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                DEPARTMENT OF HEALTH AND HUMAN SERVICES

 

                      FOOD AND DRUG ADMINISTRATION

 

                CENTER FOR DRUG EVALUATION AND RESEARCH

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                          JOINT MEETING OF THE

 

           CDER PSYCHOPHARMACOLOGIC DRUGS ADVISORY COMMITTEE

 

                                AND THE

 

                    FDA PEDIATRIC ADVISORY COMMITTEE

 

 

 

 

 

 

 

 

 

 

 

                       Monday, September 13, 2004

 

                               8:00 a.m.

 

 

 

                          Holiday Inn Bethsda

                         8120 Wisconsin Avenue

                           Bethesda, Maryland

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                              PARTICIPANTS

 

      PSYCHOPHARMACOLOGIC DRUGS ADVISORY

        COMMITTEE MEMBERS:

 

        Wayne K. Goodman, M.D., Chair

        Jean E. Bronstein, R.N., M.S.

          (Consumer Representative)

         James J. McGough, M.D.

         Philip S. Wang, M.D., M.P.H., Dr.P.H.

         Lauren Marangell, M.D.

         Dilip J. Mehta, M.D., Ph.D.

           (Industry Representative)

         Delbert G. Robinson, M.D.

         Daniel S. Pine, M.D.

         Barbara G. Wells, Pharm.D.

         Bruce G. Pollock, M.D., Ph.D.

 

      PEDIATRIC ADVISORY COMMITTEE MEMBERS:

 

         P. Joan Chesney, M.D., Chair

         Deborah L. Dokken, M.P.A.

         Michael E. Fant, M.D., Ph.D.

         Richard L. Gorman, M.D.

         Robert M. Nelson, M.D., Ph.D.

         Thomas B. Newman, M.D., M.P.H.

         Judith R. O'Fallon, Ph.D.

         Victor M. Santana, M.D.

 

      CONSULTANTS AND GUESTS (Voting):

 

         Norman Fost, M.D., M.P.H.

         Charles E. Irwin, Mr., M.D.

         Laurel K. Leslie, M.D., F.A.A.P.

         Steven Ebert, Pharm.D. (Consumer Representative)

         James M. Perrin, M.D.

         Cynthia R. Pfeffer, M.D.

         Gail W. Griffith

           (Patient Representative, Voting)

         Robert D. Gibbons, Ph.D.

         Tana A. Grady-Weliky, M.D.

         Richard P. Malone, M.D.

         Irene E. Ortiz, M.D.

         Matthew V. Rudorfer, M.D.

                                                                 3

 

                        PARTICIPANTS (Continued)

 

      GUEST SPEAKERS AND GUESTS (Non-Voting):

 

         Kelly Posner, Ph.D.

         John March, M.D., M.P.H.

         Samuel Maldonado, M.D., M.P.H.

           (Industry Representative

         Barbara Stanley, Ph.D.

         Madelyn Gould, Ph.D., M.P.H.

 

      FDA PARTICIPANTS:

 

         Robert Temple, M.D.

         Russell G. Katz, M.D.

         Thomas Laughren, M.D.

         M. Dianne Murphy, M.D.

         Anne Trontell, M.D., M.P.H

         Anuja M. Patel, M.P.H., Executive Secretary

                                                                 4

 

                            C O N T E N T S

 

      Call to Order and Opening Remarks,

         Wayne Goodman, M.D.                                     6

 

      Introduction of Committee                                  9

 

      Conflict of Interest Statement,

         Anuja Patel, M.P.H.                                    20

 

      Overview of Issues:

         Dianne Murphy, M.D., Director, Office of

           Pediatric Therapeutics,

           Office of the Commissioner                           25

 

         Russell Katz, M.D., Director, Division of

           Neuropharmacological Drug Products,

             DNDP, CDER                                         34

 

      Regulatory History and Background,

         Thomas Laughren, M.D., Team Leader, DNDP, CDER         46

 

      Recent Observational Studies of Antidepressants

        and Suicidal Behavior,

         Diane Wysowski, Ph.D., Division of Drug Risk

           Evaluation, Office of Drug Safety, CDER              62

 

      Brief Report on TADS Trial,

         John March, M.D., M.P.H., Duke University              74

 

      Committe Discussion on TADS Trial                         93

 

      Characteristics of Pediatric Antidepressant Trials,

         Greg Dubitsky, M.D., Medical Officer,

           DNDP, CDER                                          107

 

      Classification of Suicidality Events,

         Kelly Posner, Ph.D., Columbia University              117

 

      OCTAP Appraisal of Columbia Classification

        Methodology,

         Solomon Iyasu, M.D., M.P.H., Team Leader,

           Office of Counter-Terrorism and Pediatric

             Drug Development                                  140

                                                                 5

 

                      C O N T E N T S (Continued)

 

      Results of the Analysis of Suicidality in Pediatric

        Trials of Newer Antidepressants,

         Tarek Hammad, M.D., Ph.D., M.Sc., M.S., Senior

           Medical Reviewer, DNDP, CDER                        152

 

      Comparison Between Original ODS and DNDP Analyses

        of Pediatric Suicidality Data Sets,

         Andrew Mosholder, M.D., M.P.H., Division of

           Drug Risk Evaluation, ODS, CDER                     200

 

      Citalopram and Escitalopram Product Safety Data,

         Jeffrey Jonas, M.D., Forest Laboratories, Inc.        219

 

      Sertraline Use in Pediatric Population: A

      Risk/Benefit Discussion,

        Steven J. Romano, M.D., Pfizer, Inc.                   232

 

      Wyeth Pharmaceuticals, Joseph S. Camardo, M.D.           247

 

      Open Public Hearing                                      255

 

      Summary by the Committee Chair                           444

 

                                                                 6

 

                         P R O C E E D I N G S

 

                   Call to Order and Opening Remarks

 

                DR. GOODMAN:  I wish to welcome you to

 

      this two-day joint session of the

 

      Psychopharmacologic Drugs Advisory Committee and

 

      the Pediatric Advisory Committee, being held on

 

      September 13th and 14th here, at the Holiday Inn in

 

      Bethesda, Maryland.

 

                I am Wayne Goodman, Professor of

 

      Psychiatry at the University of Florida, today

 

      wearing my hat as chair of the advisory committee.

 

      As you settle in, please take this opportunity to

 

      put into silent mode your cell phones and any other

 

      devices that emit sounds in the audible range of

 

      human beings.

 

                Some of you may be surprised not to see

 

      Matt Rudorfer in this seat but we arm-wrestled for

 

      the position and he won.

 

                [Laughter]

 

                In all seriousness, his term has ended but

 

      we are fortunate to see him return as a voting

 

      consultant to the committee.

 

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                I have some official language to read to

 

      you.  All committee members and consultants have

 

      been provided with copies of the background

 

      materials, from both the sponsors and the FDA, and

 

      with copies of letters from the public that we

 

      received by the August 23rd deadline.  The

 

      background materials have been posted on the FDA

 

      website.  Copies of all these materials are

 

      available for viewing at the FDA desk outside this

 

      room.

 

                We have a very large table, a full house

 

      and important topic today so I would like to start

 

      with a few rules of order.  Please speak directly

 

      into the mike when called on.  We will be keeping

 

      track of individuals at the table who wish to speak

 

      and we will call upon them in order.

 

                FDA relies on the advisory committee to

 

      provide the best possible scientific advice

 

      available to assist us in the discussion of complex

 

      topics.  We understand that issues raised during

 

      the meeting may well lead to conversations over

 

      breaks or during lunch.  However, one of the

 

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      benefits of an advisory committee meeting is that

 

      the discussions take place in an open and public

 

      forum.  To that end, we request that members of the

 

      committee not engage in off-record conversations on

 

      today's topic during the breaks and lunch.

 

                Whenever there is an important topic to be

 

      discussed there are a variety of opinions.  One of

 

      our goals today and tomorrow is for the meeting to

 

      be conducted in a fair and open way where every

 

      participant is listened to carefully and treated

 

      with dignity, courtesy and respect.  Anyone whose

 

      behavior is disruptive to the meeting will be asked

 

      to leave.  We are confident that everyone here is

 

      sensitive to these issues so understand that these

 

      comments are as a gentle reminder.

 

                We look forward to a productive and

 

      interesting meeting.  This is an unusual meeting in

 

      that we have two advisory committees represented

 

      here, Psychopharmacological Drugs Advisory

 

      Committee, chaired by myself, and the Pediatric

 

      Advisory Committee, chaired by Joan Chesney, to my

 

      left.  We will now go around the table and have the

 

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      committee introduce themselves, starting on my

 

      right.  Please indicate your expertise and

 

      affiliation.  We will start in that corner, over

 

      there.

 

                             Introductions

 

                DR. TEMPLE:  Bob Temple.  I am the Office

 

      Director, ODE I.

 

                DR. KATZ:  Russ Katz, Division Director,

 

      Division of Neuropharmacological Drug Products,

 

      FDA.

 

                DR. LAUGHREN:  Tom Laughren, phychopharm.

 

      team leader, in the Neuropharmacological Division.

 

                DR. MURPHY:  Dianne Murphy, Office

 

      Director, Office of Pediatric Therapeutics.

 

                DR. TRONTELL:  Anne Trontell, Deputy

 

      Director, Office of Drug Safety.

 

                DR. FANT:  I am Michael Fant, University

 

      of Texas Health Science Center in Houston.  My

 

      expertise is neonatology and biochemistry.

 

                DR. PFEFFER:  Cynthia Pfeffer.  I am a

 

      child psychiatrist at Weill Medical College of

 

      Cornell University, and I have expertise in

 

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      depression suicidal behavior in children and

 

      adolescents.

 

                DR. FOST:  Norm Fost, University of

 

      Wisconsin, Professor of Pediatrics, Director of the

 

      Bioethics Program and Chair of the IRB.

 

                DR. ORTIZ:  Irene Ortiz, University of New

 

      Mexico, Albuquerque VA.  My expertise is in

 

      depression in the elderly.

 

                DR. MALONE:  Richard Malone, Drexel

 

      University College of Medicine, and my area is

 

      child psychiatry.

 

                DR. NELSON:  Robert Nelson, Children's

 

      Hospital of Philadelphia and the University of

 

      Pennsylvania.  My expertise is in pediatric

 

      critical care medicine and ethics.

 

                DR. PERRIN:  Jim Perrin, Professor of

 

      Pediatrics, Harvard Medical School and Head of the

 

      Division of General Pediatrics at the Mass. General

 

      Hospital.  I have shortened my expertise as being

 

      in general pediatrics.

 

                DR. GRADY-WELIKY:  Tana Grady-Weliky,

 

      Associate Professor of Psychiatry at the University

 

                                                                11

 

      of Rochester School of Medicine and Dentistry.  My

 

      expertise is in mood disorders and women across the

 

      reproductive life cycle and medical education.

 

                DR. EBERT:  Steven Ebert, Department of

 

      Pharmacy of Meriter Hospital and School of

 

      Pharmacy, University of Wisconsin, Madison.

 

                DR. GIBBONS:  Robert Gibbons, Professor of

 

      Statistics and Professor of Psychiatry and Director

 

      of the Center for Health Statistics at the

 

      University of Illinois, Chicago.  I only do math!

 

                DR. PINE:  Danny Pine, child and

 

      adolescent psychiatrist, National Institute of

 

      Mental Health intramural research program.  I am a

 

      clinical child psychiatrist.

 

                MS. BRONSTEIN:  Jean Bronstein,

 

      psychiatric nurse, Stanford University Hospital,

 

      the consumer representative.

 

                DR. RUDORFER:  Matthew Rudorfer, National

 

      Institute of Mental Health.  My areas of expertise

 

      are mood disorders and psychopharmacology.

 

                MS. PATEL:  Anuja Patel, Advisors and

 

      Consultants Staff, Executive Secretary for the

 

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      Psychopharmacologic Drugs Advisory Committee.

 

                DR. CHESNEY:  Joan Chesney, the University

 

      of Tennessee, in Memphis, and Professor of

 

      Pediatrics, and my specialty is infectious

 

      diseases.

