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As I have noted elsewhere (see Pan
Crisis), there is currently a world wide campaign to encourage
consumers to report the slightest adverse reaction to alternative
medicines, regardless of actual cause (1,2,3,4,5,6,7,8
- see also Dietary
Supplements). The TGA has again recently emphasised the need to report
suspected reactions to "complementary medicines" (10)
and these alleged safety concerns have been utilised to justify (see Pan
Crisis) the TGA's crackdown on alternative medicines (12).
The TGA's persistent determination to emphasise reactions to
"complementary medicines" and downplay reactions to
"drugs" or "all medicines", should be noted,
especially in view of the fact that the TGA considers complementary
medicines to be (11)
"low risk", a fact which was confirmed by Professor Dwyer
who describes such medicines as (13) "usually harmless".
Since "low risk" is a relative term it is abundantly
clear that there are also other medicines which are "high risk".
These of course, are the pharmaceutical drugs, the medicines which the TGA
seems to show least interest in.
The safety of alternative medicine has been further stressed by the
bible of sceptics and scepticism, the Skeptics Dictionary (14):
| "the risks of being positively harmed by an
"alternative" practitioner such as homeopath, for
example, are negligible when compared to the risks of being harmed
by a conventional physician dispensing powerful drugs and
performing risky surgeries......... 'Alternative' medical
treatments are essentially non-interventionist and their risks are
generally negative, not positive." |
Since, not surprisingly, adverse reactions to high
risk pharmaceutical drugs
outnumber reactions to alternative medicines by around 98 to 2 ( see Response
to the Report of the Expert Committee, Holistic
Medicine Sets the Standard for Safety), this concern about low risk
alternative
medicines is clearly not motivated by public health considerations. If our
concerns are confined to public health considerations then we should
consider first those products which pose the greatest risk. Pharmaceutical drugs of course,
unlike low risk alternative medicines, are classified under the Poisons
Schedule. Sudden
concerns about the safety of low risk alternative medicines, while not related to public
health, do correlate very strongly with moves to justify a
takeover of the industry by the medico-pharmaceutical juggernaut (see Pan
Crisis). According to Geraldine Moses of the Pharmaceutical
Society of Australia, changes to the alternative medicine industry are
usually brought about by complaints and adverse reaction reports (2):
| "The way the Complementary Medicine
industry is regulated in Australia, it is only through such
complaints or adverse reaction reports that changes in the
industry are activated." |
One can appreciate the considerable dilemma facing those with a vested
interest in the drug industry and their political servants. Since changes
only result from adverse reaction reports, how can they possibly justify a
financial takeover of products which, at their worst, are hundreds of
times safer than the drugs which they peddle everyday? The answer is
simple. Convince consumers that all adverse reactions are due to
the lowest risk and most harmless products.
In the rush to convince consumers of the dangerous nature of low risk usually harmless
alternative medicines it has been declared that the precise cause of any
apparent adverse reaction is unimportant (see Pan
Crisis):
| "according to orthodox medicine's
definition, when it comes to alternative therapies an adverse
event is an adverse event 'whether or not it is confirmed to be
related to the therapy'(7,8)." |
Given the current medical obsession with reporting adverse reactions to
low risk usually harmless alternative medicines, and in view of the infinitely greater risks posed
by the use of high risk pharmaceutical drugs (see Holistic
Medicine Sets the Standard for Safety), it is vitally important that we
concentrate first and foremost on these much more dangerous and toxic
pharmaceutical products. Since 90%-99% of adverse drug reactions are never
reported (see Holistic
Medicine Sets the Standard for Safety) it is abundantly clear that the
current reporting system is an abject failure, a fact which clearly gives
public health authorities a very dangerous and disturbing false impression
about the dangers of pharmaceutical drugs. Since doctors are very
reluctant to report adverse drug reactions (see Holistic
Medicine Sets the Standard for Safety), public health authorities such
as the TGA can only be correctly
informed about drug reactions if there is widespread consumer
participation in the reporting process.
As I have stated elsewhere (see Pan
Crisis):
| "Reporting of significant adverse prescription drug reactions
should be compulsory and failure to do so should incur very heavy
penalties. Unless this is done, the full magnitude of this problem will
remain unknown." |
Recently I had an opportunity to assess first hand the effectiveness of
the adverse drug reactions reporting system in Australia.
