proof that lawyers don't always make the right call... even highly paid ones such as GSK's.


Q: Well, lawyers, like most, I suppose, act according to instructions, and because they're getting paid to act. We'll probably never know what those instructions were, but the warning letter you received was probably their best effort at carrying out those instructions. I wanted to talk a bit more about the side effect profile of Seroxat - the suicidality issue, specifically. Again, the official line, whilst acknowledging that it is a problem, minimizes the risk. How do you see that?

It is difficult to prove that Seroxat causes suicide because of the underlying circumstances in most of the cases. Again the suicidal thoughts issue could be down to the reasons why the patient is actually on the medication... at least that's the route GSK lawyers would take I guess?

It's a strange route to take wouldn't you say?

I mean, by their own admission, GSK admitted that it could cause suicidal thoughts in children - I say 'admission' when in actual fact they were backed into a corner in admitting this fact.

So, if they admit it causes suicidal thoughts in children could it be feasible that it can cause suicidal thoughts in adults?

Here's Alasdair Breckenridge’s, Chairman of the MHRA, take on things:

“There is very good clinical trial evidence that these drugs do not cause suicide, they do not cause suicidal thoughts in adults.”(16)

And Benbow:

"The evidence, however, is clear, these medicines are not linked with suicide, these medicines are not linked with an increased rate of self harm."(17)

Given what we know now, Matt, in fact what we [Advocates] have known for some considerable time, I lean toward the school of thought that suggests Seroxat does cause suicide or suicidal thoughts in adults. Donald Schell murdered his wife, daughter, and granddaughter in a fit of rage shortly after starting Paxil. He then took his own life by blowing his brains out with the murder weapon. The remaining members of the family won a multi-million dollar settlement from the GlaxoSmithKline(18). The phrase 'Enough said' springs to mind.


Q: Suicidality, as a side effect, is now acknowledged on the PIL, but officially at least, it is only the under-30s who are at risk (or the under-25s, if one lives in the Antipodes, I think). The case you mention, Tobin v Smithkline Beecham, was a civil case, of course, and SKB (and subsequently, GSK), continued to maintain that the drug was safe in over-30s, presumably because the standard of burden of proof [“on the balance of probabilities“] is much lower in civil cases [than the criminal standard of “beyond reasonable doubt“]. The EWG came to the same conclusion, in its report: the older demographic is safe, and relevant government sources have followed this line. Aside from successful civil actions (of which Tobin was just the first), what leads you to think that GSK, the MHRA and the UK government are mistaken?

Because of the evidence Matt - See the recent Glenmullen report(19). Because of GSK's reluctance to come forward with the suicide data in the paediatric studies - it took them years. Because of the 'experts' they hired to basically pimp Seroxat - Martin Keller(20) et al. Because of the online Paxil petition and patient comments(21).

I don't think GSK, the MHRA and the UK government are mistaken, I think they are aware but such an admittance would have drastic consequences for all those concerned... or not as the case may be.

I have used this analogy before Matt. If Heinz Baked Beans sold their wares and it was proven that one of the ingredients caused children to commit suicide or have suicidal thoughts, do you honestly think that they would remain on sale? OK, baked beans don't profess to cure an illness like Seroxat does but the fact remains - if the make-up of the beans was detrimental to one age group then common sense would be to pull the product. I cannot think of any other product on the market today that is being sold to members of the public where it has been proven to cause serious danger in children, unless of course alcohol and cigarettes are thrown into the pot. Thing is we all know the dangers of alcohol and cigarettes, what we don't know are the dangers of Seroxat. Step forward the risk-benefit ratio - the figures just don't add up.


Q: There's countermanding evidence, then, and from expert sources? That could, of course, simply be an alternative reading of the available facts. You touched on the issue of "efficacy," there - it is argued that the drug is sufficiently beneficial to justify its continued availability, notwithstanding the side effects, now acknowledged to an extent, of course. Given that you questioned the "benefit," in an earlier answer, do you regard the drug as not being sufficiently efficacious to justify these risks?

From my own personal experience, Yes. A total of 21 months to taper off it was not beneficial to me. Taking Seroxat... or rather withdrawing from Seroxat took away almost 2 years of my life. I would say that taking away someone’s right to live as they want isn't beneficial to anyone.

Seroxat can help people through depression, I don't think I or other campaigners have an issue with that. Our issue is that it is so difficult to get off of and when trying one is faced with a whole host of adverse reactions. For me, these reactions far outweigh the 'benefits' of taking Seroxat. Like you, Matt, I still do not know what the benefits are of taking Seroxat. I do know that whatever they are, they do not outweigh the risks as GSK and the MHRA would have us believe.

Way I see it, the only possible answer GSK or the MHRA could give regarding the 'benefits' of Seroxat would be 'because it helps people with depression'. Put that up against the list of adverse reactions on the patient information leaflet and/or the 'anecdotal reports' then we have a serious imbalance in benefits and costs.


Q: But there's an objective assessment of efficacy, isn't there? There must be, or else the MHRA wouldn't be able to carry out a risk:benefit analysis. I know that NICE(22) has decided that a drug must alleviate the symptoms of depression better than placebo - three points better, on Hamilton DRS, than placebo. Is NICE's measurement of efficacy different to the MHRA's, and if it's the same, is three Hamilton points an acceptable trade-off against the withdrawal effects and suicidality that we've discussed?

It's hard to judge, Matt. The MHRA will receive the yellow card reports citing adverse reactions to Seroxat, they will log them and... well, that's basically it! They have nothing to put them up against. I think where they fail is that they assume all the others taking Seroxat who haven't made a complaint or filled in a yellow card must be happy with Seroxat. That's the way I see it, anyhow. I really can't see any other logical explanation for their reluctance to condemn Seroxat. They grant a licence to a drug, they get complaints - I, myself, am not asking for Seroxat to be removed from the shelves, I am asking for the whole withdrawal issue to be acknowledged and for the MHRA to stand with the patients on this and not the manufacturer. I can't really get into the Hamilton points thing as it is something that I have not really studied and I wouldn't feel comfortable talking about it.

To sum it up.

BENEFITS = 1

RISKS = Loads.

Now, I'm no Einstein but I'm guessing that the figures don't add up!