 

                DR. MCGOUGH:  Jim McGough, Professor of

 

      Psychiatry, UCLA.  My area is child and adolescent

 

      psychopharmacology.

 

                MS. GRIFFITH:  My name is Gail Griffith

 

      and I serve as the patient rep. on this committee,

 

      and I would just like to take this opportunity to

 

      say why I am here.  First, I am not a medical

 

      professional; I am a consumer.  I have suffered

 

      from major depression since I was a teen.  Second,

 

      I have a son who suffers from major depression and

 

      three years ago, at age 17, after he was diagnosed

 

      and placed on a regimen of antidepressants he

 

      attempted suicide by overdosing intentionally on

 

      all his medications.  He nearly died.  So, I know

 

      this illness.  I know what it does to adolescents.

 

                For the record, I would simply like to

 

      state that I have no professional ties to any

 

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      advocacy group or any patient constituency.  I also

 

      wish to affirm that I have no ties to any

 

      pharmaceutical company, nor do I hold any

 

      investments in pharmaceutical manufacturers.  My

 

      sole responsibility is to ensure that the interests

 

      of concerned parents and families are represented

 

      at this meeting.

 

                DR. MARANGELL:  Lauren Marangell, Baylor

 

      College of Medicine.  I specialize in adult

 

      interventions in mood disorders, both unipolar and

 

      bipolar.

 

                DR. ROBINSON:  I am Delbert Robinson.  I

 

      am from the Albert Einstein College of Medicine, in

 

      New York, and I specialize in psychotic disorders

 

      and anxiety disorders.

 

                DR. LESLIE:  Laurel Leslie.  I am a

 

      behavioral developmental pediatrician at Children's

 

      Hospital, San Diego and my area of expertise is in

 

      children's mental health services research.

 

                DR. IRWIN:  Charles Irwin.  I am a

 

      professor of pediatrics at the University of

 

      California, San Francisco.  I am in charge of the

 

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      Division of Adolescent Medicine at the University,

 

      which is a multi-disciplinary program that cares

 

      for adolescents and trains large numbers of

 

      individuals caring for teenagers, and my research

 

      is in the area of risk-taking during adolescence.

 

                MS. DOKKEN:  I am Deborah Dokken.  I

 

      reside in the Washington, D.C. Metro area.  I do

 

      not have a specific institutional affiliation, and

 

      I have for several years been involved in parent

 

      and family advocacy and health care.

 

                DR. NEWMAN:  I am Thomas Newman.  I am a

 

      professor of epidemiology and biostatistics in

 

      pediatrics at the University of California, San

 

      Francisco, and a general pediatrician.

 

                DR. WELLS:  I am Barbara Wells.  I am a

 

      professor and Dean of the School of Pharmacy at the

 

      University of Mississippi.  My expertise is in

 

      psychiatric pharmacotherapy.

 

                DR. POLLOCK:  I am Bruce Pollock.  I am a

 

      professor of psychiatry, pharmacology and

 

      pharmaceutical sciences at the University of

 

      Pittsburgh.  I head the Division of Geriatric

 

                                                                15

 

      Psychiatry at the university.

 

                DR. O'FALLON:  Judith O'Fallon, Emeritus

 

      Professor of Biostatistics from the Mayo Clinic,

 

      with 30 years of experience particularly in cancer

 

      clinical trials but clinical trials methods.

 

                DR. SANTANA:  Good morning.  I am Victor

 

      Santana.  I am a pediatric hematologist/oncologist

 

      at St. Jude's Children's Research Hospital in

 

      Memphis, Tennessee.

 

                DR. WANG:  I am Philip Wang, Harvard

 

      Medical School.  I am a psychiatrist and

 

      epidemiologist and those are my areas of expertise.

 

                DR. GORMAN:  Richard Gorman, a practicing

 

      pediatrician for 20 years in the Baltimore suburbs,

 

      Chair of the American Academy's Committee on Drugs,

 

      and representing the American Academy of Pediatrics

 

      at this table.

 

                DR. MALDONADO:  Sam Maldonado.  I work at

 

      pediatric drug development at Johnson & Johnson.  I

 

      am one of the industry representatives to this

 

      committee.

 

                DR. MEHTA:  Dilip Mehta, retired industry

 

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      executive and industry representative on the

 

      Psychopharmacologic Drugs Advisory Committee.

 

                DR. GOODMAN:  Thank you, all, for being

 

      with us these two days.  Our session today is the

 

      second of two planned advisory committee meetings,

 

      convened to address recent concerns about reports

 

      of suicidal ideation and behavior developing in

 

      some children and adolescents during treatment of

 

      depression with a selective serotonin reuptake

 

      inhibitor, an SSRI, or other newer generation

 

      antidepressants.  Our goal is to gather information

 

      from a variety of sources and perspectives to help

 

      us understand this complex situation, and

 

      ultimately to offer the best possible

 

      recommendations to the FDA.

 

                I would like to thank the many groups,

 

      individuals and families that submitted written

 

      statements in advance of the meeting, many of which

 

      were quite informative as well as moving.  A major

 

      portion of today's meeting will be devoted to a

 

      four-hour open public hearing during which dozens

 

      of people from around, and even beyond, the country

 

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      will have the opportunity to present their own

 

      personal or professional experiences and ideas

 

      about the relative risks and benefits of

 

      antidepressant medication in children and

 

      adolescents.  Although the necessary consideration

 

      of the clock will permit only a short time at the

 

      microphone for each speaker, I can assure you that

 

      the committee welcomes and values input from all

 

      viewpoints and feels it is essential to our work

 

      that all voices be heard.

 

                The committee's task is more difficult

 

      than usual.  Our review is not confined to whether

 

      one agent is safe and effective based upon the

 

      corresponding clinical trials submitted to the FDA.

 

      We are faced, instead, with assessing efficacy and

 

      safety for nine drugs that represent more than one

 

      chemical class of antidepressants, all of which are

 

      already available on the market.

 

                Although the cornerstone of the data under

 

      examination is derived from randomized clinical

 

      trials submitted to the FDA this time, following a

 

      reclassification of the adverse events, we find

 

                                                                18

 

      ourselves turning to information from a wide

 

      variety of sources, in particular to inform

 

      ourselves about the drugs' possible benefits in

 

      this population.  However, once we open our minds

 

      to consideration of data originating outside

 

      randomized clinical trials we rest upon a slippery

 

      slope in which variations in interpretation are

 

      introduced according to the weighting each member

 

      places on the merits of the source.

 

                For me, the difficulty in assessing the

 

      balance between benefit and risk is multiplied by

 

      the nature of the adverse events under scrutiny.

 

      Psychiatrists grapple, for the most part, with

 

      illnesses that produce significant morbidity and

 

      more rarely mortality except from suicide.  Nothing

 

      in my experience is more tragic than the loss of a

 

      child to suicide.  To think that I might prescribe

 

      an agent that contributed to that outcome is

 

      unbearable.  Equally unbearable is to think that I

 

      did not do enough to prevent it.  This is the

 

      essence of the dilemma before us.

 

                We may not have all the data we would

 

                                                                19

 

      like, especially to assess long-term benefit.  We

 

      can make recommendations about what research should

 

      be conducted, but we will be faced at the

 

      conclusion of business tomorrow to make

 

      recommendations based upon what we know at this

 

      cross-section in time.  In deliberating on the

 

      safety of antidepressant treatment in children, let

 

      us not forget the toxicity of the underlying

 

      disease.  Major depression remains an

 

      under-diagnosed, under-studied and under-treated

 

      serious disorder among many thousands of our

 

      nation's youth, leading to considerable suffering,

 

      disability and heartbreak in many families.

 

                I believe that all of us in this room

 

      share the desire to alleviate the suffering from

 

      this disorder through the successful use of

 

      interventions that are made available to all those

 

      who need them.  Despite the daunting task before

 

      us, I remain hopeful that with a fair and

 

      open-minded review of the evidence this advisory

 

      committee will constructively address the issues

 

      and ensure that interventions for this serious

 

                                                                20

 

      disorder meet high standards for both effectiveness

 

      and safety.

 

                Now I will ask Anuja Patel, executive

 

      secretary for the advisory committee, to review

 

      some of the ground rules for this committee and the

 

      public hearing.

 

                     Conflict of Interest Statement

 

                MS. PATEL:  Good morning.  Before I

 

      continue, I would like to notify you of a

 

      correction on the roster attached to the agenda.

 

      The following consultants, Dr. Robert Gibbons, Dr.

 

      Matthew Rudorfer, Dr. Richard Malone, Dr. Tana

 

      Grady-Weliky and Dr. Irene Ortiz will be added to

 

      the roster.  Amended copies of the roster will be

 

      available later this morning at the information

 

      desk outside this ballroom.

 

                As you know, we have a very full open

 

      public hearing today, and in the interest of both

 

      fairness and efficiency we are running it by some

 

      strict rules.  To make transitions between speakers

 

      more efficient, all speakers will be using the

 

      microphone and podium in front of the audience. 

 

                                                                21

 

      Each speaker has been given their number in the

 

      order of presentations and when the person ahead of

 

      you is speaking, we ask that you move to the nearby

 

      next speaker chair.  Individual presenters and

 

      families have been allotted three minutes for their

 

      presentations.  The one consolidated presentation

 

      has been given five minutes.  We will be using a

 

      timer and speakers who run over their time will

 

      find that the microphone is no longer working.  We

 

      apologize for the need for the strict rules, but we

 

      wanted to be fair and to give as many people as

 

      possible an opportunity to participate.

 

                The public may submit comments after this

 

      meeting directly to the FDA's Division of Dockets

 

      Management.  Instructions for submitting electronic

 

      and written statements are available at the

 

      registration desk outside this room.  The docket

 

      will remain open until July 29, 2005.  Thank you

 

      for your cooperation.

 

                I would like to read the meeting statement

 

      into the record now.  The following announcement

 

      addresses the issue of conflict of interest and is

 

                                                                22

 

      made a part of the record to preclude even the

 

      appearance of such at this meeting.  The topics to

 

      be discussed today are issues of broad

 

      applicability.  Unlike issues before a committee in

 

      which a particular company's product is discussed,

 

      issues of broader applicability involve many

 

      industrial sponsors and products.

 

                All special government employees and

 

      invited guests have been screened for their

 

      financial interests as they may apply to the

 

      general topics at hand.  The Food and Drug

 

      Administration has granted particular matters of

 

      general applicability waivers under 18 USC

 

      208(b)(3) to the following special government

 

      employees, which permits them to participate fully

 

      in today's discussion and vote:  Jean Bronstein,

 

      Dr. Joan Chesney, Dr. Wayne Goodman, Dr. Lauren

 

      Marangell, Dr. James McGough, Dr. James Perrin, Dr.

 

      Bruce Pollock.  In addition, Dr. Philip Wang has

 

      been granted a limited waiver that permits him to

 

      participate in the committee's discussions.  He is,

 

      however, excluded from voting.

 

                                                                23

 

                A copy of the waiver statements may be

 

      obtained by submitting a written request to the

 

      agency's Freedom of Infection Office, Room 12A-30

 

      of the Parklawn Building.

 

                In addition, Dr. Judith O'Fallon and Dr.

 

      Victor Santana have financial interest under 5 CFR,

 

      Part II, Sec. 40.202 that are covered by a

 

      regulatory waiver under 18 USC 208(b)(2).

 

                Because general topics impact so many

 

      entities, it is not practical to recite all

 

      potential conflicts of interest as they may apply

 

      to each member, consultant and guest speaker.  FDA

 

      acknowledges that there may be potential conflicts

 

      of interest but, because of the general nature of

 

      the discussion before the committee, these

 

      potential conflicts are mitigated.

 

                With respect to FDA's invited industry

 

      representatives, we would like to disclose that Dr.

 

      Dilip Mehta and Dr. Samuel Maldonado are

 

      participating in this meeting as industry

 

      representatives, acting on behalf of regulated

 

      industry.  Dr. Mehta is retired from Pfizer and Dr.

