Discussion Paper
Chapter 12
Dietary Supplements and
Over-the-Counter Drugs
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Drugs and food are similar in some respects
For example, both contain chemicals that interact with the body’s physiology
Dietary supplements may be thought of as drugs by consumers
Example: St. John’s Wort to improve mood
But they are legally classified as food products
There are important differences in the ways drugs and food are regulated
Dietary Supplements: Food or Drug?
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Defines a drug as
A product intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease
According to the Act, drugs must be shown to be
Safe when used as directed
Effective for their intended use
According to the Act, food products must be
Safe
Pure (unadulterated)
Not required to show that they are effective or provide any benefit
Food, Drug and Cosmetic Act
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Dietary Supplement Health and Education Act (DSHEA) of 1994
Passed in part due to pressure on Congress from the supplement industry
Industry wanted to limit FDA regulation
DSHEA made several important changes including
Redefinition of which substances could be dietary supplements
Redefinition of presumed safety
Vague health claims without proof were allowed
Regulation of Dietary Supplements
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DSHEA expanded the definition of supplements to include a variety of substances:
Vitamins and minerals
Herbs (whole, concentrates, and extracts)
Amino acids
DSHEA: Defining Dietary Supplements
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FDA can declare a dietary supplement to be unsafe or adulterated
only if it presents a significant or unreasonable risk of illness or injury
Ingredients already on the market at the time of the Act:
Considered safe enough to be sold unless the FDA can demonstrate a risk
Recent rules have emphasized safety
Good Manufacturing Practices rules
“Adverse Events Reporting” process
But the rules for supplements are still more lenient than those for drugs
DSHEA: Defining Safety
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Dietary supplements cannot claim to be a treatment for a disorder
Statements can be made about:
Beneficial effects on a structure or function of the body or on “well-being” in general
Sellers do not have to prove these claims
Only have to provide evidence that the claims are not false or misleading
Label must carry a disclaimer:
This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease
DSHEA: Supplement Labeling
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Boon:
Many more supplements on the market
Thus, consumers have more options
Cons:
Much less research available about safety and effectiveness
Supplements remain on the market until the FDA presents clear evidence of risk
Case study: Ephedra
a stimulant for weight loss
1994: First evidence of safety concerns published by FDA
However, it took 10 more years for FDA to compile evidence to get ephedra off the market
DSHEA: Boon or Threat to Consumers?
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2010: Introduced by Senator John McCain
Key innovations:
All manufacturers would have to register with FDA
Manufacturers would have to provide a complete list of ingredients
FDA could recall any ingredient they found to be unsafe
Outcome:
Dietary supplement industry mounted a campaign against the regulation
McCain withdrew the bill
Dietary Supplement Act
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Saint John’s wort
Hypericum perforatum
Used for centuries
Once thought to prevent possession by demons
Currently used as a potential treatment for both anxiety and depression
Some evidence supporting its use for depression
May interact with prescription drugs
so users should notify their physicians
Psychoactive Dietary Supplements
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SAMe
S-adenosyl-L-methionine
A naturally occurring substance found in the body
The active form of amino acid methionine
A possible antidepressant
Several studies indicate it is as effective as approved antidepressants
But many of the studies have not been well controlled
Psychoactive Dietary Supplements
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Ginkgo biloba
Long history of medical use in China
Active ingredients are unclear
Reduces blood clotting
May improve circulation
Potentially risky if used with aspirin or other drugs that reduce clotting
Psychoactive Dietary Supplements
Research suggests slight improvements in memory in some people
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Weight control products
People hoping to lose weight are the biggest dietary supplement market
Many different products
Like other supplements, no evidence of effectiveness is required
Example: Herbalife
Before the FDA banned ephedra, many original products contained this drug
Now many products contain large doses of caffeine
Herbalife reported $3.5 billion in worldwide sales in 2011
Psychoactive Dietary Supplements
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OTC drugs
Self-prescribed for treatment of self-diagnosed illnesses
Americans spend over $18 billion per year on OTC drugs
Americans self-treat four times as many health problems as doctors treat
Often with OTC drugs
Over-the-Counter (OTC) Drugs
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1962 Kefauver-Harris amendment required that all drugs be evaluated for safety and efficacy
FDA was charged with reviewing all OTC drugs currently on the market
An impossible task?