Q: Withdrawal is acknowledged as an issue, to an extent (ie, it's on the PIL, and the EWG accepted it was a factor in the use of all SSRIs). What are you hoping for, from the MHRA, over and above what it's already doing?

Well, to act, Matt. The MHRA seems to be doing a lot of listening but nothing more.

I've publicly stated what I want from them.

There is currently no guidance on withdrawal other than what it states on the patient information leaflet. I would want the MHRA to liaise with someone like David Healy so they could at least offer some sort of withdrawal programme for those suffering severe withdrawal. This programme would have to be available at surgeries and NOT just as a download on the MHRA website.

I would want them to send a 'Dear Doctor' letter out to health centres in the UK stating that any patient suffering from withdrawal with Seroxat MUST be prescribed the liquid suspension and given a programme of withdrawal [see above]

I would want special clinics set up for those suffering withdrawal... even a 24 hour hotline specifically set up to talk to patients going through the withdrawal process. A patient can feel suicidal when withdrawing too fast, they may have the choice of ringing the Samaritans but would a volunteer at the Samaritans actually know what it feels like to be 'coming down' from Seroxat?

The MHRA needs to liaise with the government on this. If Pharma want to fund it then so be it, but they cannot have any influence on those handing out the guidance. Who better to operate these guidelines than former withdrawal sufferers?

Maybe a special warning needs to be included on packs of Seroxat, such as there is with packets of cigarettes. Not every patient reads the PIL but I do think patients would take notice if a warning was slapped on the box.

They [MHRA] may think it's an awful lot to ask for, I would have to disagree. They are in a position to stop un-needed suffering, they have an opportunity to show how much they care about safeguarding human health.

They ARE listening... I'll give them that and the communication HAS improved but it's time for action, it's time for them to prove to the patient that they are not in Pharma's pocket.


Q: Well, aside from the question of funding, none of the things that you mention appears outlandish, and, perhaps more importantly, none requires that GSK/other takes the blame for what has gone before, nor even acknowledges that a wrong, in the shape of knowledge of what was happening, has taken place. Aside from any adjustments to the PIL, which would obviously require agreement from GSK and the MHRA, have you considered de-looping the authorities, and setting up your own helpline, perhaps in conjunction with Seroxat User Group - in that way, you wouldn't be beholden to anybody?

I would bend over backwards to help people suffering withdrawal Matt. One phone line just wouldn't be enough and then of course there is the money required to set up such a thing. I would help run such a service but it would be logistically impossible to man a phoneline as I have a life too. If anyone wishes to start such a 'helpline' up then I would be willing to do my share of work on it... Unfortunately, there are many people who 'bad mouth' GSK but don't have the commitment to stand next to their convictions. I'm not blaming them because I know how time consuming it can be and how intimidating they or their lawyers can be. Thing is, the UK bloggers cannot do everything... at some point someone has to step in and say 'We realise that help is needed... what about x,y or z', will that help you?

The MHRA knows pretty much what I want and what I feel is best for all concerned. Time will tell whether or not I get it.



Afterward

There is one fact that cannot be denied, by anybody: a lot of people are experiencing suffering. This may be because of the drug, and it may not. The cause ought to be irrelevant to a determination to seek a solution. So:

1. We have a bunch of desperate people, who are complaining;

2. It seems that everybody is expending more effort in denying responsibility than in seeing what they might be able to do to help those people;

3. Why is that?

We already know that there is a limit to what activists can do, given our financial resources, or lack, thereof. There is also the factor of selfishness, if that's not too blunt a word - nobody who could help will help, because they perceive it (or want it), to be somebody else's responsibility (ie, they don't want to expend time, effort and money, when somebody else might be expending time, effort and money). Finally, nobody appears to know how to begin to address the issue, and therefore it's easier to not acknowledge it (or else blame it on the people experiencing it), than it is to acknowledge that they don't know what to do, when this simple thing would be the first step towards understanding. In part, this may be to avoid acknowledging a lack of expertise in an area in which they are supposed to be expert.

The objective as I perceive it is to have withdrawal sufferers to not feel as desperate as they do (irrespective of how achievable one believes that goal to be that is, nevertheless, the goal). Nothing that's being done contributes towards that objective, as far as I can see.

Matthew Holford, LlB, FICA




(1) Bob Fiddaman is the author of Seroxat Sufferers. He has been raising awareness for three years regarding the safety and efficacy of Seroxat.
(2) Dr. L. Gary Hart, PhD is an endowed professor in the College of Public Health at the University of Arizona and Director of the Arizona Rural Health Office.
(3) Michelle "Shelly" Hart is a Registered Nurse currently writing a book on Paroxetine withdrawal after having had a severe withdrawal reaction stopping the medication.
(4) Matthew Holford is a Law graduate and Financial Compliance professional, whose interest in SSRIs began in 2004/5, when he experienced a severe reaction to fluoxetine.
(5) GlaxoSmithKline was formed in 2001, through the merger of Glaxo Wellcome and Smithkline Beecham, a merger overseen by the recently departed CEO of GSK, Jean Pierre Garnier.
(6) The MHRA “is the government agency which is responsible for ensuring that medicines and medical devices work, and are acceptably safe.” It was created in 2003, through the merger of two government agencies, the Medicines Control Agency, and the Medical Devices Agency.
(7) Selective Serotonin Reuptake Inhibitors, or SSRIs, are said to relieve the symptoms of depression by blocking the reabsortion of serotonin, once a chemical message has been passed across a synapse. Doubt has been cast upon this hypothesis, to the extent that manufacturers acknowledge that it is not known how SSRIs work, which assumes that they do work.
(8) Seroxat is the name under which paroxetine hydrochloride is marketed, in the UK. The drug is also known as Paxil, Aropax, Deroxat and Motivan.
(9) “General Practitioner” is the term applied to primary care doctors, in the UK. “Family Physician,” or “General Internist” would be the equivalent terms, in the US.
(10) PILs became mandatory, in the UK, in 1996. Leaflets, providing information on drugs, had been available prior to this, but this was done on a voluntary basis, and the information contained therein had not been formalized. According to the MHRA, the PIL is a collaboration between the manufacturer, which remains responsible for the wording, at all times, and the regulator, which approves it.
(11) See The Report of the CSM Expert Working Group on the Safety of Selective Serotonin Reuptake Inhibitor Antidepressants, published in 2003.
(12) The Diagnostic and Statistical Manual, currently in its fourth edition, published by the American Psychiatric Association, “is the standard classification of mental disorders used by mental health professionals in the United States.”
(13) Dr Alistair Benbow is Head of European Clinical Psychiatry, at GSK. He has featured regularly as a spokesperson, in defence of Seroxat.
(14) BBC Panorama, "Taken on Trust," 21 September, 2004
(15) See, for example, Pharmalot's Glaxo, an Angry Blogger and Free Speech
(16) Ibid.
(17) Ibid.
(18) Tobin v Smithkline Beecham Pharmaceuticals 164 F. Supp.2d 1278 (D. Wyo. 2001) . See also Paul Whitehead, MD, Causality and Collateral Estoppel: Process and Content of Recent SSRI Litigation, J Am Acad Psychiatry Law, 31:377-92, 2003
(19) Report of Joseph Glenmullen, August, 2007
(20) Dr. Martin Keller is the Mary E. Zucker Professor and Chairman of the Department of Psychiatry and Human Behavior at Brown Medical School in Providence, RI, as well as Executive Psychiatrist-in-Chief at the seven Brown Medical School affiliated hospitals. He is alleged to have put his name to an academic article, published in the Journal of the American Academy of Child and Adolescent Psychiatry, which he did not write, and had not seen the data supporting the conclusions drawn to the effect that Seroxat was efficacious and safe in the treatment of minors.
(21) Seroxat Withdrawal Comments
(22) The UK’s National Institute for health and Clinical Excellence, or NICE, is responsible for drafting guidance to GPs, concerning best practice in the treatment of medical conditions. It is also responsible for approving drugs for use on the National Health Service.