 

                                                                24

 

      Maldonado is employed by Johnson & Johnson.

 

                With respect to all other participants, we

 

      ask in the interest of fairness that they address

 

      any current or previous financial involvement with

 

      any firm whose product they may wish to comment

 

      upon.  Thank you.

 

                DR. GOODMAN:  We will now proceed with a

 

      series of formal presentations that will bring us

 

      to 11:45 a.m. and then a 15-minute discussion

 

      before lunch.  In the interest of time, I would

 

      like to ask my fellow committee members to restrict

 

      their questions after each presentation to issues

 

      of clarification only.  There will be time, 15

 

      minutes, for some discussion between 11:45 and

 

      12:00 and tomorrow there will be a great deal of

 

      time for discussion and consideration of the

 

      questions before us.  So, please, if you have

 

      questions about clarification, you can ask them

 

      after each presentation but restrict it to those

 

      kinds of issues.

 

                With that, I would like to introduce Dr.

 

      Dianne Murphy, of the FDA, who will be followed by

 

                                                                25

 

      Dr. Russell Katz, also of the FDA.

 

                           Overview of Issues

 

                DR. MURPHY:  Good morning and welcome to

 

      this very important discussion.  Before we begin

 

      today's important deliberations, I would ask us to

 

      step back and see the broader context in which this

 

      meeting is occurring.  I am going to spend a few

 

      minutes trying to describe that for you.

 

                There are four points I hope you take from

 

      this short presentation.  One is that the majority

 

      of medicines given to children in this country are

 

      prescribed off-label and have not been studied in

 

      all the pediatric populations in which they are

 

      used.

 

                Second, because of new legislation and

 

      regulations since 1998, FDA has seen an increase in

 

      products that are used in children being studied in

 

      children.

 

                Third, for the first 100 products,

 

      involving over 200 studies conducted as a result of

 

      the new legislation, FDA has found that

 

      approximately one-fourth of the time there was a

 

                                                                26

 

      need to change the dose, a new pediatric-specific

 

      adverse event was described or the product was not

 

      found to be efficacious despite the fact that it

 

      was efficacious in adults.

 

                Fourth, part of the reason we are here

 

      today is because we are finally studying the

 

      therapies that are being given to children.

 

      Children deserve the same level of evidence that is

 

      required for adults to determine that their use by

 

      them is safe, effective and properly dosed.  They

 

      are a heterogeneous group who undergo rapid

 

      metabolic, hormonal, physiologic, development and

 

      growth changes in comparison to us, adults, who are

 

      rather static and tend only to deteriorate.

 

                Over the last two decades FDA has actively

 

      supported, along with the American Academy of

 

      Pediatrics and many other groups, the efforts to

 

      encourage development of information and

 

      appropriate use of therapies in the pediatric

 

      population.

 

                Very quickly, and this is important to

 

      understand, again, the context in which some of

 

                                                                27

 

      this information has been brought to you, in the

 

      last decade we have made tremendous progress.  In

 

      1994 the agency published an approach that it hoped

 

      would help foster and encourage development of

 

      therapies that we be used in children.  Congress

 

      passed legislation in 1997 which is referred to as

 

      the exclusivity or the incentive to develop studies

 

      on products that are being used in children.

 

                In 1998 the FDA published the Pediatric

 

      Rule, which was an effort to say that if a sponsor

 

      is going to develop a product in adults and that

 

      same disease occurs in children, or condition, that

 

      product in most circumstances and certain

 

      conditions would be required to be studied.

 

                We are going to go more into the 2001

 

      adoption by FDA of Subpart D, Pediatric Ethics

 

      Regulations, and I wanted to bring up the Best

 

      Pharmaceuticals for Children Act, which you will

 

      hear referred to as BPCA, because it renewed the

 

      congressional legislation of '97 and is important

 

      in that, again, it is the renewal of the incentive

 

      to study products that are being used in children.

 

                                                                28

 

                Another congressional legislative

 

      activity, the Pediatric Research Equity Act, in

 

      essence confirmed FDA's authority to require

 

      studies in children in certain circumstances.

 

                In the last decade, particularly really

 

      since 1997, the FDA has issued over 290 written

 

      requests to sponsors asking them to study products

 

      in children because these products are being used

 

      in children.  We have had submitted to us over 110

 

      products, involving over 220 studies in children,

 

      and have now more than 76 new labels that have new

 

      pediatric information from these studies.

 

                The major depressive disorders were

 

      included in the written requests that were issued,

 

      and written requests were issued for the products

 

      you see listed here, Prozac, Zoloft, Remeron, Paxil

 

      Effexor, Celexa and Serzone.  Those studies were

 

      all conducted under this program or in response to

 

      this program.

 

                This is a list of some of the programs and

 

      activities that are in place at FDA to help ensure

 

      the quality and ethical conduct of studies and the

 

                                                                29

 

      approach to pediatrics.  This is really focusing

 

      mostly on the drugs component of this.  But there

 

      is, at the Commissioner's level, an Office of

 

      Pediatric Therapeutics.  This was enacted by the

 

      Best Pharmaceuticals for Children Act in 2002 and

 

      first staff were hired last year.  We now have in

 

      place an ethicist whose focus is pediatric ethics.

 

      You will hear a little bit more about the Pediatric

 

      Advisory Committee and Subpart D referrals in a

 

      minute.  You just heard about the exclusivity

 

      process which has been important in making sure

 

      that trials do get conducted.  I will spend a few

 

      moments at the end talking about disclosure

 

      requirements that are unique to pediatric studies

 

      that are conducted under exclusivity.

 

                This is another meeting, actually in a

 

      long series of meetings that have occurred to

 

      ensure the scientific and ethical quality of

 

      activities involving studies that are being

 

      conducted in children.  Since 1999, the Pediatric

 

      Advisory Subcommittee has had, including today's

 

      meeting, over ten meetings that have addressed over

 

                                                                30

 

      ten scientific issues, three ethical issues and, in

 

      addition, starting last year, began having specific

 

      safety reviews of products that have been approved,

 

      again under the exclusivity provisions, so that all

 

      adverse events that occurred in the year after

 

      product was granted exclusivity were reviewed.

 

      Again, this is just to inform you of the ongoing

 

      pediatric activities that are occurring at the FDA,

 

      some of them.

 

                The new advisory committee, I should say

 

      full Pediatric Advisory Committee is meeting for

 

      the first time today.  It was  chartered this year

 

      and is mandated to include patient and family

 

      organizations, and its mandated responsibilities

 

      include safety, labeling disputes and Subpart D

 

      referrals and general pediatric issues.

 

                The first Subpart D ethics panel met this

 

      past Friday and will report to this committee on

 

      Wednesday.  I will tell you a little bit more about

 

      that.

 

                It is important to understand that Subpart

 

      D, which is part of the Common Rule, was those

 

                                                                31

 

      extra protections for children applied to only

 

      federally funded activities until recently.  In

 

      2000, the Children's Health Act required FDA

 

      regulated products to be in compliance with

 

      additional protections for children that are

 

      embodied in the Subpart D of the Common Rule.

 

                Subpart D is fundamentally a referral

 

      process.  There is much more to it but it is a

 

      process for IRBs when they are unsure they can

 

      approve or under which regulation they should

 

      approve a study involving children.  The Pediatric

 

      Ethics Subcommittee reports to the Pediatric

 

      Advisory Committee and this is a public process.

 

                The disclosure of the studies that are

 

      conducted in children is distinct for studies that

 

      are conducted in children under the exclusivity

 

      provisions of BPCA.  I mention this because it is

 

      unusual in the FDA if a product is not approved

 

      that those studies would be disclosed.  However, we

 

      now have, again under BPCA, a requirement that

 

      within 180 days of submission of a pediatric study

 

      a public summary of the medical and clinical

 

                                                                32

 

      pharmacology reviews will be posted.  There are now

 

      41 pediatric summaries posted at this website.

 

      Basically, you can go to the FDA page and get there

 

      by going to the Center for Drugs or pediatric

 

      summary\summary review.

 

                The summaries of Effexor, Paxil, Serzone,

 

      Celexa, Zoloft and Remeron are available on the

 

      pediatric summary review site.  As you know, and

 

      will hear, Prozac is the only antidepressant that

 

      is approved for use in children, and it is posted

 

      up on FDA's site for approved applications.  That

 

      URL is provided for you here and in your handouts.

 

                The new pediatric data has taught us that

 

      our knowledge of pediatric therapeutics is in its

 

      infancy; that we must study children if we are to

 

      understand pediatric-specific adverse events and

 

      reactions or if a product is going to work in

 

      children.  The pharmacokinetics in children has

 

      proven to be more variable than anticipated.  The

 

      submitted studies that we are receiving are

 

      teaching us that we need to know more about

 

      pediatric endpoints, pediatric trial designs and

 

                                                                33

 

      how to conduct these trials, and that we will need

 

      to change some of our trials as we move forward.

 

      Ethical issues require reassessment from a

 

      pediatric perspective.  Therefore, at this point no

 

      longer shall each child be an experiment of one in

 

      which not much knowledge is gained.

 

                As we move forward, it will require our

 

      careful attention if we are to discover why

 

      children are behaving differently.  If children are

 

      to be appropriately treated, we will need to know

 

      more than how to correct those things or describe

 

      adverse events.  We are going to need answers to

 

      such fundamental questions as to why children react

 

      differently, what are the metabolic, physiologic

 

      events that are occurring that necessitate

 

      different dosing, or why is there a therapy that

 

      works in adults and does not work in children.  Our

 

      public policy must be more knowledge to replace our

 

      ignorance.  Thank you, and we look forward to your

 

      discussion.

 

                DR. MARANGELL:  Dr. Murphy, a quick

 

      question, when the FDA requests a study can you

 

                                                                34

 

      specify methodology and assessments that you would

 

      like to see included?

 

                DR. MURPHY:  When FDA requests a study we

 

      do put in that written request the trial design,

 

      the number of patients, the adverse events--you

 

      know, under exclusivity all of that does go into

 

      the written request.

 

                DR. GOODMAN:  Thank you, Dr. Murphy.  Now

 

      Dr. Katz?

 

                           Overview of Issues

 

                DR. KATZ:  Thank you, Dr. Goodman, and

 

      good morning.  I would like to welcome you to this

 

      joint meeting of the Psychopharmacologic Drugs

 

      Advisory Committee and the Pediatric Advisory

 

      Committee.

 

                As you know, we are here to present to you

 

      and to ask for your guidance in interpreting the

 

      results of our analyses of the relationship between

 

      antidepressant drug use and suicidal behavior in

 

      controlled trials in pediatric patients.  This

 

      meeting is in follow-up to the meeting of these two

 

      committees held in February of this year.  At that

 

                                                                35

 

      meeting, as you recall, we presented to you and

 

      obtained your endorsement of our plans to perform

 

      these analyses.

 

                At this point I would like to very briefly

 

      recap how we arrived to this point.  As you know,

 

      we first became aware of a possible relationship

 

      between antidepressant drug use and suicidal

 

      behavior in pediatric patients in May of 2003 when,

 

      in response to our request for further

 

      clarification of their data, GlaxoSmithKline, the

 

      manufacturer of Paxil, submitted data to us that

 

      suggested such a link for that drug.  As a result

 

      of this submission, the agency issued a public

 

      statement recommending that this drug not be used

 

      in pediatric patients with depression, and

 

      independently we asked all other manufacturers of

 

      antidepressant drugs to resubmit the relevant data

 

      from controlled studies with their drugs in

 

      pediatric patients.

 

                Based on our review of this data, we

 

      issued a statement informing prescribers that there

 

      was a potential relationship between all of these

 

                                                                36

 

      drugs and suicidal behavior, and that these drugs

 

      should be used with caution in these patients.

 

                However, at that time we also noticed that

 

      the data submitted to us from the various companies

 

      was not reported to us in a form that would permit

 

      definitive analyses.  Specifically, each company

 

      classified various behaviors as being

 

      suicide-related adverse events in their own

 

      idiosyncratic manner.  This led to questions about

 

      whether or not these events were, in fact,

 

      suicide-related and, in addition, prevented

 

      meaningful comparisons between drugs in this class.