There were approximately 300,000 products
Solution: Only active ingredients were reviewed
The 300,000 individual products contain fewer than 1,000 total active ingredients
FDA Regulation of OTC Products
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GRAS (generally recognized as safe)
given currently available information, the ingredient is considered safe
Safe = a “low incidence of adverse reactions”
Note that no drug is entirely safe
GRAE (generally recognized as effective)
a reasonable expectation that the pharmacological effect of the drug will provide clinically significant relief
GRAHL (generally recognized as honestly labeled)
OTC Regulation: 3 Standards
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Consistent labels make it easier for consumers to compare products
Uniform labeling standards were adopted in 1997 to reduce consumer confusion
Layout, headings, and topics are consistent
Language has been made clearer and more concise
Less medical terminology
OTC Drug Labeling
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1938 Food, Drug, and Cosmetic Act
Established a classification of drugs that can be sold only by prescription
Possible differences between OTC and prescription drugs
Dosage: An OTC version of a drug may come in smaller doses
Chemicals: A prescription drug may contain a chemical not allowed for OTC sale due to potential toxicity
OTC vs. Prescription Drugs
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OTC Drug Review process:
FDA reviews products and may switch drugs to OTC status
Examples of drugs switched to OTC
ibuprofen (Advil: analgesic)
lansoprazole (Prevacid: heartburn)
fexofenadine (Allegra: antihistamine)
OTC vs. Prescription Drugs
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Stimulants
Only legal OTC ingredient is caffeine
Combinations of caffeine and other stimulants (e.g., ephedrine) are not allowed
Example: Vivarin
Sedatives and sleep aids
Early OTC sedatives and sleep aids
Combination of scopolamine (acetylcholine receptor blocker) and methapyrilene (antihistamine)
These were found to be unsafe
Brands changed active ingredients frequently
Current OTC drug is diphenhydramine (antihistamine)
Psychoactive OTC Drugs
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Weight-control products
1970s: phenylpropanolamine (PPA) was legal OTC
2000: FDA requested all companies to stop marketing products containing PPA
Concerns over safety and effectiveness of PPA
Currently, one FDA-approved weight-control OTC drug:
Orlistat (alli)
The weight-control market has shifted largely from OTC drugs to the less well regulated dietary supplements
Psychoactive OTC Drugs
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Two major classes of drugs to reduce pain:
Anesthetics reduce all types of sensation or block consciousness completely
Analgesics reduce pain selectively without causing a loss of other sensations
OTC analgesics include:
Aspirin
Acetaminophen
Ibuprofen
Experience of pain varies with:
personality, gender, time of day, and other factors
About 35 percent of patients obtain pain relief from placebo
People and Pain
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Chemical Name:
Acetylsalicylic Acid
Development:
Long historical use of teas and extracts of willow and poplar bark for pain relief
19th century: active ingredient (salicylic acid) identified, synthesized, and mass-produced
1898: Acetylsalicylic acid synthesized by Bayer
1915: Aspirin sold over the counter in tablet form
OTC Analgesics: Aspirin
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Analgesic
Effectively blocks mild-to-moderate somatic pain
Especially effective for headache and musculoskeletal pain
Antipyretic
Reduces fever
Causes vasodilation of peripheral blood vessels and increased perspiration
Anti-inflammatory
Reduces swelling, inflammation, and soreness
Used extensively for arthritis treatment
Aspirin: Therapeutic Use
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Inhibits blood platelet aggregation
Can cause bleeding problems for surgical patients
May prevent heart attacks and strokes by preventing clots in high-risk patients
Induces gastrointestinal bleeding
Reye’s syndrome
Rare but serious disease
Symptoms include disorientation, personality changes, lethargy, coma, and death
Almost all case occurred in people under age 20 who have had a viral illness such as influenza, or chicken pox
Aspirin: Effects and Risks
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Analgesic action:
Aspirin inhibits the synthesis of prostaglandins
Prostaglandins are local-acting hormones
Released when cell membranes are injured
Mediate pain in injured areas by sensitizing neurons to stimulation
Aspirin: Mechanism of Action
Antipyretic action:
Aspirin acts on prostaglandins involved in heat regulation
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Compared to aspirin:
As effective in analgesic and antipyretic effects
Less useful as an anti-inflammatory drug
Risks:
Overuse can cause serious liver disorders
DAWN data: acetaminophen has far surpassed aspirin for ER visits and deaths
FDA has limited the maximum single capsule amount to 650 mg for OTC products
OTC Analgesics: Acetaminophen
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Ibuprofen is a nonsteroidal anti-inflammatory drug (NSAID)
Effective as an analgesic and anti-inflammatory
Like aspirin, inhibits COX enzymes
Potential side effects
Nausea and stomach pain
Liver damage (if taken in large amounts)
OTC Analgesics: Ibuprofen
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All-too-common cold
Colds are viral infections
More than 100 have been identified
Symptoms include coughing, sneezing, and production of fluid by the mucous membranes
OTC Cold and Allergy Products
Virus transmission
Most cold viruses enter the body through the nose or eyes
Usually transmitted via an infected person’s hands
Frequent handwashing is a good strategy to reduce the risk of contracting a cold
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Cold symptoms can be treated, not cured
Modern cold remedies contain three common types of ingredients
Antihistamines for temporary relief of runny nose and sneezing
Also used for relief of allergy symptoms
Nasal decongestants for temporary relief of swollen nasal membranes
Analgesic-antipyretics for temporary relief of aches and pains and fever reduction
OTC Cold and Allergy Products
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Most products contain one or more of only a small number of ingredients, in different combinations
Thus, an informed consumer can understand a large proportion of these products by being familiar with only a few drugs
Single ingredient medications may be preferable to combination products
Avoid medication interactions and side effects
Avoid treating symptoms you may not have
Choosing an OTC Product
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