(c) 2008 Blumsohn, Fiddaman, Hart, Hart and Holford


Addendum:
For the record, the text of this interview was presented to the Bedford Massive, the Nine Elms Massive and the D'oh, amongst others, for comment. Only the MHRA responded, in the person of John Watkins, saying that it had no objections to publication, it being fair comment, and an expression of personal opinion.

Thursday, 8 May 2008

Create the Life You Deserve

Just under three years ago, I attended a NLP Practitioner's course, operated by a company called Inner Compass. Inner Compass has since gone into receivership, although the name has been acquired, and is still being used to sell goods and services. As far as I can establish, most of the people who were employed by Inner Compass are still in position. Hmmm. That sounds like a phoenix company, to me. Still.

Anyway, the Company failed me on the course, for reasons that it was unwilling to go into any detail over. That is, I was told that I was "seeking significance," although what this amounted to was not explained. Now, I don't think people should go around throwing around language, when they are unable to detail what they're talking about, because then it makes them look incompetent, but still.

So, having paid over 3,500 quid, I have no call on the Company to provide me with the certificate, nor to find me a place on another course, as was promised by the then owner of the Company, Andy Harrington, who still consults for the new company. Not within the Law, anyway (but in Equity? Well, that's a different matter). As "Sherry," the person who took my telephone call this morning, put it "your three and half thousand pounds doesn't exist, anymore". Right, thanks for that, Sherry. Actually, it does exist: it's in Andy Harrington's back pocket, and I can quite legitimately trace it all the way there.

So, I am currently awaiting the largesse of the new owner, who, I am assured, is very keen to maintain the good name of Inner Compass. I imagine we'll establish just how keen he is.

Matt

Related link:
The "all new" Inner Compass

Saturday, 3 May 2008

Recording: British Paxil Users Meet With Brit FDA

Furious Seasons has posted the audio recording of the recent meeting between representatives of the Nine Elms Massive and patient advocates. I've made a couple of comments on there, if you're interested (and even if you're not interested, I've still made a couple of comments), but the upshot is that the Establishment has decided to defend its position - there is no attempt being made to address the issues with the industry that several commentators and patient advocates have raised. It seems to be about justifying the status quo, when the status quo is shit.

I listened to the recording for 36 minutes, and I was so disgusted with the whole fucking thing that I refused to expose myself to it, any further. It sounded very much like a PR exercize, nothing more. If the MHRA was really listening, it would be including its biggest (or at least most vocal), critics in the discussion and it would be addressing the issues that they raise, instead of justifying the machinations of the system, which, in their totality, I argue achieve precisely the opposite of what it is argued is being achieved.

What is being done to address the way in which companies have complete control over the trial of drugs, statistical analysis and writing of papers? What is being done to establish regulatory rules and guidelines, which fill the gaps left by legislation? Will the UK regulator address the question of its apparently flimsy assessment process - for example, why does it accept those dodgy academic papers as valid evidence of safety and efficacy, when there is evidence that this business of "information laundering" renders academia unreliable, to say the least?

Oh, it's all bollox - the halfwits don't want to change a damn thing, because it's not in their interests to change anything, and because they don't know how.

Matt

Wednesday, 30 April 2008

Clinical trials and drug promotion: Selective reporting of study 329

A paper by Jureidini, McHenry and Mansfield on the subject of Protocol 329. Dr Jureidini, you may remember, was one of the original critics of the paper that the Great Genius Who Is Professor Martin Keller "wrote," back in 2001. The paper is available on Healthy Skepticism, but has attracted attention from Fidders and Clinical Psych, the latter making the particularly pertinent observation that the various statistical shennanigans that took place in order to turn, quite magically, Paxil from a pile of kak into a pile of kak with a bow on top is anything but an isolated incident (although, I find that all magic is based on sleight of hand).

I'm not a statistician, and so I don't fully understand the nature of the argument, although I do understand that changing what one claims to have been looking for, after one has the results in front of one, probably isn't very scientific. No, to quote the Great Genius Who Is Professor Martin Keller, "I'm better with words"! And I'm still struck by the need that James McCafferty (the Paxil Phase 4 project manager, and a SKB employee), perceived to tell Sally Laden (the ghostwriter) that she oughtn't to be making grand claims as to safety, when she was also documenting lots of adverse events.