 

                For this reason, we decided that an

 

      independent assessment of these possible events by

 

      experts in suicidology would be the most

 

      appropriate way to definitively answer the question

 

      of whether or not any, all or none of these drugs

 

      increased the risk of suicidal behavior in

 

      pediatric patients.  Let me just add that by

 

      definitive analyses I mean analyses that make the

 

      best possible use of the available data.

 

                It was at this time that we brought the

 

                                                                37

 

      issue before you.  At that meeting we presented you

 

      with our plans to submit blinded narrative

 

      descriptions of possible suicide-related events to

 

      a group of independent experts, to be coordinated

 

      by Columbia University, whose task it would be to

 

      classify these events as being suicide-related or

 

      not.  Although no formal vote was taken, this

 

      committee fully endorsed this effort and agreed

 

      that the data in hand at that time did not permit

 

      definitive analyses to be done.

 

                The committee also recommended, based in

 

      part on the data in hand but also, I believe

 

      importantly, on the basis of testimony from members

 

      of the public who had suffered the tragedy of loved

 

      ones who had committed suicide while taking these

 

      drugs, that the agency should ask sponsors of these

 

      products to warn prescribers that patients being

 

      treated with these drugs, especially at the

 

      beginning of treatment, should be closely watched

 

      for the emergence of signs and symptoms that might

 

      suggest a worsening in their clinical state.

 

                Since that February meeting a number of

 

                                                                38

 

      important things have happened.  Based on your

 

      advice, the agency drafted, and all of the sponsors

 

      of these drugs have adopted, language in product

 

      labeling warning about the possibility of

 

      significant behavioral changes at the outset of

 

      treatment with these drugs in both pediatric and

 

      adult patients, and the prescribing community and

 

      the public have been informed of these changes.

 

                Critically, this warning made clear that

 

      the possibility of worsening and a possible

 

      increased risk of suicidal behavior at the outset

 

      of treatment could not necessarily be attributed to

 

      the drugs because the data did not permit such a

 

      definitive conclusion.  Nonetheless, it was

 

      considered appropriate and prudent to inform

 

      prescribers and patients and their families that

 

      changes in behavior could occur with the onset of

 

      treatment.

 

                Also, the Columbia group has completed

 

      their task of reclassifying the potential cases of

 

      suicidal behavior and, importantly, we have

 

      completed our reanalyses of these data.  As

 

                                                                39

 

      promised at our February meeting, we are now ready

 

      to present to you the results of these analyses.

 

                At this point I would just like to give

 

      you a brief overview of the agenda for today's and

 

      tomorrow's session.  First Dr. Tom Laughren, of the

 

      Neuropharmacology Division, will provide you with a

 

      more detailed account of the regulatory history and

 

      events that have brought us here this morning.  He

 

      will be followed by Dr. Diane Wysowski, of the

 

      agency's Office of Drug Safety, who will briefly

 

      present the results of some recently published

 

      epidemiologic studies relevant to this question.

 

      We have provided the committees with copies of

 

      these published materials.  Although, of course, we

 

      consider our reanalyses of the controlled data to

 

      be the primary source of data on which your

 

      discussions and recommendations will be based, we

 

      thought it important to present at least briefly

 

      the available relevant epidemiologic data.

 

                Next, Dr. John March, of Duke University,

 

      will present a brief report of the Treatment for

 

      Adolescent Depression Study, or TADS trial, a

 

                                                                40

 

      recently completed trial that evaluated the effects

 

      of fluoxetine in adolescents with depression.  As

 

      you know, fluoxetine is the only drug approved in

 

      the United States for the treatment of depression

 

      in pediatric patients and, as you will see, these

 

      data make an important contribution to our overall

 

      assessment of the problem before us.

 

                Dr. Greg Dubitsky, again of the

 

      Neuropharmacology Division, will then present an

 

      overview of the design of the pediatric trials from

 

      which the data for our analyses were derived.  This

 

      exploration is important because similarities and

 

      differences in design elements among these trials

 

      can have important implications for whether or not

 

      these data can be examined as a whole, or whether

 

      they must be considered separately.

 

                Then, Dr. Kelly Posner, of Columbia

 

      University and the primary person responsible for

 

      coordinating the blinded reclassification effort,

 

      will present to you the methodology her group used

 

      to produce what we now consider to be the

 

      definitive data on which we have based our

 

                                                                41

 

      reanalyses.

 

                Because the reclassification of these

 

      clinical events was the critical activity on which

 

      all subsequent analyses and decisions will have

 

      been based, and because by its nature it involved

 

      subjective assessments of the primary data, we felt

 

      strongly that it was appropriate to ensure that the

 

      methodology used by the Columbia group could

 

      reliably and reproducibly yield similar results

 

      when applied by an independent group.  For this

 

      reason, agency scientists performed such an

 

      independent reclassification of a percentage of

 

      these cases, utilizing the Columbia classification

 

      schema, and Dr. Solomon Iyasu, of the agency's

 

      pediatric group, will present the results of this

 

      independent audit of the Columbia process.

 

                At that point, Dr. Tarek Hammad, of the

 

      neuropharmacology group, will then present the most

 

      critical results of his extensive reanalyses of the

 

      data as reclassified by the group of outside

 

      experts.  These analyses look at the data for

 

      individual drugs, as well as across all drugs, and

 

                                                                42

 

      will provide the data on which the committee

 

      subsequent discussions will be based.

 

                Finally, the last formal agency

 

      presentation will be given by Dr. Andrew Mosholder,

 

      of the Office of Drug Safety.  Dr. Mosholder's name

 

      is undoubtedly familiar to you.  Dr. Mosholder was

 

      the agency reviewer who had, prior to the February

 

      advisory committee meeting, performed analyses on

 

      the cases as submitted, that is, the

 

      non-reclassified cases, and had concluded that

 

      these drugs did, in fact, increase the risk of

 

      suicide-related behaviors in this population.  As

 

      you know, Dr. Mosholder did not present his

 

      conclusions at the February meeting, although the

 

      data on which his analyses were based were

 

      presented and we noted at that time that some in

 

      the agency had already reached a definitive

 

      conclusion on this question.

 

                There has been since that meeting

 

      considerable public discussion and controversy

 

      related to the fact that Dr. Mosholder was not

 

      given the opportunity to present his conclusions at

 

                                                                43

 

      that meeting.  The reasons for our decision at that

 

      time were straightforward.  As I have discussed

 

      today and as we have discussed publicly on numerous

 

      occasions, we had decided that at the time of the

 

      February meeting the data had not been submitted in

 

      a form in which we could reliably agree that the

 

      events described as representing suicide-related

 

      behavior did, in fact, represent such behavior.

 

      We, therefore, felt that conclusions reached on the

 

      basis of analyses that relied on these descriptions

 

      could no, in turn, be considered completely

 

      reliable.

 

                We felt, and still feel, that presenting

 

      conclusions based on potentially unreliable

 

      analyses could have led to errors in either

 

      direction, that is, resulted in a conclusion that

 

      the drugs were dangerous when they really were not,

 

      or resulted in a conclusion that the drugs were

 

      safe when they were not.  A mistake of either kind

 

      could have, in our view, disastrous consequences.

 

      For this reason it was, and remains, our view that

 

      these decisions must be based on the most reliable

 

                                                                44

 

      analyses possible.  Now that the definitive

 

      analyses have been done, however, Dr. Mosholder

 

      will present his own analyses and conclusions, with

 

      particular attention to a comparison between his

 

      results and Dr. Hammad's.

 

                Following lunch we will hear brief

 

      comments from several of the pharmaceutical

 

      companies who have antidepressant drug products on

 

      the market, and the day will end with the open

 

      public hearing.  A total of 73 members of the

 

      public have signed up to make statements.  As you

 

      have heard and as in the February meeting, we will

 

      again need to limit the statements from the public,

 

      this time to three minutes per individual.  We

 

      recognize that this is not much time and we

 

      apologize for the limit but it would be impossible

 

      for all those who wish to make statements to do so

 

      without imposing this limitation.  We appreciate

 

      your understanding on this point and, as you have

 

      heard, anyone who wishes may submit written

 

      testimony to the docket.

 

                Tomorrow the committee will discuss the

 

                                                                45

 

      data you will have heard.  We, of course, look

 

      forward to this discussion and in particular to

 

      your answers to the questions we have brought to

 

      you and which we have provided in your background

 

      packages.  We are, in brief, interested in your

 

      views on our approach to the reclassification

 

      effort and, critically, whether you believe that

 

      the analyses establish that one or more of the

 

      drugs studied increases the risk of suicidality in

 

      pediatric patients.  Importantly, if you do

 

      conclude that there is a signal for suicidality,

 

      whether for one or more of these drugs, we need to

 

      know what additional regulatory action, if any, you

 

      believe should be taken.

 

                The results of our reanalyses are complex

 

      and their interpretation is not immediately

 

      obvious.  They raise difficult questions, not only

 

      about the fundamental meaning of the results of the

 

      analyses for each drug, but also about the

 

      comparability of the various treatments and,

 

      therefore, whether it is appropriate to consider

 

      the drugs as a class for which any conclusion

 

                                                                46

 

      reached should globally apply or whether the drugs

 

      must be considered individually.  Further, the

 

      question of any further regulatory action is also a

 

      thorny one and must take into account the

 

      consideration of the lack of available

 

      effectiveness data for all of the drugs, except

 

      fluoxetine, although the absence of this

 

      effectiveness data is not easily interpreted

 

      either.

 

                Because of the complex nature of the

 

      evidence and because of the extraordinary

 

      importance for the public health of the decisions

 

      that we need to make, we are turning to you, the

 

      experts, for guidance on these matters.  We thank

 

      you in advance for your efforts.

 

                DR. GOODMAN:  Thank you, Dr. Katz.  I

 

      would like to invite Dr. Tom Laughren to come to

 

      the podium.

 

                   Regulatory History and Background

 

                DR. LAUGHREN:  Thank you, and I would also

 

      like to welcome everyone to the meeting today.  I

 

      am going to begin by briefly giving an overview of

 

                                                                47

 

      events leading up to today's meeting.  I am then

 

      going to talk about the key elements in the

 

      division's exploration and analysis of the

 

      pediatrics suicidality data.  I will then spend a

 

      little time talking about our March 22nd public

 

      health advisory and the subsequent labeling changes

 

      that have now been implemented.  Then I am going to

 

      spend a little time talking about the effectiveness

 

      data.  I did this at the last meeting; I will do

 

      this again because I think it is important to have

 

      these data in mind since they are an important part

 

      of the context of this discussion about pediatric

 

      suicidality.  Then I am going to quickly go over

 

      the questions and the issues for which we are going

 

      to be seeking feedback tomorrow.  I think it is

 

      important that you have these questions in mind as

 

      you hear the talks this morning.

 

                This slide lists a number of the people at

 

      FDA who have been involved in looking at these

 

      data.  As you can see, these people come from

 

      various sections of the agency.  It is a long list,

 

      and really the point of this slide is that we take

 

                                                                48

 

      this matter very seriously and we have invested a

 

      lot of effort into trying to understand these data.

 

                You heard earlier about the two laws,

 

      FDAMA and BPCA, that give FDA authority to grant

 

      additional market exclusivity for companies which

 

      do pediatric studies.  The point of this slide is

 

      that most of the data that we are dealing with this

 

      morning come from these types of studies, in other

 

      words, studies that were done to obtain additional

 

      marketing exclusivity.  However, we have also

 

      included in our analysis data from a ninth

 

      antidepressant drug, Wellbutrin, that was not

 

      studied for exclusivity.  That was one study in

 

      ADHD.  We are also including in our analysis data

 

      from the TADS trial that you will hear about in

 

      more detail later in the morning from John March,

 

      from Duke.