After taking the blood pressure drug candesartan for some time,
suddenly, and quite dramatically, my elderly mother experienced acute
swelling around the face and mouth. An urgent trip to the local GP
resulted in a diagnosis of angioedema due to candesartan, a reaction
which, according to the GP is not too uncommon. Amazingly, according to
the doctor, this type of reaction to candesartan commonly continues for
six months or more after the medication is discontinued, a fact which was
subsequently confirmed by various other doctors.
| Here we have a drug which
may cause potentially life threatening reactions even six months
after it has been discontinued and yet the TGA continues to
approve its use. Apparently the TGA can see no reason why this
drug should be withdrawn from sale. It seems even a media alert or
public warning is deemed unnecessary. Apparently the TGA considers
the safety and
toxicity of this drug to be quite acceptable, unlike dangerous low
risk alternative medicines. But then again, no legislative
changes are sought regarding drugs whereas the dramatic changes
required in the alternative medicine industry necessitates the
manufacture of numerous averse reaction reports. |
After administering further drugs to counter this adverse reaction and advising
her to immediately discontinue candesartan, the doctor gave us specific
instructions to immediately attend hospital if there was any
deterioration, especially swelling in the throat. About one hour later the
throat did begin to swell and necessitated a trip to hospital.
The swelling soon began to subside however, and she was discharged a few
hours later. Doctors at the hospital confirmed the initial diagnosis.
Two weeks after discontinuing the drug she experienced the same
reaction and was taken to hospital again with the same diagnosis
and result. A further three weeks later, or five weeks after discontinuing
the drug, she experienced yet another reaction and was rushed to a
different hospital. This third reaction was by far the worst with extensive internal
swelling in the throat which made talking and swallowing virtually
impossible and breathing was impeded to the degree that oxygen and
adrenalin had to be administered. The diagnosis was the same.
Considering my responsibility to report this reaction, especially given
the current environment regarding reporting of reactions to low risk
alternative
medicines, I decided to report this matter to the Adverse
Drug Reactions Unit of the TGA. One of the advantages of reporting
this reaction would be that it would give me the opportunity to observe
first hand the effectiveness of the TGA's drug monitoring and safety
system. I would be able to assess how effective the reporting system
actually is when it comes to life threatening reactions to drugs as
distinct from reactions to low risk alternative medicines.
I initially reported these reactions using the TGA's
online reporting system followed up by facsimile reports. During my
subsequent communication with the Adverse Drug Reactions Unit (ADRU) of
the TGA some rather surprising and disturbing facts began to emerge.
Firstly, I found it rather difficult to obtain definite statements from
the ADRU regarding whether or not the various doctors and hospitals
involved in my mother's case had actually submitted adverse reaction
reports. At first this question was completely ignored. In a subsequent
communication I made the following response to the TGA:
| "my attempt to ascertain if the adverse
reactions experienced by my mother had actually been reported to
the TGA by the doctors and hospitals involved was completely
ignored by you. This is an extraordinarily simple question for you
to answer but yet you decided, for some reason, to completely
ignore this whole matter. I reiterate this query:*
Did the doctors and hospitals involved in these incidents
submit adverse reaction reports to the TGA and how long after the
incidents did you receive these reports."
*(this paragraph from my correspondence is the "Paragraph
2" referred to below.) |
I received the following response to this query from the ADRU:
| "In regard to the 'extraordinarily simple'
question that you have complained about, specifically with trade
name Atacand Plus the Adverse Drug Reactions Unit has received 2
other reports. ADRAC publicised this reaction in February 1999." |
This incredible reluctance to provide a specific answer to my query is
of course an answer in itself. The TGA's drug reaction reporting system is
obviously a complete sham and is in keeping with estimates that up to 99%
of drug reactions, even life threatening reactions, are unreported. What
is most disturbing however, is the obvious evasiveness of our national
drug regulatory body and public health watchdog, the TGA. Why would they
seek to conceal whether or not an incident had been reported? What do they
feel is to be gained by such evasiveness? Are not public health and drug
safety the primary considerations? But perhaps even more disturbing
is the fact that the ADRU found my query to be so difficult to cope with that they
terminated any further correspondence about the matter. According to the
ADRU:
| "Paragraph 2* of your further letter is at
least impolite, and no further correspondence will be entered into
by the Adverse Drug Reactions Unit."