McCafferty and Rosemary Oakes, a senior statistician at SKB, who worked on the project, got their names on the paper, when it was published. Call me old-fashioned, but I should have thought that having the Company run the trial, crunch the numbers, and then write the paper, informing people of what the numbers meant, before using that paper as an adjunct to a marketing authorization application (and have the regulator accept said paper as valuable evidence), is probably open to abuse. What? Oh, yeah: it was abused, but I should state for legal reasons that it is only my opinion that this was abused. As such, it is merely my opinion that I cannot conceive of a more flagrant fraud.

Matt

Friday, 25 April 2008

Book of the Week - The Autumn of the Patriarch

At the suggestion of a friend, this is to be the first in a regular series, wherein I'm going to let you know what I like to read, and maybe why. I'll quote an excerpt, and then you can please yourself whether you go and get yourself a copy!

...When the cataclysm had passed he still heard the distant music of the windless afternoon, he went on killing mosquitoes and with the same slaps trying to kill the katydids in his ears which hindered him in his thinking, he still saw the light of the fires on the horizon, the lighthouse that tinted him with green every thirty seconds through the slits in the blinds, the natural breathing of daily life which was getting to be the same again while his death was changing into a different death more like so many others in the past, the incessant torrent of reality which was carrying him off toward the no man's land of compassion and oblivion, God damn it, fuck death he exclaimed, and then he left his hiding place exalted by the certainty that his grandest hour had struck, he went through the sacked salons dragging his thick phantom feet in the midst of the ruins of his former life in the shadows that smelled of dying flowers and burial candlewicks, he pushed open the door of the cabinet room, heard through the smoky air the thin voices around the long walnut table, and saw through the smoke that all the ones he wanted to be there were there, the liberals who had sold the federalist war, the conservatives who had bought it, the generals of the high command, three of his cabinet ministers, the archbishop primate and the Ambassador Schontner, all together in the one single plot calling for the unity of all against the despotism of centuries so that they could divide up among themselves the booty of his death, so absorbed in the depths of greed that no one noticed the appearance of the unburied president who gave a single blow with the palm of his hand on the table, and shouted aha! and that was all he had to do, for when he lifted his hand from the table the stampede of panic was over and all that was left in the room were the overflowing ashtrays, the coffee mugs, the chairs flung on the floor, and my comrade of a lifetime General Rodrigo de Aguilar in battle dress, minute, impassive, wafting away the smoke with his one hand and indicating to him to drop to the floor general sir because now the fun is going to begin, and they both dropped to the floor at the instant the machine guns' death jubilation started up by the front of the building, the butcher feast of the presidential guard who with great pleasure and great honor general sir carried out his fierce orders that no one should escape alive from the meeting where treason was being hatched...

I'm a big fan of Marquez. I don't know what made me think of this book, though. Something to do with deception and illusion, perhaps? It's a recurring theme, of late. Perhaps somebody should have realized before now that when a tyrant takes charge, he spends his time in power turning his dominion into a replica of himself. Just think what Mugabe's mind looks like. How he neglects himself - or most of himself, anyway!

Monday, 21 April 2008

Fluoxetine - Part III

I thought about writing a caustic preamble to this latest missive from the MHRA, but then the whole thing's so fucking tedious that, frankly, I felt that it was beneath me to devote the requisite mental energy for a truly lacerating introduction. Anyway, the MHRA has nothing to say. Seemingly, it is a body with no knowledge and no ideas, and no hope of securing either of those things. Either that, or it's as corrupt as fuck. This to the Ministry of Truth, copied to Vara, blind copied to lots of people (the MHRA's Great Words of Wisdom are emboldened, as usual):


Dear Sir or Madam,

Thank you for your prompt reply, and for taking patient concerns over the drugs that they use so seriously. Particularly those patients who are giving you earache over drugs that they believe to be snake oil remedies.

The issue of the way in which the MHRA assesses drugs is a new one, in that the MHRA has not chosen ever to answer the query, in the first place. I don't believe that the way in which drugs are assessed for marketing in the UK could be any more substantive. Perhaps you could give me a checklist of "substantive" items that the MHRA would be prepared to answer - it has already refused to confirm its assessment process, and the benefit to be taken from both fluoxetine and paroxetine? Frankly, I'm struggling to understand what it will discuss.

In fact, on that note, I rather suspect that the MHRA has nothing at all to discuss with me, on any subject. And I rather think I know why, but that would be for another day. Regrettably, that means that I have nothing to discuss with you (pl), because that seems to be the only level of agreement that we can reach. I regret that your methodology is anything but sophisticated - tant bloody pis!

Best regards


Matthew Holford




***********************************
Subject: RE: FOI 08/064 - FW: Fluoxetine
Date: Mon, 21 Apr 2008 13:04:43 +0100
From: info@mhra.gsi.gov.uk
To: m.holford@hotmail.co.uk


Dear Mr Holford

Thank you for your e-mail of 19 March.

You reference one of the documents we previously sent you, and in particular the phrase "if used in its specified way"; and ask whether this phrase was included by a scientist or a lawyer. The document which you refer to was in fact developed through a consultation process which included people working for the MHRA itself as well as a range of stakeholders from outside the Agency (including patients and consumers). To attribute any one particular phrase or part of the document to a specific individual is therefore difficult and potentially misleading.

In relation to the other questions you pose, we have nothing to add to our earlier response. Unless you raise substantive new matters, we will not be responding to further correspondence on this issue.

Kind regards

MHRA Information Centre

Friday, 18 April 2008

MHRA - Has the penny finally dropped?

Fidders has been intrigued by the apparent confluence and coincidence of interest shown by the D'oh, the MHRA and GSK's lawyers (please see the link, below). I thought it would be quite a sweet idea to contact Steptoe's, and put a human face on patient dissent! This to Andrew Bloom, a partner at Steptoe's, copied to Fidders and Breckenridge, blind copied to lots of people:

From: m.holford@hotmail.co.uk
To: abloom@steptoe.com
CC: [redacted]@blueyonder.co.uk; [redacted]@mhra.gsi.gov.uk
Subject: MHRA - Has the penny finally dropped?
Date: Fri, 18 Apr 2008 08:41:11 +0000

Dear Andrew,

I wonder if you could forward this email to the person responsible for "reviewing" Mr Fiddaman's blog?