 

                As Dr. Katz pointed out, this issue first

 

      came to our attention based on a review of the

 

      Paxil supplement.  In that review, the reviewer

 

      noticed that events suggestive of possible

 

      suicidality were subsumed, along with other

 

                                                                49

 

      behavioral events, under the preferred term

 

      "emotional lability."  This led FDA to issue a

 

      request to the sponsor, GSK, to explain this coding

 

      practice.  Ultimately, that resulted in a report to

 

      FDA, in May of last year, on pediatric suicidality

 

      with Paxil.  As Dr. Katz pointed out, that report

 

      did suggest a signal of increased suicidality in

 

      association with drug use, particularly in one of

 

      three depression trials in that program.

 

                What I am going to do in this slide is

 

      very quickly run through subsequent events that led

 

      us up to the February advisory committee meeting.

 

      So, in June of last year we issued a public

 

      statement cautioning about the use of Paxil in

 

      pediatric patients with depression.  In July we

 

      issued requests to sponsors of eight other

 

      antidepressant products to ask them to give us the

 

      same kind of summary data that GSK had provided for

 

      Paxil.

 

                In September of last year we held an

 

      internal regulatory briefing at FDA.  The purpose

 

      of this was to brief upper management about this

 

                                                                50

 

      signal.  The two points that I took away from that

 

      meeting from the standpoint of the division's work

 

      were, number one, there was general agreement that

 

      it would be important to try and classify these

 

      events since many of them were not clearly related

 

      to suicidality and we felt it would be very

 

      important to do a rational classification.

 

      Secondly, there was sentiment that we ought to try

 

      and obtain patient-level data information, beyond

 

      the summary information, in order to try and

 

      explain differences among trials and between

 

      programs.

 

                In September and October we began to get

 

      responses to our July requests.  Also, in October

 

      we issued requests to sponsors for the

 

      patient-level data sets that I mentioned earlier.

 

      Also in October, we decided to go outside of FDA to

 

      get a classification of these cases accomplished.

 

      Then, again as Dr. Katz mentioned, in October we

 

      issued a second public health advisory, this time

 

      extending the cautionary language to all current

 

      generation antidepressants.  Finally, in November

 

                                                                51

 

      and December, having looked at the responses to the

 

      July request for summary data, it occurred to us

 

      that we may not have obtained all of the relevant

 

      events and so we sent additional requests to have a

 

      broader search for events that we would then try

 

      and get classified.

 

                That brings us up to the February advisory

 

      committee that we held.  At that meeting you

 

      advised us to basically continue with our analysis

 

      of the data but, in the meantime, to go ahead and

 

      make some labeling changes.  In March of this year

 

      we issued a public health advisory announcing the

 

      changes that we had requested.  In the meantime,

 

      the classification of the cases was ongoing by the

 

      Columbia group.  Those were completed in June of

 

      this year.  Then, in August of this year we

 

      completed our analysis of the pediatric suicidality

 

      data.

 

                In this slide what I am doing is basically

 

      summarizing what I think is the major contribution

 

      of the division to this effort.  Again, we went to

 

      a lot of effort to try to ensure completeness of

 

                                                                52

 

      case findings, that we had a complete set of events

 

      to have classified.  We then worked with Columbia

 

      University to have these events classified.

 

                As an aside, I would like to mention that

 

      this effort, conducted by Kelly Posner and her

 

      group at Columbia and the very exceptional group of

 

      outside experts that they assembled to do this,

 

      represents a very substantial effort that has not

 

      only helped us to understand these data but I think

 

      will have implications for the field in terms of

 

      developing a standard approach to classifying these

 

      kinds of data, and also will lead to guidance

 

      document that, hopefully, will improve

 

      ascertainment for suicidality, which was a very

 

      significant problem in these trials.

 

                Finally, the third effort that we were

 

      involved in was, again, in obtaining the

 

      patient-level data sets that allowed us to try and

 

      explore for confounding and effect modification, in

 

      essence, to try to explain some of the striking

 

      differences we were seeing in the signal across

 

      trials within programs and across programs.

 

                                                                53

 

                As mentioned, at the February advisory

 

      committee you advised us to go ahead and strengthen

 

      labeling, in particular for monitoring for

 

      suicidality, while we were completing our analysis.

 

      We did this and we announced the request that we

 

      were making in a March 22nd public health advisory.

 

                The changes in labeling that we requested

 

      have now all been implemented for the ten drugs of

 

      interest.  I would add here that our plan is to

 

      extend the standard language to all

 

      antidepressants, not just the current generation

 

      and, in fact, that has already been done for some

 

      of these drugs.  We are waiting to do it for the

 

      others until we work out the final standard

 

      language, which will be based on advice we get from

 

      you at this meeting.

 

                What I want to do in this slide is to very

 

      quickly go over the labeling changes that have been

 

      implemented now.  This slide focuses on the advice

 

      for clinicians who are using antidepressants for

 

      treating any condition really, whether in adult of

 

      pediatric patients.  So, the advice is as follows,

 

                                                                54

 

      first of all, we are asking clinicians to closely

 

      observe patients who are being treated with

 

      antidepressants for clinical worsening and for the

 

      emergence of suicidality, especially at the

 

      beginning of therapy but also at times of dose

 

      change.

 

                Secondly, we are asking clinicians to

 

      consider changing the therapeutic regimen in

 

      patients whose depression is either persistently

 

      worse or whose emergent suicidality is severe,

 

      abrupt in onset, or was not part of the patient's

 

      presenting symptoms.

 

                Finally, we are also asking clinicians to

 

      observe for the emergence of other symptoms as

 

      well, for example, anxiety, agitation, panic

 

      attacks, insomnia, irritability, hostility,

 

      impulsivity, and so forth.  The idea here is that

 

      there is a belief, not really solidly empirically

 

      established but a belief that many of these events

 

      may represent precursors to emerging suicidality.

 

      So, we are also asking clinicians to be alert to

 

      these symptoms.

 

                                                                55

 

                This slide focuses on advice for families

 

      and caregivers that also is included in labeling.

 

      We are asking those folks to also be alert to the

 

      emergence of these same symptoms and to report

 

      those symptoms to healthcare providers if they

 

      emerge.

 

                Now I want to turn to briefly describing

 

      the efficacy data for the 15 short-term trials that

 

      we looked at in our review of these pediatric

 

      supplements.  I am going to be focusing on primary

 

      outcomes in those trials.  I also want to spend a

 

      little time talking about the difficulty in

 

      interpreting negative findings in this setting and

 

      again I want to note that although I am not going

 

      to be talking about the TADS efficacy data, you

 

      will be hearing about the TADS efficacy data from

 

      John March a little bit later in the morning.

 

                This is kind of a busy slide but basically

 

      each row in this table represents a different

 

      trial.  Again, there was a total of 15 trials.

 

      This is color-coded so you can separate the

 

      different programs.  There were seven programs. 

 

                                                                56

 

      Paroxetine had three trials.  The rest all had two

 

      trials.  The column to look at is the far column

 

      where I have summarized the results on the primary

 

      endpoint.

 

                Basically I have characterized the results

 

      as follows:  Where the p value on drug versus

 

      placebo on the primary endpoint was less than 0.05,

 

      I am calling it positive.  As you can see, that

 

      applies to the two fluoxetine trials and one of the

 

      citalopram trials.  If the p value fell between

 

      0.05 and 0.1 I am characterizing it as a trend.

 

      That applies to one of the sertraline trials and

 

      one of the nefazodone trials.  If the p value was

 

      greater than 0.1 on that primary endpoint I am

 

      characterizing it as negative.  That applies to all

 

      the remaining trials.  So, basically what you have

 

      here is three out of 15 trials meeting FDA's

 

      standard for being positive.

 

                The other point I want to make on this

 

      slide is that this represents FDA's view and I

 

      think it is a reasonable standard, however, it is

 

      not the only standard.  To illustrate that, I want

 

                                                                57

 

      to talk about two published papers, one for study

 

      329, the paroxetine trial, a paper that was

 

      published by Keller in 2001.  That paper

 

      characterized that trial as a positive study, the

 

      argument being that although it failed on the

 

      primary endpoint it succeeded on all the secondary

 

      endpoints.  So, the authors of that paper

 

      considered it a positive trial and many in the

 

      community also considered that a positive study.

 

                Secondly, there was a paper published on

 

      the two sertraline trials by Wagner et al., in

 

      2003, that was based on a pooling of the two

 

      trials.  Individually those trials did not make it

 

      but if you pooled them you got a significant p

 

      value.  Again, many in the community view that as

 

      evidence of effectiveness of sertraline in

 

      pediatric depression.  This does not meet FDA's

 

      standard but the point is that different folks have

 

      different views of the same data.

 

                Now I want to talk a little bit about the

 

      problem of interpreting negative findings in this

 

      setting.  First I want to turn to adult depression

 

                                                                58

 

      trials for drugs that we believe work.  Llooking at

 

      trials that on face should work, about half the

 

      time those trials fail. If that failure rate can be

 

      extrapolated to the pediatric population, the

 

      expectation in two study programs and most of these

 

      programs were two study programs--the expectation

 

      is that three out of four times you would fail to

 

      get two positive studies.  So, perhaps it shouldn't

 

      have come as such a surprise that many of these

 

      programs failed.  On the other hand, the fact that

 

      the overall success rate, again according to FDA's

 

      standard, is only 20 percent success is clearly a

 

      concern.

 

                Other factors to think about in looking at

 

      negative trials in this setting is, first of all,

 

      the history of antidepressant trials in pediatric

 

      depression.  If you go back to the tricyclic era,

 

      there were 12 trials comparing tricyclics with

 

      placebo in this population.  All of them failed.

 

      There are many interpretations of that.  One, of

 

      course, is that these drugs simply don't work in

 

      that population.

 

                                                                59

 

                Another might be that there is even

 

      greater heterogeneity in this population of

 

      patients captured under the diagnostic criteria for

 

      major depression than we see in adults.  That would

 

      work against getting positive trials.

 

                Another factor to think about is the

 

      somewhat unusual regulatory context in which these

 

      studies were done.  Ordinarily, when companies do

 

      studies they only benefit if they get a positive

 

      trial.  In this setting they would win in terms of

 

      getting exclusivity whether the trial succeeded or

 

      failed.  I don't know whether or not that was a

 

      factor in the conduct of these trials but it is

 

      another thing to think about.

 

                Finally, at the time that we issued

 

      written requests for these programs we were not

 

      routinely asking for phase 2 dose-finding studies

 

      as we are now.  That, again, maybe a factor.  It is

 

      possible that the dose was not right in some of

 

      these trials.

 

                In any case, the bottom line in terms of

 

      efficacy is that I think there are plausible

 

                                                                60

 

      reasons for failure to find efficacy other than the

 

      obvious one that maybe the drugs don't work.  On

 

      the other hand, a very important point I believe is

 

      that even though most of these programs have failed

 

      to meet FDA's standard for approval, this is not

 

      the same thing as saying that we have proof that

 

      the drugs have no benefit.  The drugs may have

 

      benefit that has simply not yet been demonstrated.

 

      On the other hand, the failure to demonstrate

 

      benefit clearly is a concern, especially when we

 

      have a risk, as we have now seen, of emerging

 

      suicidality.  So, the burden is clearly on those

 

      who believe that these drugs do have benefit to

 

      show that benefit.  Tomorrow I am going to talk a

 

      little bit about some possible designs for looking

 

      at longer-term benefits with these drugs.

 

                Now what I would like to do is quickly

 

      move through the questions that we are going to be

 

      asking you to discuss and comment on tomorrow.

 

      Again, we think it is important that you have these

 

      in mind as you hear the presentations this morning.

 

                First of all, we are going to ask you to

 

                                                                61

 

      comment on our approach to classifying the possible

 

      cases of suicidality and our subsequent analyses of

 

      the resulting data for the now 24 trials--again,

 

      the additional trial is the TADS trial.

 

                The question then would be do the

 

      suicidality data from these trials support the

 

      conclusion that any or all of these drugs increase

 

      the risk of suicidality in pediatric patients?  If

 

      the answer to that question is yes, to which of

 

      these nine drugs does that risk apply?  In other

 

      words, is this a class effect of all

 

      antidepressants?  Does it apply to certain

 

      subclasses within this broader class or only to

 

      specific drugs?