*(paragraph 2 from my letter has been cited above) |
This really is absolutely astonishing. Our national regulatory
authority and public health watchdog is so incapable or unwilling to
respond to queries about adverse drug reaction reports that they simply
refuse point blank to communicate. This surely is the absolute height of
evasiveness. But why? Are we expected to believe that members of ADRAC are
so emotionally hypersensitive that they cannot cope with simple queries
about adverse reaction reports. Or is there a more sinister motive for
their response? Are they attempting to conceal the fact that the whole
adverse drug reaction reporting system is a sham, a fact which would also mean that
the TGA has absolutely no idea of the true extent of adverse reactions in
Australia?
I should not be surprised. As I have noted elsewhere (see Pan
Crisis):
| "Sadly, if you happen to become a victim of
a serious adverse drug reaction, history shows that the medical
profession and the pharmaceutical industry will seek to frustrate
your every attempt to obtain not only justice or compensation, but
also recognition............ There will likely be little or no
concern about those who suffer an adverse drug reaction or about
the implications of such reactions as far as public health is
concerned. We can see a clear example of this with the Travacalm
incident. On the other hand it seems, if you suffer a significant
adverse reaction to an alternative medicine you will be welcomed -
and the implications for public health will likely become headline
material." |
What is most insulting about the attitude of the TGA and the
government is that they apparently believe that the intelligence of the
general community is such that they may be persuaded that they must be
urgently protected from the safest or lowest risk medicines on the
market. When drugs such as hyoscine hydrobromide in Travacalm are
shown to be toxic (see Pan
Crisis), we are expected to believe that we must be urgently protected
from the sale of 'dangerous' vitamins and nutritional supplements, the clear
inference being that this will protect us from dangerous pharmaceutical
drugs. It is all for our own good. As medical experts (who increasingly
take supplements themselves) increasingly confirm that those who do not
take nutritional supplements are increasing their risk of suffering
serious or fatal chronic diseases (see Health
News and Links, Alternative
Medicine Inquiry, Pan
Crisis), the TGA expects the community to believe they must be
protected from these dangerous lifesaving supplements. They
really do have an amazingly low opinion of the intelligence of the general
public and the alternative health community. It is also astonishing that our public health
watchdog and regulatory authority is asking the
alternative health industry, and the wider community, to accept
blanket reforms to a complete heterogenous group of products as though
they are one and as though the 'scientific evidence' applies equally and
identically to all of them. Never before has the public been treated with
such contempt. Do the authorities intend in future to take action against
ALL pain killers or ALL anti-inflammatories? Or will ALL drugs be banned
when a serious adverse reaction is reported? Or perhaps a radically
different set of rules apply to highly profitable high risk pharmaceutical
drugs. The more profit, the fewer rules? It is difficult
indeed to imagine a more preposterous double standard and insult to the
collective intelligence of the community. This is simply a deliberate move
to deceive the public by manufacturing false public health concerns to
justify legislative changes aimed at enabling drug companies to take
financial control of the alternative medicine industry. It is a
clear abandonment of honesty, integrity and public health in the interests
of profit. If public authorities are
permitted to successfully perpetrate this incredible fraud then clearly
their future behaviour can be expected to degenerate to an even lower
level.
It is abundantly clear that if our
current adverse reaction reporting system is to be even remotely effective
then it will depend very heavily indeed on extensive public participation
in the reporting process. Unless this occurs, then clearly, regulatory and
public health authorities will remain blissfully unaware of the myriad of
adverse reactions which are experienced everyday. Appropriate health care
reforms cannot occur in such a situation of ignorance. Since our health
care system is strongly dependent upon public participation in the
reporting process I urge everyone to report any and all adverse drug
reactions to the Adverse
Drug Reactions Unit of the TGA. As is emphasised by the TGA, the
monitoring of drug safety in Australia can only be carried out effectively
if all significant adverse reactions are reported (9).
| "In Australia, adverse reaction reporting is
coordinated by the Adverse Drug Reactions Unit (ADRU) at the
Therapeutic Goods Administration (TGA).