Perhaps you will be aware that staff at the MHRA have been forbidden from visiting the site, aside from one or two authorized persons, that is? We are interested at the correlation between visits by the MHRA, Steptoe's and the D'oh. We are also interested in that, whilst it ought to be trivial for the MHRA to have its IT people establish which user station it is that is visiting Mr Fiddaman's site, it appears not to be concerned with the breach of its own ban. Plus ca change, plus ca le meme chose, I imagine!

MHRA - Has the penny finally dropped?

In any event, I am concerned that there is an inequality of bargaining power, here. That is to say, we have significantly more knowledge in this area than you do. We regret this state of affairs with all the sincerity that our hearts have to offer you. If you are interested in having the deficiency in your intelligence remedied, we would be happy to oblige.

Howsoever it may be, you will have noted, I imagine, that Mr Fiddaman is doing nothing other than describing the world from his perspective, as are we all, I imagine. We would regret any attempt by Steptoe's to try to characterize it in any other way. I trust that we understand one another. Incidentally, if you believe that you have won an argument with us, at any point, please advise, and we will be happy to disabuse you. We imagine that you are very bright guys, but you are not in our league. Kindly do not contradict me on that point.

Finally, I would be grateful if you would not take to making allegations of defamation, harassment, and whatnot, in our direction. It's really quite tiresome. And untrue. As I wrote, before, we are merely describing the world from our perspective. How you receive our perspective is a matter for you to address, not us.

Best regards


Matthew Holford

Friday, 4 April 2008

I've just posted this as a comment...

...on the Pharmalot thread that covers the Bob Fiddaman intimidation story, and I thought it summed up my position so succinctly that I'd post it, here, too:

Former pharma Marketing Exec wrote:
“…In the end, when you connect all the dots - and the dots always get connected - you can actually see the extent the management went to in order to cover up and deceive the very market they serve. The patients, their own scientific advisory board, their KOL’s…”

Yes, and yet, despite this evident and flagrant abuse of trust, it seems that no significant effort is being made to remedy the deficiencies of the system that permitted it to happen, in the first place. There will be a bit of superficial tweaking, obviously, but there will be no attempt to change the culture of secrecy and blind eye.

There is no argument, here: the drug doesn’t work in any but the tiniest proportion of depressed people. And it’s dangerous. The Company knew both these things, but continued to press the drug on an unwitting public. The only thing that saves GSK from a very public humiliation in the criminal courts, is, I suspect “the public interest,” as perceived.

That is, I imagine, the damage to the UK economy (loss of jobs - and people are already being laid off in Eire, where the drug is manufactured), and, more pointedly, loss of public confidence in a lie that should never have been peddled, when there is no alternative treatment that people are willing to consider, are the things that will be used as justification for doing nothing meaningful, at all. Meanwhile, people such as Bob Fiddaman will continue to receive shitty letters from halfwit lawyers on behalf of mealy-mouthed jobsworths.

Shit sticks. The things that GSK (and its regulators), would have to do in order to restore public trust are unconscionable for people with the mindset that these people have. It would mean that they have to admit that they were wrong - and they’ve positioned themselves such that that is not a possibility.

Matt

Sunday, 30 March 2008

Intimidation: a standard tactic?

I couldn't help but have a chuckle to myself, this morning. I'm a longtime fan of Elvis Costello, and Watching the Detectives is a wonderful track, but given recent events, it was an uncannily timed post.

It seems that Bob Fiddaman has incurred the wrath of the Great, Powerful and Excellent GSK, and has, incidentally, injured the fragile sensibilities of Ali B, in the process. You should have a read, for yourself:

GSK Lawyers target Seroxat campaigner Bob Fiddaman

GSK's got form in the intimidation stakes, of course, as I pointed out to the Ministry of Truth, in a recent post. Anyway, I suppose I ought quickly to apologize to GSK and Ali B, et al, if I have inadvertently suggested that they are a bunch of lying, scheming scumbags, at any point, during the past year, on this blog. They are, of course, not lying, scheming scumbags, but fine upstanding members of the corporate community, with only the good of Mankind in their thoughts. I just wanted to make that absolutely clear.

Related links:
Addleshaw and Goddard email request form - feel free to make enquiries of GSK's conduct, via its lawyers!

Friday, 21 March 2008

Abuse of Trust - Part VI

I'm not sure what prompted this: boredom, I suppose. To Breckenridge, copied to the Ministry of Truth and Vara. Blind copied to lots of people:


Dear Professor Sir Alasdair (that's "D-A-I-R") Breckenridge,

"The MHRA Chairman [that'd be you] suggested that trust underpinned the stance of the MHRA towards the companies they regulate. We inferred that this extended to the routine acceptance of companies’ summaries of the results of tests on their drugs as true reflections of the raw data on which they were based."
Source: The Influence of the Pharmaceutical Industry para 283

Did the HSC surmise correctly? If so, then I would suggest that this is not sensible. The cases of Avandia, Seroxat, Vioxx, Seroquel, Risperdal and Zyprexa (and, no doubt, many other drugs), would bear me out. There appears, then, to be ample evidence that the Worshipful Company of Apothecaries is not to be trusted. Why do you continue to trust it, Professor?

What I'm saying, in essence, is that the Worshipful Company appears to be only too well aware that it's opinion of its own drugs is going to be taken at face value, with little or no scrutiny from the body that is charged with that responsibility. As such, the temptation to take liberties is one that the Worshipful Company is unable to resist, apparently. This would be fine, if everybody understood that to be the position - we just wouldn't take the snake oil remedies on offer. However, the Worshipful Company (and at this point I include the MHRA), presents itself as the very paradigm of truth and scientific rigour. But it's not, is it? The upshot of this model is that inefficacious and dangerous drugs may find their way onto the market in spades. And you're pretending that everything's OK, by the look of things.

So, why aren't you (ie, you personally, and the MHRA), doing anything to tighten up the system, to prevent the fraudulent use of KOLs, dubious marketing techniques, intimidation of whistleblowers, suppression of adverse event data, etc, etc? It's your job, remember? Or do you not regard this as part of your remit, in which case you should let us know?