 

                If you believe there is a class risk or a

 

      risk that applies only to certain drugs, how should

 

      this information be reflected in the labeling for

 

      each of these products?  What, if any, additional

 

      regulatory actions do you think we need to take?

 

                Finally, again we would like you to

 

      consider what additional research might be needed

 

      to further delineate the risks and the benefits of

 

                                                                62

 

      these drugs in patients with pediatric depression?

 

      Thank you very much.

 

                DR. GOODMAN:  Thank you, Tom.  I imagine

 

      people have questions but I want to try to catch up

 

      this morning to make sure that we have time for all

 

      the presentations.  So, I will ask you to hold your

 

      questions and I would like to invite the next

 

      speaker, Dr. Diane Wysowski, who will be looking at

 

      data from different sources other than clinical

 

      trials.

 

            Recent Observational Studies of Antidepressants

 

                         and Suicidal Behavior

 

                DR. WYSOWSKI:  Good morning.  In this

 

      presentation I will be reviewing recent studies of

 

      antidepressants and suicidal behavior and briefly

 

      discuss their methods, results and limitations.

 

                I reviewed two types of studies,

 

      ecological and patient-level controlled,

 

      observational studies.  Ecological studies show

 

      increasing antidepressant use and simultaneous

 

      decreasing suicide rates.  However, such

 

      correlations do not necessarily imply causality. 

 

                                                                63

 

      Findings of ecological studies can be merely

 

      coincidental.  Numerous factors such as changes in

 

      risk factors, social and economic changes, more

 

      available counseling, changes in gun access and

 

      choice of a less lethal means of suicide in

 

      children and adolescents may coincide with

 

      decreases in the suicide rate in children and

 

      adolescents.

 

                Ecological studies don't show which factor

 

      or factors are responsible for an observed trend.

 

      Furthermore, an increased relative risk of suicide

 

      with antidepressants in children and adolescents

 

      may coexist with a decreased suicide rate.  To

 

      better examine causality, we turned to

 

      patient-level controlled studies, such as

 

      observational studies, in clinical trials.

 

                For the rest of this presentation I will

 

      be focusing on two patient-level controlled,

 

      observational studies.  The first is the Jick study

 

      that was published this July in The Journal of the

 

      American Medical Association.  It is a matched case

 

      control design based on patient prescriptions and

 

                                                                64

 

      diagnoses obtained from the United Kingdom's GPRD,

 

      the General Practice Research Database, for the

 

      period 1993-1999.  The GPRD is a database of

 

      medical records from general practitioners of more

 

      than three million patients in the United Kingdom.

 

                For this study subjects were 10 through 69

 

      years of age.  Exposures studied were the most

 

      widely used antidepressants in the U.K.,

 

      amitriptyline, fluoxetine, paroxetine and

 

      dothiepin.  Dothiepin was chosen as the reference

 

      category.  From data on these antidepressants

 

      users, the investigators identified 555 cases of

 

      nonfatal suicidal behavior, defined as ideation or

 

      attempts.  They identified 17 cases of suicide.

 

      From the base group of antidepressant users, the

 

      investigators matched the cases with more than 2000

 

      controls who did not develop suicidal behavior.

 

      The researchers then compared the suicidal cases to

 

      the non-suicidal controls for initiation of each

 

      antidepressant.

 

                Controlling for age, sex, calendar time

 

      and time from first antidepressant prescription to

 

                                                                65

 

      onset of suicidal behavior, the range of relative

 

      risk for nonfatal suicidal behavior was 0.83 to

 

      1.29 for the antidepressants compared to dothiepin.

 

      None of these risks were statistically significant.

 

      Paroxetine, with a relative risk of 1.29 and a 95

 

      percent confidence interval of 0.97 to 1.7, had

 

      borderline statistical significance.

 

                Similar results were obtained for those

 

      10-19 years old.  No statistically significant

 

      association was found between each antidepressant

 

      and completed suicide.  No statistically

 

      significant association was found between stopping

 

      an antidepressant and nonfatal suicidal behavior.

 

                The relative risk for nonfatal suicidal

 

      behavior and suicide were highest for patients

 

      first prescribed an antidepressant within 1-9 days,

 

      versus 90 days or more, before the suicidal

 

      behavior of the case in the same time period for

 

      the control.  For nonfatal suicidal behavior the

 

      relative risk for antidepressant use within 1-9

 

      days was 4, with a 95 percent confidence interval

 

      of 2.89 to 5.74.  For suicide the relative risk for

 

                                                                66

 

      antidepressant use within 1-9 days was 38, with a

 

      wide confidence interval of 6.2 to 231.

 

                Reviewing the limitations of this study,

 

      the results are only as good as the GPRD data.

 

      There are concerns about possible missing data,

 

      possible incomplete ascertainment and

 

      misclassification of patients, and possible

 

      uncontrolled biases among the antidepressant drugs,

 

      such as selection by severity of depression.  There

 

      were no interviews of cases and controls so

 

      medication compliance is not systematically known.

 

      There was no unexposed group, and the

 

      antidepressant risks are only in reference to the

 

      dothiepin group.

 

                FDA asked Dr. Jick and colleagues to

 

      reanalyze their results with amitriptyline as the

 

      reference category.  They kindly responded to our

 

      request, and asked that their interpretation of the

 

      results be presented verbatim to the committee.  If

 

      the committee wishes to see these supplemental

 

      analyses I will be glad to present them in the

 

      question and answer period.

 

                                                                67

 

                Other limitations of the study include the

 

      fact that suicidal ideation is a more subjective,

 

      softer diagnosis than suicide attempts and the

 

      risks were not examined separately.  This was a

 

      study of mostly adults and there is limited

 

      information on children and adolescents.

 

                Finally, the investigators excluded

 

      patients with a history of 11 other

 

      neuropsychiatric diagnoses, calling into question

 

      the representativeness of the patients compared

 

      with those in clinical practice.

 

                Another patient-level controlled study

 

      examined the relationship between antidepressants

 

      and the risk of suicide attempt by adolescents with

 

      major depressive disorder diagnoses.  The study was

 

      done by investigators at the University of Colorado

 

      School of Pharmacy and Medicine.  Robert Valuck was

 

      the principal investigator.  It was presented as a

 

      poster at the International Society of

 

      Pharmacoeconomics and Outcomes Research meeting,

 

      this past May.

 

                It is a retrospective cohort study of paid

 

                                                                68

 

      medical claims data from the PharmMetrics

 

      Integrated Outcomes Database of 70 managed health

 

      plans for the period 1995 through March, 2003.

 

      Paid claims data include health care provided in

 

      which costs are incurred, such as for

 

      prescriptions, doctor visits, emergency room visits

 

      and hospitalizations.

 

                The investigators identified about 16,000

 

      adolescents aged 12-18 with the first major

 

      depressive disorder diagnosis.  They classified

 

      patients into cohorts by antidepressant

 

      prescription, those who received none over the

 

      entire follow-up period, which was the reference

 

      group, and those who received SSRIs, tricyclic

 

      antidepressants or other antidepressants within 30

 

      days of diagnosis.  They followed the cohorts for

 

      at least 6 months.

 

                The researchers used a Cox proportional

 

      hazards regression analysis to control for some 14

 

      covariates and to examine the multivariate

 

      relationship between antidepressant use and time to

 

      suicide attempt.  The majority of patients, 78

 

                                                                69

 

      percent, had no antidepressant filled in the 6

 

      months after diagnosis; 15 percent had SSRIs filled

 

      within 30 days of diagnosis.  And, 209, 1.3

 

      percent, of the 16,000 patients made at least one

 

      suicide attempt in the follow-up period.

 

                The investigators concluded that

 

      antidepressant treatment with any class of drugs

 

      did not increase the risk of suicide attempt.

 

      Antidepressant use for less than 6 months, compared

 

      with use for 6 months or more, was associated with

 

      a statistically significant 3-fold increased risk

 

      of suicide attempt.  Females, those who received

 

      psychotherapy within 90 days of major depressive

 

      diagnosis, patients with substance abuse,

 

      schizophrenia or another mental health disorder,

 

      patients with more chronic diseases and those in

 

      the Midwest and West were independently at greater

 

      risk of suicide attempt.

 

                Dr. Valuck and co-investigators recently

 

      expanded their study to include 24,000 eligible

 

      patients with a new diagnosed major depressive

 

      disorder.  This expanded study is currently being

 

                                                                70

 

      reviewed for publication.  The researchers added a

 

      propensity matching adjustment to control for

 

      predictors of treatment and to achieve greater

 

      balance among the antidepressant groups.  The

 

      proportion of suicide attempters, 1.4 percent, was

 

      about the same proportion as in their smaller

 

      study.

 

                In this expanded study the hazards ratio

 

      for SSRIs compared to no treatment was 1.58, not

 

      statistically significant.  The hazards ratio for

 

      tricyclics was not estimable due to small numbers

 

      and it was 1 for the other antidepressant category.

 

      The hazards ratio for multiple antidepressants was

 

      1.43, also not statistically significant.  The risk

 

      of suicide attempt declined with longer use of an

 

      antidepressant.  Compared with patients having less

 

      than 8 weeks of use, those with equal to or greater

 

      than 6 months of use had a statistically

 

      significant decline in the risk of suicide attempt.

 

                Concerning the limitations, the results

 

      are only as good as these paid claims data.  There

 

      are concerns about possible missing data, possible

 

                                                                71

 

      incomplete ascertainment and misclassification of

 

      patients, and possible uncontrolled selection

 

      biases by antidepressant group.  There were no

 

      interviews of patients so we don't have

 

      systematically collected information on medication

 

      compliance.  There are no data on the outcomes of

 

      the attempts.  We don't know how many of the

 

      attempters died, and there is no information on

 

      suicides.   Also, there is no information on

 

      individual antidepressants.  There were differences

 

      in study results between the poster and the

 

      expanded study, although this is probably due to

 

      the larger size of the expanded study.

 

                In conclusion, although most of the

 

      results for the individual antidepressants or

 

      classes of antidepressants were not statistically

 

      significantly associated with suicidal behavior, I

 

      do not believe that the Jick and Valuck studies

 

      completely rule out a possible increased risk of

 

      suicidal behavior with antidepressant use.  The

 

      studies reviewed were in agreement in showing that

 

      the risk of suicidal events occurred statistically

 

                                                                72

 

      significantly closer to diagnosis and onset of

 

      antidepressant treatment.  The studies did not

 

      provide data about the characteristics of patients

 

      who did not respond to antidepressants or whose

 

      illness worsened with them.  The studies had actual

 

      or potential methodological limitations.

 

                I conclude that more definitive studies,

 

      perhaps large randomized, controlled trials of

 

      sufficient length, are needed concerning the risk

 

      of suicidal behavior and suicide as related to

 

      antidepressant use in children and adolescents.

 

      With so much at stake, children and adolescents,

 

      their parents and physicians and society in general

 

      deserve to know which therapies and which

 

      individuals work best for treatment of depression.

 

      Thank you.

 

                DR. GOODMAN:  Thank you very much, Diane.

 

      My preference would be that you present those

 

      additional Jick data tomorrow.  I don't think we

 

      have time for it today.  Would that be an agreement

 

      by the committee as well?  So, I think we are in

 

      accord on that, if you could prepare to present

 

                                                                73

 

      that data tomorrow to us.  There is one question,

 

      yes, we will allow that.

 

                DR. PINE:  I am wondering if you could

 

      clarify in the Valuck 24,000 patient study, if you

 

      looked at the association in the less than 8-week

 

      treatment versus no treatment group.  Did that

 

      confidence interval exclude 1?  I mean, I saw that

 

      you gave less than 8 weeks versus prolonged

 

      treatment but I didn't see an odds ratio for less

 

      than 8 weeks versus no treatment.

 

                DR. WYSOWSKI:  I don't think that I have

 

      those data.  I don't think that they did that

 

      analysis.  Their results are still being considered

 

      for publication and we just got an abstract.  You

 

      saw the poster in your package.  Then, when they

 

      did the expanded analysis they only gave us an

 

      abstract of the results.  So, we don't have a lot

 

      of detail on the expanded study.