The system for monitoring adverse reactions in Australia is by
voluntary reporting by health professionals and consumers. When a
health professional or consumer suspects an adverse reaction to a
medicine has occurred, they can report it directly to the Adverse
Drug Reactions Advisory Committee (ADRAC) using a "blue
card".
All reports are individually reviewed by medical and
professional staff." |
The TGA emphasises that all suspected adverse reactions should
be reported, including reactions to prescription drugs although they avoid
any specific mention of these (10):
"What to report?
(you do not need to be certain, just suspicious!)
ADRAC encourages the reporting of all suspected
adverse reactions to medicines, including vaccines, OTC medicines,
herbal, traditional or alternative remedies". |
To report adverse reactions follow the guidelines provided by the TGA (10):
"For blue cards
Reports of suspected adverse drug reactions are best made by
using a prepaid
reporting form ("blue card") which is available from
at the front of the "Schedule of
Pharmaceutical Benefits" and the "Australian
Medicines Handbook", from the Adverse Drug Reactions
Unit (02 6232 8386), or from this website.
Reports can also be submitted electronically, by clicking on
"Adverse
Drug Reaction Reporting" on this website.
Further information can be obtained from the ADRAC
Secretariat:
Phone: 1800 044 114
Fax: 02 6232 8392
Email: adrac@health.gov.au
(Problems with therapeutic devices should be reported on
1800 809 361)" |
If you wish to maximise the efficiency of Australia's drug
monitoring system then make sure you double check with the ADRU to ensure
that the doctors and/or hospitals involved in your particular case also
submitted reports along the same lines.
As is so often stated in regard to politics, we get the system we
deserve. The same also holds true for our health care system. Unless we
all actively participate we will continue to get the health care system we deserve. |
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References
1. http://www.ama.com.au/web.nsf/doc/SHED-5FK4YN/$file/healths_gd_p
See: AMA Position Statement on Complementary Medicine, 2002.
2. http://web.archive.org/web/20030608102915/http://www.abc.net.au/public/s84
See: Geraldine Moses, spokeswoman for the Pharmaceutical Society of
Australia, Drug recall should be used as industry wake-up call,
Public Record, ABC, 8th June, 2003.
3. http://www.soaringspiritwithtears.com/healthcare/rebuttal.html
4. http://www.soaringspiritwithtears.com/healthcare/regulations.html
5. http://www.cspinet.org/reports/wh_statement020702.html
See: Bruce Silverglade, Director of Legal Affairs, Comments on the Draft
Recommendations of the White House Commission on Complementary and
Alternative Medicine that Pertain to Dietary Supplements, 7th Feb., 2002.
6. http://www.ama.com.au/web.nsf/doc/WEEN-5GB44J
See: Speech to the Natural and Complementary Healthcare Summit Canberra, 1
March 2001 President of the AMA, Dr Kerryn Phelps.
7. http://apsu.inopsu.com/cam2001.pdf
See: Dr Mike South, et al, Adverse Effects Associated with the use of
Complementary or Alternative Medicine, Australian Paediatric Surveillance
Unit, 2001.
8. http://apsu.inopsu.com/CAMprotocol.pdf
See: Dr Mike South, et al, Adverse Effects Associated with the use of
Complementary or Alternative Medicine, Australian Paediatric Surveillance
Unit, 2001.
9. http://www.tga.gov.au/adr/adrfaq.htm
See: Adverse drug reactions: frequently asked questions, TGA.
10.http://www.tga.gov.au/adr/aadrb/aadr0502.htm
See: Australian Adverse Drug Reactions Bulletin, Volume 24, Number 1,
February 2005, TGA.
11.http://www.tga.gov.au/docs/pdf/cmfact3.pdf
See: Complementary Medicines Explained, Fact Sheet, TGA.
12.http://www.tga.gov.au/cm/cmresponse.htm
13.Dwyer, J., Doctors and Chemists should tell the Truth about Natural
Medicines, Sydney Morning Herald, p17, 1st May 2003.
14.http://skepdic.com/althelth.html
See: Robert Todd Carroll, Robert T. Carroll, The Skeptic's Dictionary,
Wiley; 1st edition August 15, 2003.
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