Best regards


Matthew Holford

Wednesday, 19 March 2008

Fluoxetine - Part II

God, I'm bored. The MHRA's mail is in bold, as usual:


Dear Sir or Madam,

I have had the opportunity to scan the excellent and informative documents that you linked. I am particularly interested in the second of these:

Making Regulatory Decisions about Medicines and Medical Devices

and most particularly Section C., paras 1/2:

1 Does the product work and offer useful clinical benefit if used in its specified way? [my emphasis - was this rider included by a scientist, or a lawyer?]

Is there robust evidence that the product will do what the company says it will do?

2 What impact will the product have, or is it having, on both the quality and length of life in those patients who are treated with it or on whose behalf it is used?

Are you able to expand, at all? I think that these questions, in combination, essentially ask the same question that I put to you, initially - ie, "what is the benefit of fluoxetine?". So, perhaps you could detail what "robust" evidence amounts to, and what evidence would be sufficiently robust, such that it demonstrates that which is claimed of a drug? I am particularly interested, in this context, on the question of "quality of life," alluded to in para 2 - presumably the "impact" spoken of is intended to refer to a positive/beneficial impact? In which case, what "robust" evidence would demonstrate the same beneficial impact claimed of a given drug by the manufacturer?

Please feel free to use fluoxetine as a case study, when answering these questions - I imagine that this would assist my understanding.

Best regards

Matthew Hoford

***********************************
Subject: FW: FOI 08/064 - FW: Fluoxetine
Date: Wed, 19 Mar 2008 12:06:56 +0000
From: info@mhra.gsi.gov.uk
To: [redacted]@hotmail.co.uk


Dear Mr Holford,

Thank you for your recent enquiry to the MHRA.

Please find attached a response to your enquiry.

Please contact us again if you need further assistance with this, or any other queries.

Kind Regards,

Central Enquiry Point
Information Centre
Medicines and Healthcare products Regulatory Agency
Tel: 020 7084 2000

Attachment:
Thank you for your e-mail dated 18 February, 2008, concerning fluoxetine. In particular, you wish to conduct you own risk:benefit analysis using the MHRA’s methodology. You will not be surprised to know that the risk:benefit analysis does not consist of a magic formula. We do however outline our approach to weighing up risks and benefits for medicines in a document on our website called "Medicines and Medical Devices Regulation: What you need to know http://www.mhra.gov.uk/home/groups/comms-ic/documents/websiteresources/con2031677.pdf, particularly in the box entitled "When is a product acceptably safe?" on page 2). There is further detail in another document on our website titled "Making Regulatory Decisions about Medicines and Medical Devices"

http://www.mhra.gov.uk/home/groups/comms-sp/documents/websiteresources/con2030689.pdf

These documents should give you some insight into the way we make decisions and the factors and considerations that go into the risk:benefit analysis.

You have also asked us to explain the benefit of fluoxetine, this information can be obtained from the Summary of the Product Characteristics for fluoxetine which you can access through the Electronic Medicines Compendium (http://www.medicines.org.uk/searchresult.aspx?search=fluoxetine)

I hope the above information is helpful and answers your query.

Monday, 10 March 2008

Monty Burns and Avandia Renegade-gate‏

Given the MHRA's recent decision not to pursue GSK, I thought I'd stick the boot in - this one's been simmering just beneath the surface for a while, so it's not shy on invective. This to the Ministry of Truth, copied to Vara, Johnson and the White House, blind copied to lots of people:


Dear Sir or Madam,

I am keen that nobody should misunderstand the moniker that I have given to Garnier: one is a shady bastard, who lives in his own private fantasy world, where he may do anything that takes his fancy and avoid the consequences, and the other is a cartoon character. I'm going to quote the Senate Finance Committee's report into the intimidation of Dr John Buse at you, at every possible opportunity:

"GSK’s behavior since these allegations [came] to light has been less than stellar. Instead of acknowledging the misdeed to investors, apologizing to patients, and pledging to change corporate behavior, GSK launched a public relations campaign of denial. Specifically, GSK sent out a press release titled “GSK Response to US Senate Committee on Finance” which stated that the allegations raised by the Committee were “absolutely false.” Further, CEO Jean-Pierre Garnier denied having any knowledge of the alleged intimidation of Dr. Buse in an interview that ran in July in The Philadelphia Enquirer."

Ouch - not many fans on Senate Finance Committee, then, I guess? "Instead of... apologizing to patients, and pledging to change corporate behaviour... GSK launched a public relations campaign of denial..."? Hmmm, there's something about that, that I can't quite put my finger on...

And later we discover that Monty was lying about his knowledge of the incident (what other extremely important matters does he lie about, I wonder?), or if he wasn't lying, then I'd be delighted to have him reconcile for me his claim in The Philadelphia Enquirer, as against the following excerpt:

"In response to [a] series of emails, Dr. Tachi Yamada, GSK’s head of research at the time, wrote in an email that he had discussed Dr. Buse with GSK’s CEO Dr. Jean-Pierre Garnier as well as David Stout, a senior GSK executive. Dr. Garnier and Mr. Stout are copied on the email. Specifically, Dr. Yamada’s email reads: In any case, I plan to speak to Fred Sparling, his former chairman as soon as possible. I think there are two courses of action. One is to sue him for knowingly defaming our product even after we have set him straight as to the facts—the other is to launch a well planned offensive on behalf of Avandia…"
(Source: The Intimidation of Dr. John Buse and the Diabetes Drug Avandia - it's a super read, I really do recommend it)

"Setting him straight as to the facts."? I'll bet Yamada's "facts" barely qualify as opinions. How do these fuckwits get their PhDs? Do they buy them out of the back of Private Eye, or something?

So, the lesson we take from this is that when Monty and his ilk feel that the reputation of their snake oil remedies is under threat, they wheel out the well-oiled intimidation machine and pretend that they are exercizing their legal right. Monty, Yamada, Stout: what a bunch of crooked cunts they would have to be to either actively engage in this type of activity, or to give it their tacit approval by remaining silent while it played out (by which I mean that they would have to be devoid of any admirable human characteristics). Sadly, I'll bet they're not the only ones. In fact, I know they're not, because it's "just business, nothing personal" isn't it? Intimidation = business? I'll remember that - it's another of your unspoken rules, isn't it?