 

                DR. GOODMAN:  Dr. Fost, you had a question

 

      also?

 

                DR. FOST:  One of the theories of why

 

      suicide behavior might be increased shortly after

 

                                                                74

 

      prescribing is that the patients are at the worst

 

      then and that is why they are started on

 

      prescriptions.  If that were true, one might expect

 

      to see increased suicidal behavior in the week or

 

      two before prescribing.  Do either of these studies

 

      allow for that analysis?

 

                DR. WYSOWSKI:  I believe the Jick study

 

      did look at that.  Actually, no--no, I don't see

 

      any information on that; it is just after.

 

                DR. FOST:  And the data set doesn't allow

 

      itself for that reanalysis?

 

                DR. WYSOWSKI:  Well, it may.  I don't know

 

      whether either investigator has information on

 

      that.

 

                DR. GOODMAN:  I think that was an

 

      excellent question.  Now I would like to invite Dr.

 

      John March, from Duke University, to present

 

      results from the TADS trial.

 

                       Brief Report on TADS Trial

 

                DR. MARCH:  Thanks, it is a pleasure to be

 

      here and I would like to begin the presentation by

 

      thanking the committee for inviting the TADS team

 

                                                                75

 

      to present the TADS data, and also thank the FDA

 

      for the comprehensive and thoughtful way that it is

 

      approaching this question of enormous public health

 

      importance.

 

                The TADS trial, the Treatment for

 

      Adolescents with Depression Study, is an

 

      NIMH-funded comparative treatment trial, and I am

 

      going to present efficacy and safety data from the

 

      stage-1 outcomes that were published in The Journal

 

      of American Medical Association several weeks ago.

 

      We have a detailed safety paper in preparation.  We

 

      have a methods paper which has been published and a

 

      baseline paper which looks at the sample

 

      composition in press, and those of you who are

 

      interested in the TADS trial are referred to these

 

      papers for further information.

 

                As I mentioned, this is a study funded by

 

      the NIMH, coordinated by the Department of

 

      Psychiatry at Duke University and the Duke Clinical

 

      Research Institute, the DCRI.  It has had the

 

      benefit of oversight and consultation from numerous

 

      consultants, a scientific advisory board.  The

 

                                                                76

 

      NIMH, DSMB participants included 12 sites from

 

      around the United States.  Lilly provided

 

      fluoxetine under an independent educational grant

 

      to Duke University, had no input into the design of

 

      the study, the conduct of the study, the analysis

 

      of the data or the preparation of the manuscript.

 

      My sense is that the major credit for this work, as

 

      for all of the research on which we base

 

      evidence-based practice, goes to the children and

 

      families who are willing to participate in

 

      research.  Without their participation, we would

 

      have no evidence at all.

 

                The overall objective of the TADS trial

 

      was to examine the effectiveness of medication and

 

      cognitive behavioral psychotherapy alone and in

 

      combination for the acute and long-term treatment

 

      for adolescents with DSM-IV diagnosis of major

 

      depression.  The design of the trial was a

 

      balanced, randomized, controlled study that was

 

      masked by use of independent evaluators; four

 

      groups, placebo, cognitive behavioral

 

      psychotherapy, fluoxetine and their combination,

 

                                                                77

 

      and the study involved 36 weeks of treatment, of

 

      which I am going to present the stage-1 data for

 

      the first 12 weeks of treatment.  We also have a

 

      year of naturalistic follow-up and we have recently

 

      been funded to follow these youngsters out into

 

      young adulthood.  That data will not be discussed

 

      today.

 

                Now, it is important, in understanding the

 

      generalizability of the data, to know a little bit

 

      about the sample composition.  The inclusion

 

      criteria included outpatients, both boys and girls

 

      age 12-17, with a DSM-IV diagnosis of major

 

      depressive disorder and an IQ greater than or equal

 

      to 80.  Youngsters with severe conduct disorder or

 

      substance abuse, other than nicotine, pervasive

 

      developmental disorders, thought disorder, bipolar

 

      disorder, or history of suicidality or homicidality

 

      were excluded from the trial.

 

                Because suicidality is the question at

 

      issue today, I thought it important to say a little

 

      bit more about these exclusion criteria, kids were

 

      excluded if they had a hospitalization within the

 

                                                                78

 

      previous 3 months or if they were considered to be

 

      high risk, which meant a suicidal event of some

 

      sort within the past 6 months, the presence of

 

      active intent or plan, or if they had suicidal

 

      ideation in the context of a family which was so

 

      disorganized that we felt that even with the

 

      intensive monitoring in the TADS trial framework

 

      that it would not be reasonable to enter them into

 

      a randomized, controlled research study.

 

                This was a moderate to moderately severely

 

      ill population.  We had 439 kids, as you can see,

 

      randomized equally into the 4 groups.  The total

 

      sample on the Children's Depression Rating Scale

 

      had a CDRS scale score of 60.  That, again, is a

 

      mean score of moderate to moderately severely

 

      depressed, with a range from mild to severe

 

      depression.  The T score for that mean score is 75.

 

      That means that these kids were more than 2

 

      standard deviations out from normal with respect to

 

      severity of depression.  The sample was multiply

 

      comorbid, as is characteristic of patients in the

 

      clinical samples.  This was the first major

 

                                                                79

 

      depressive episode for about 90 percent of the

 

      sample.  Ten percent of the sample had had more

 

      than one depressive episode.  The mean duration of

 

      major depression was 42 weeks.  Again, over 50

 

      percent of the sample was comorbid for another

 

      mental disorder, both internalizing and

 

      externalizing disorders; 14 percent of the sample

 

      had ADHD and half of those kids were on concurrent

 

      psychostimulant treatment.

 

                So, unlike the industry-funded trials, the

 

      TADS sample is largely representative of patients

 

      who are treated in clinical practice with major

 

      depressive disorder.  As you might expect, given

 

      the severity of illness and the pattern of

 

      comorbidity, these youngsters suffered significant

 

      functional impairment.  This is the children's CGAS

 

      rating and you can see that the mean CGAS score was

 

      between 40-50, so significant functional impairment

 

      associated with mental illness in this patient

 

      population.

 

                What did we learn in the trial?  This is a

 

      take-home efficacy message.  Four groups, again,

 

                                                                80

 

      began at a CDRS raw score of 60.  These are random

 

      regression analyses looking at the adjusted or

 

      predicted means at baseline, week 6 and week 12 of

 

      treatment.  Actually, all 4 treatments showed

 

      significant improvement, a characteristic of major

 

      depression.  The placebo group and the cognitive

 

      behavioral psychotherapy group were superimposed,

 

      one on top of the other.  There is no additional

 

      benefit from receiving cognitive behavioral

 

      psychotherapy, either in the slope term or at the

 

      end point, over receiving placebo.  There was

 

      significant benefit from fluoxetine alone, and the

 

      largest effect was associated with the combination

 

      condition.  The combination condition beat the CBT

 

      condition and the placebo condition on all 4

 

      efficacy measures.  Fluoxetine beat these CBT on

 

      all 4 measures and placebo and placebo on 3 of the

 

      4 measures.

 

                If we look at the impact of treatment

 

      using effect size calculations, the mean of the

 

      control condition minus the mean of the placebo

 

      condition, divided by the pooled standard

 

                                                                81

 

      deviation, the effect size for the combination was

 

      close to 1.  This is a very large effect.  For

 

      fluoxetine it was around 0.6, a moderate to large

 

      effect.  For CBT there was no difference between

 

      CBT and placebo, effect size calculated relative to

 

      placebo.

 

                If we look at response rates, defined as a

 

      clinical global importance measure rated by the

 

      independent evaluator of much improved or very much

 

      improved, 71 percent of the combination kids

 

      improved; 61 percent of the fluoxetine-treated

 

      patients improved; 43 percent of the cognitive

 

      behavioral psychotherapy treated patients and 35

 

      percent of the placebo-treated patients improved.

 

      Combination statistically was no different than

 

      fluoxetine.  CBT was no different than placebo.

 

      The two drug-containing conditions were superior to

 

      the two non-drug-containing conditions on responder

 

      analysis.

 

                If we look at the effect size calculated

 

      as a derivative of the odds ratio of improvement

 

      for the active treatments relative to placebo for

 

                                                                82

 

      the responder analyses, the results parallel the

 

      analyses on a scale or outcome variable, the

 

      Children's Depression Rating Scale.  The effect

 

      size for combination was 0.8, almost 0.6 for

 

      fluoxetine, and about 0.2 for cognitive behavioral

 

      psychotherapy.  So, again, clear superiority for

 

      the drug-containing conditions, with the largest

 

      effect reserved for the combination of medication

 

      management and CBT.

 

                Now, of interest here are the safety

 

      outcomes from the TADS trial.  Although we spent an

 

      enormous amount of time and energy on measuring

 

      adverse events, particularly measuring the impact

 

      of the treatments on the potential for harm, I

 

      think it is important to point out that the study

 

      did not have safety as a primary outcome.  With 439

 

      subjects randomized to 4 conditions, it is easy to

 

      see that for these outcomes the study is clearly

 

      under-powered.

 

                It is I think important to separate

 

      ideation from behavior.  Despite the exclusion, we

 

      had significant suicidal ideation in the TADS

 

                                                                83

 

      sample.  This is looking at the Reynolds Adolescent

 

      Depression Scale, item 14, and 7.5 percent of the

 

      sample exhibited a score of 4 or above which is the

 

      threshold for clinical investigation on the RADS.

 

      CDRS item 6, serious suicidal ideation, the kind of

 

      suicidal ideation that leads you to consider

 

      hospitalization, 2 percent of the sample met CDRS

 

      item 13 criteria for severe suicidal ideation.  On

 

      the suicidal ideation questionnaire 2 measures, the

 

      SIQ flag which is to prompt clinical investigation,

 

      or elevated scores on any one of the items on the

 

      SIQ that would also prompt suicidal ideation, 29

 

      percent and 10 percent of the sample respectively

 

      on these measures exhibited clinically significant

 

      suicidality.  So, although suicidality was an

 

      exclusion criterion, there was plenty of suicidal

 

      ideation exhibited in the TADS sample at baseline.

 

                Now, as expected, suicidal ideation

 

      occurred across all 4 groups taken in the

 

      aggregate.  One sees here, looking at the CDRS item

 

      13 score, in this case greater than 1, or SIQ

 

      score, SIQ flag greater than 31, significant

 

                                                                84

 

      suicidal ideation at baseline.  It came down at

 

      week 6 and was significantly reduced overall at

 

      week 12.  This is the aggregated data across all 4

 

      treatment groups.

 

                Random regression analyses looking at

 

      between group differences on the SIQ, although it

 

      looks like these groups might be different at

 

      baseline, in fact there were no statistically

 

      significant differences on the SIQ in all 4

 

      treatments.

 

                One sees a different result than we found

 

      in the pattern for depression.  This is placebo;

 

      this is fluoxetine; this is CBT and this is

 

      combination.  The take-home messages here are

 

      three.  First, as we saw in the previous slide,

 

      suicidal ideation improves with treatment

 

      irrespective of which treatment one gets.  Second,

 

      fluoxetine and placebo are indistinguishable with

 

      respect to suicidal ideation, either with respect

 

      to the slope or at entry, indicating that

 

      fluoxetine, at least on average, is not provoking

 

      suicidal ideation.  Finally, the only treatment

 

                                                                85

 

      which separated from placebo with respect to

 

      reducing suicidal ideation was the combination of

 

      fluoxetine and CBT.  So, here the combination

 

      offers a significant advantage over medication

 

      monotherapy.