Ah, isn't it great to have opinions? They're the last refuge of free speech, you know.

Best regards


Matthew Holford

PS It's a side issue, given that I just wanted to establish my contempt for Monty, but the Committee report asserts that many lives would have been saved, had GSK not sought to suppress Dr Buse's concerns. Just something to think about.

Thursday, 28 February 2008

Reaction time is a factor, so please pay attention...

I was just wondering what the MHRA assessment process looked like. It wouldn't tell me, you see, so I had to do something to fill the gap in my knowledge. I came up with this:

MHRA: Are your drugs the best in the world, ever?

Worshipful Company: Oh, yes!

MHRA: Are they really safe, and efficacious, such that none may doubt your great wisdom and excellence?

Worshipful Company: Oh, yes!

MHRA: Well, I think that's all I need to know: the Marketing Authorization will be in the post, tonight.

Anyway, yesterday's "Here's an interesting little snippet" reminded me that I wrote to the Head of the MHRA's ill-named Intelligence and Enforcement Unit back in September (see Sept, 2007 archives). I re-sent the query, copied to Brown, Johnson, Vara and blind copied to a whole bunch of people:

Dear Mr Deats,

You may remember that I contacted you, back in September, of last year. I don't appear to have had a response from you, on this point:

"I am currently engaged in a discussion with Professors Woods and Breckenridge and the CPS (please see below) on a question over the application of Regulation 50 of the Medicines for Human Use (Clinical Trials) Regulations 2004 (as amended).

Would it be your position, as Head of the Intelligence and Enforcement Unit at the MHRA, that where trials have been carried out on a drug, and those trials have produced negative results, and that there are also trials of that same drug that have yielded results that are interpreted as positive, and it is subsequently only the positive results that are submitted in support of a marketing authorization application, that the presentation of only the positive data (owing to the suppression of the negative data) amounts to the provision of "false or misleading" information, under Regulation 50?"

Far be it from me to question the quality of the MHRA's response time to any but the most trivial of queries, but I think five months is probably enough thinking time. Would the scenario that I've drawn up for you qualify as a breach of Regulation 50? This is an example of one of those embarassing little questions that the MHRA is so piss poor at answering. However, the cumulative effect of all these unanswered questions is quite telling - they give me some idea of the areas where the MHRA does not wish to commit itself, and one may only speculate on why that would be...

Best regards


Matthew Holford

Wednesday, 27 February 2008

Here's an interesting little snippet:

To the Ministry of Truth, at the MHRA, copied to Brown, Johnson and Vara, blind copied to lots of people:


Drug giants warned: Tell the truth on medicines

Towards the bottom of the piece, the D'oh is quoted as saying:

"The Government has consistently supported open access to information about research when the findings could affect decisions about treatment or health outcomes. We planned to support the principle of mandatory registration of clinical trials in the UK, but legal advice stated this would be illegal under EU law."

First, I don't think anybody should be positioned, such that they can make a decision upon whether findings "affect decisions about treatment..." The information should be made publicly available. End of. Second, it was my understanding, although the MHRA never explicitly confirmed that it was also its understanding, that the Medicines for Human Use (Clinical Trials) Regulations ("MHU") required that all trials be registered, and that regulators be notified when trials had ended (it didn't have to confirm it: it's Law). The MHU is itself an implementation of EU Law. So, the EU says that all trials must be registered and notified when they end, but there is no requirement to do other than submit the data to the regulator - the Worshipful Company is protected by EU Law from wider scrutiny?

The loophole (or should that be "black hole"?), here is the regulator. It has the power to demand data. It receives all data, we're told. And then it makes really fucking weird choices that other bodies making similar decisions (eg NICE), are altogether more circumspect about, given that they don't have access to the same data.

And all this, which as we know leads to abuse of trust (Vioxx, Avandia, Seroxat, Seroquel, etc, etc, ad nauseum), is permitted to continue, because the Worshipful Company is entitled to pretend that trials results are trade secrets. I think somebody's putting the wrong weighting on their decision-making. This is about public health and safety, not commerce, and if one approaches this problem from the former angle, this whole cluster fuck looks anomalous. It only looks proper and normal, when a minority interest is being protected.

Matt

Tuesday, 26 February 2008

Psych Drug Shocker: Antidepressant Drugs Work No Better than Placebo; Big Pharma Hoax Finally Exposed (Westender, Brisbane headline)

Well, the shit has well and truly hit the fan, hasn't it? Fidders has done a lovely little round up of some of the mainstream press coverage, if you hadn't seen it, yet:

Any comment from MHRA or DOH?

However, Seroxat Secrets' treatment of the matter reminded me of my discussion with Richard Goldfinch. I made this comment, which just about sums up my feelings on the way that I have been bullshitted and misled, as I have tried to understand this grotesque and unseemly mess:

Sorry to go over old ground, but do you remember all the fun and games that I had with Dick Goldfinch? He told me that there was no definition of efficacy. He told me that it was not known how much more beneficial than placebo Seroxat was. He told me that it just was, and then he told me to “fuck off” (actually he told me that I was vexatious and that no further correspondence was being entered into with me on the subject of Seroxat, but the effect is much the same).

Well, now, it seems that NICE has a definition of efficacy: 3 Hamilton points more effective than placebo (as such, SSRIs, at 1.8 points, are a big pile of kak). Also, it seems that NICE knew about this 1.8 points.

Am I fucking missing something here? Why does the body that passes drugs for use on the NHS know about this stuff, when the body that licences drugs for use by hoi polloi seems to know absolutely FUCK ALL? I must be missing something, because that looks like one mega-sized cluster fuck, to me.

Matt

Saturday, 23 February 2008

Yellow Cards - Part II

To Phul, copied to Brown, Johnson and Vara:


Oh, and another thing, Mr Phul. How dare you tell me that the "benefits outweigh the risks," and that you are continually monitoring the safety profile of these drugs, when NICE, at least, already acknowledges (or should that be "recommends to doctors"?), that I could go for a run with some mates, or use psychotherapy, and experience the same level of improvement. That is the benefit of Seroxat, isn't it: 10 fucking Hamilton points, which may or may not be sustainable? You and your colleagues in the industry are pushing placebos with side effects, and that's the truth of the matter. I will not be made responsible for the fact that SSRIs are snake oil remedies, manufactured by charlatans, talked up by lackeys (KOLs), and prescribed by the medical equivalent of MacDonalds' counter staff.

The benefits did not outweigh the risks for me, Mr Phul. So kindly do not try to project your reality onto me. Is that clear? If you can be bothered, you will address my experience, and not try to reinforce the MHRA's beliefs (which appear to be skewed by its need to uphold the interests of the Worshipful Company), which run contrary to mine, on this point.

Best regards

Matthew Holford

Addendum:
The NICE reference is to the following document (see section 4.4): CG23 - Depression: Management of depression in primary and secondary care

Thursday, 21 February 2008

Yellow Cards

Too funny: this is a real bonus, because I wasn't expecting a reply to my original message. "The benefits outweigh the risks". Not for me, they fucking didn't, Mr Phul, and I would have appreciated being told that I could have had the benefits, without the risks, by exercizing for an hour, three times a week, or with psychotherapy. The MHRA's Great Words of Wisdom are in bold, as usual:


Dear Mr Phul,

Thank you for taking the time to respond, although it is something of a non-answer, from my perspective. SSRIs are a placebo substitute (given their level of efficacy), but have extreme side effects, which are acknowledged. It is regrettable that the Worshipful Company has chosen to profit from the fact that it is regarded as unethical to prescribe placebos.

Please do not express your regret at my experience. First, because you do not know what I have experienced (and thus you do not know what you are apologizing for), and second, because it is evident that you have no intention of seeking an understanding and making redress. What I experienced is not acceptable, irrespective of the pharmaceutical industry's lack of understanding of mental illness. The lack of concern that has been demonstrated subsequently, by all interested parties, merely suggests to me that not only are those parties determined to lock down their own position, but also to ensure that it is made clear to me that the only possible explanation for my experience is down to me. In other words, the MHRA, with others, is justifying what happened to me. I think you understand how I need to respond to that.

For the record, I do not accept that interpretation of events. Unpleasant as it is to conceive, the logical, alternative explanation for my experience is that the MHRA (and others), is incompetent. There are many factors that contribute to this being an reasonable alternative explanation, not least because it is apparently driven by the marketing concerns of the industry (which is itself marketing-led), that it purports to regulate. When an organization's culture is geared towards sales and marketing, compliance tends to go out of the window, in my experience.

When the MHRA speaks as freely to patients as it does to the companies it regulates, I will review my position. The problem is still Ms Raine's.

Best regards


Matthew Holford

********************************
Subject: Re: Yellow Cards
Date: Thu, 21 Feb 2008 13:43:13 +0000
From: [redacted]@mhra.gsi.gov.uk
To: [redacted]@hotmail.co.uk


Dear Mr Holford,

Thank you for your recent e-mail to Dr Raine regarding your concerns about fluoxetine and the side effects you experienced. I have attached a response to this message.

Kind regards

[redacted], BSc (Hons) Ph.D
Senior Pharmacovigilance Scientist
Vigilance and Risk Management of Medicines
Medicines and Healthcare products Regulatory Agency

Attachment:
Dear Mr Holford,

Thank you for your recent e-mail to Dr Raine regarding your concerns about fluoxetine and the side effects you experienced. I have been requested to reply on her behalf. I am sorry to hear of the problems you have had since taking this medicine.

I understand you have been in correspondence with other colleagues in the Agency and we have noted your concerns regarding the use of SSRIs and I would like to assure you that as with all medicines, the safety of fluoxetine is closely monitored by the Medicines and Healthcare products Regulatory Agency/Commission on Human Medicines to ensure that the benefits of this medicine outweigh any potential risks, and when evidence of a new safety issue comes to light, appropriate action is taken.

Thank you again for contacting us and taking the time to fill in a Yellow Card, your contribution to the scheme is important.

Yours sincerely

[redacted]
Senior Pharmacovigilance Scientist
Pharmacovigilance Information Unit
Vigilance and Risk Management of Medicines
Room 15-208
cc: [redacted], Pharmacovigilance Information Unit Manager


********************************
From: Matthew Holford
Sent: 18 February 2008 13:26
To: Raine, Dr June
Subject: Yellow Cards


Dear Ms Raine,

I understand that the following quotation is attributable to you:

"If you suspect that you have had a side-effect to your medicine, please tell us about it via the Yellow Card scheme."

I have filled out a Yellow Card report, as it happens, but I'll tell you about the side effect that I experienced consequent to using fluoxetine, too. It made me suicidal. I think it was the sense, as I paced in between my front room and kitchen, unable to settle, like a hunted animal (I believe this is known as akathasia), that it would never end. And that nobody cared, either. Do you care (servant) Raine? Really? How about you (servant) Texture? (servant) Johnson? (servant) Vara? Anybody? No, I didn't think so.

There: I've told you about it. Now, it's your problem.

Best regards


Matthew Holford

Monday, 18 February 2008

Fluoxetine

To the Ministry of Truth, at the MHRA, copied to Brown, Johnson and Vara:


Dear Sir or Madam,

It is my undertstanding, given previous correspondence with the MHRA, that there are three statutory criteria involved in the assessment of a drug for a marketing authorization. Those three criteria are efficacy, safety and quality.

A drug must, then, do the thing that is claimed, and that thing must be a benefit to the patient (efficacy). This benefit is then assessed against the safety of the drug. During this process, the nature of the condition is taken into consideration, and the less serious the condition is, the less tolerant the regulator will be of serious side effects. As such, a drug designed to treat a condition that is not life-threatening is unlikely to be licensed, if the side effects are life-threatening. This comparison between benefit and safety, I understand, is known as a risk:benefit analysis and the benefits must outweigh the risks, in order for the drug to be licensed. Finally, it has to be demonstrated that the drug can be produced to a consistently high standard (quality).

I would like to conduct my own risk:benefit analysis on fluoxetine, and I would like to use the MHRA's methodology, if it has one. Could you explain to me what the benefit of the drug is, please?

Best regards


Matthew Holford