 

                Moving on to behavior, using a

 

      comprehensive adverse event monitoring procedure,

 

      we looked at the incidence of three kinds of

 

      harm-related adverse events.  Harm-related events,

 

      the broadest category, were defined as harm to

 

      self.  This could involve no suicidal ideation,

 

      ideation or attempt.  Or, harm to others which

 

      required aggressive ideation or actual behavior

 

      involving harming another person or physical

 

      property.  These events are subsumed one within the

 

      next.  So, a suicide-related event, which is a

 

      subset of harm-related events, involves harm to

 

      self, either ideation or attempt.  Then we had

 

      suicide attempts themselves.  What differentiates

 

      harm-related events from suicide-related events is

 

      primarily one subject with aggression and 7

 

      subjects, I believe, who exhibited self-injury

 

                                                                86

 

      without ideation, primarily cutting.

 

                These are the actual rates of harm-related

 

      and suicide-related events divided by treatment

 

      group.  One sees that there is a larger number of

 

      harm-related events and suicide-related events in

 

      fluoxetine-treated kids relative to placebo-treated

 

      kids.  The combination group is intermediate

 

      between harm-related and suicide-related events,

 

      intermediate between fluoxetine and placebo.  The

 

      cognitive behavioral psychotherapy group was

 

      roughly comparable to the placebo group.

 

                If you look at children who received drug,

 

      that is, combining the fluoxetine and the

 

      combination groups and comparing them to the

 

      placebo group, 10 percent, 22 of those

 

      fluoxetine-treated kids exhibited a harm-related

 

      event; 7 percent exhibited a suicide-related event;

 

      and the rates of these events overall were quite

 

      low, 7.5 percent of 439 kids, or 33 kids had a

 

      harm-related event, 24 of 439 kids, or 5.5 percent

 

      exhibited a suicide-related event.

 

                I think it is very important as we move

 

                                                                87

 

      through this discussion to understand that the base

 

      rates of these events are extremely low relative to

 

      the rates that we see for benefit.

 

                If we look at the odds ratios calculated

 

      from the actual rate data, the relative risk is 1.5

 

      for combination, 2 for fluoxetine, less than 1 for

 

      CBT.  Those is calculated relative to placebo.  For

 

      the collapsed category of fluoxetine and

 

      combination the relative risk is slightly greater

 

      than 2.  This is the only statistically significant

 

      relative risk in which the confidence interval

 

      crosses 1.  That is largely because these events

 

      are so rare so the power is quite low to identify

 

      these events.  In fact, the power for detecting a

 

      20 percent difference is about 10 percent.

 

                For suicide-related events there are no

 

      statistically significant differences although, as

 

      you can see from the graph, the odds ratios pretty

 

      closely track the odds ratios for harm-related

 

      events.

 

                The take-home message from this

 

      presentation actually is in this table--no, it is

 

                                                                88

 

      in the next table.  This is the table that looks at

 

      the suicide attempts in the trial.  We had 7 of

 

      them out of 439 kids, or slightly less than 2

 

      percent of the sample,  Two fluoxetine-treated

 

      kids, 4 combination-treated kids, 1 CBT and no

 

      placebo-treated patients made a suicide attempt.

 

      There probably is an imbalance in randomization

 

      which may in part be responsible for this.  There

 

      were more kids with an elevated SIQ flag randomized

 

      to the drug-containing than the non-drug-containing

 

      conditions so it is not clear what to make of this

 

      data.

 

                Here I think is where the take-home

 

      message lies relative to safety.  This is looking

 

      at the benefit/risk ratio using analyses for the

 

      number needed to treat and number needed to harm.

 

      What we see here is fluoxetine compared to placebo,

 

      in the first column; combination compared to

 

      placebo; and the collapsed category, SSRI versus no

 

      SSRI.  The absolute benefit increase is calculated

 

      as the control, the experimental event rate minus

 

      the control event rate.  So, it is the absolute

 

                                                                89

 

      benefit increase for receiving the treatment.  The

 

      absolute risk increase is calculated, again, as the

 

      experimental event rate minus the control event

 

      rate, that is, the risk increase attributable to

 

      the treatment over the placebo condition in

 

      absolute numbers.

 

                The NNT and the NNH are the reciprocal of

 

      the absolute benefit increase and the absolute risk

 

      increase respectively, 1 over the absolute benefit

 

      increase or 1 over the absolute risk increase.

 

      These are defined as the number of patients for

 

      benefit that would need to be treated to find one

 

      patient who had benefit over the benefit occurring

 

      from the control condition or, in the case of the

 

      NNH, the number of patients who would need to be

 

      treated to find one patient who would be harmed

 

      over treatment with the control condition.  So, it

 

      is a nice metric that combines both the absolute

 

      rate and the magnitude of the effect.

 

                One sees clearly here that 27 percent of

 

      patients benefit from treatment with fluoxetine,

 

      with an NNT of 4 which is a large effect; 27

 

                                                                90

 

      percent of patients benefit from treatment with

 

      combination, with an NNT of 3, again a very large

 

      effect; for SSRI versus no SSRI, combining the

 

      categories, 31 percent of patients benefit, again

 

      with an NNT of 3.

 

                The absolute risk increase for a suicidal

 

      event with respect to fluoxetine is 4.7 percent as

 

      compared to placebo; 2 percent for combination over

 

      placebo; and 3 percent for the combined category.

 

      NNH is number of patients that you would need to

 

      treat with the active treatment to find one patient

 

      who would be harmed over the control condition of

 

      21, 50 for the combination condition and 4 for the

 

      collapsed categories.

 

                From a clinical point of view, these

 

      patients would be easy to pick out in a crowd,

 

      easily identifiable who is getting better and who

 

      is not getting better, active treatment versus

 

      control.  These effects are so small and so

 

      uncommon that one could not possibly pick out

 

      patients who would be harmed by the medication

 

      versus patients who would commit these

 

                                                                91

 

      suicide-related event behaviors with placebo

 

      treatment.  If you calculate the NNT to NNH ratio

 

      looking at benefit to risk, one sees clearly here

 

      that the benefit tilts in favor of the treatment,

 

      and particularly the combination treatment.

 

                So, we conclude that the combination of

 

      fluoxetine and CBT is the most effective treatment

 

      for adolescents with major depression.  Fluoxetine

 

      alone is effective but not as effective as the

 

      combination of the two treatments.  CBT alone is

 

      less effective than fluoxetine and not

 

      significantly more effective than placebo.  We also

 

      conclude that placebo is acceptable in randomized,

 

      controlled trials of adolescent major depression

 

      and, in fact, is essential for looking at the

 

      adverse event outcomes, at least in this study.

 

      Suicidality decreases substantially with treatment.

 

      The improvement in suicidality is greatest with the

 

      combination and least for fluoxetine alone.

 

      Fluoxetine does not increase suicidal ideation.

 

      Suicide-related adverse events which are uncommon

 

      may occur more often in fluoxetine-treated

 

                                                                92

 

      patients.  CBT may protect against suicide-related

 

      adverse events in fluoxetine-treated patients.

 

      Taking both risk and benefit into account, the

 

      combination of fluoxetine and CBT appears superior

 

      as a short-term treatment for major depression in

 

      adolescents.

 

                Now, the most practical clinical trialist,

 

      the kind of trial models that are used in other

 

      areas of medicine--cardiology, oncology, infectious

 

      disease for example, would much prefer a large

 

      simple or practical clinical trial in 2000 subjects

 

      to a meta-analysis of 10 under-powered subject

 

      trials.  So, it is our sense from looking at the

 

      FDA data and also the TADS data that we have a

 

      significant signal for drug treatment relative to

 

      suicidality but the evidence is not conclusive.  In

 

      fact, a definitive study has not been done and we

 

      would, as a field and as consumers of this

 

      information, much benefit from a

 

      placebo-controlled, practical clinical trial

 

      comparing fluoxetine to another SSRI, perhaps

 

      sertraline or citalopram.  This trial could be run

 

                                                                93

 

      easily on the child and adolescent psychiatry

 

      trials network, which is a clinical trials network

 

      that we are now putting in place to run these kinds

 

      of trials in the pediatric population.  Thank you.

 

                DR. GOODMAN:  Thank you, John.  My first

 

      question is will you be here tomorrow?

 

                DR. MARCH:  No.

 

                DR. GOODMAN:  Oh, you won't?  That may

 

      affect my subsequent questions because I am sure,

 

      besides myself, there will be a number of questions

 

      for you.  I don't know if we have time to take them

 

      all right now.  I wonder if there is any other

 

      option, Anuja.  What time do you leave today, Dr.

 

      March?

 

                DR. MARCH:  Noon.

 

                   Committee Discussion on TADS Trial

 

                DR. GOODMAN:  I am going to ask a

 

      question.  My understanding in looking at your

 

      results is that on the categorical measures of

 

      response fluoxetine is superior to placebo.

 

      However, if you look at a comparison of the mean

 

      scores on the CDRS fluoxetine is not superior to

 

                                                                94

 

      placebo.  Is that correct?

 

                DR. MARCH:  The slope term on the random

 

      regression analysis for the CDRS, the p value was

 

      0.08 for fluoxetine versus placebo.  Fluoxetine was

 

      statistically significantly different than CBT but

 

      not placebo.

 

                DR. GOODMAN:  So, from a standpoint of

 

      FDA, if this trial had been submitted to the FDA

 

      and you didn't have the CBT group, it seems to me

 

      that it might be classified as a negative study.

 

                DR. MARCH:  It would have been classified

 

      as a negative study using the CDRS as the primary

 

      endpoint, the slope term.

 

                DR. GOODMAN:  Do you have any comments

 

      about the methodology or outcome measures we are

 

      using and whether we are using the most appropriate

 

      ones in your opinion?

 

                DR. MARCH:  Well, I think it is actually a

 

      very important question.  If you look at the

 

      fluoxetine outcomes on the predicted endpoint, the

 

      week 12 endpoint on the CDRS predicted by the CDRS

 

      slope, on the clinical global improvement measure

 

                                                                95

 

      dichotomized and on the Reynolds Adolescent

 

      Depression Scale fluoxetine was statistically

 

      better than placebo.  It was simply a near miss on

 

      the slope term, which probably relates to the way

 

      the random regression analyses handle standard

 

      errors.  So, my sense of the story that the data is

 

      telling us is that fluoxetine--and also if you look

 

      at the effect size calculations--the story the data

 

      is telling is that fluoxetine is an effective

 

      treatment and it would be a mistake to consider

 

      this a negative trial.  On the other hand, the

 

      technical definition used by the FDA would require

 

      that the study be considered negative.

 

                DR. GOODMAN:  Dr. Perrin?

 

                DR. PERRIN:  On the other side of the

 

      equation, you made comments that the sample was

 

      somewhat different from some of the trials that

 

      have been sponsored by industry.  Could you be a

 

      little bit more specific about what the differences

 

      are, and how they might have affected the results,

 

      and what are the implications for meta-analyses of

 

      these studies?

 

                                                                96

 

                DR. MARCH:  I think it is a very important

 

      question, and we have a paper that is in press in

 

      The Journal of Child Medicine Psychiatry, the

 

      "orange journal," which describes the TADS sample

 

      in some detail and compares the TADS sample to

 

      epidemiologic samples and to treatment samples,

 

      both on the pharmacotherapy side, primarily the

 

      industry data sets, and also the cognitive

 

      behavioral psychotherapy trials, of which there are

 

      13 published at this point.  In general, our sample

 

      is not substantially different from either the

 

      epidemiologic or the treatment seeking samples,

 

      with the caveat that we are slightly sicker and

 

      slightly more comorbid, particularly relative to

 

      the CBT samples.

 

                So, given that the range of depression

 

      goes from mild to severe and half the sample is

 

      comorbid, there are plenty of patients in the data

 

      set who resemble the mildly ill patient all the way

 

      up to the severely ill, multiply comorbid patients.

 

      So, I think the result of the TADS trial is

 

      generalizable to the total sample.

 

                                                                97

 

                With respect to meta-analyses, it would be

 

      better to have a very large sample including all

 

      these variations, but by combining the data sets

 

      one gets a better picture, I believe, of the total

 

      variation in the patient population than simply

 

      using the industry data sets which tend to exclude

 

      the more complicated and clinically ill patients.

 

                DR. GOODMAN:  Dr. Newman, did you have a

 

      question?

 

                DR. NEWMAN:  Normally when you use a

 

      continuous outcome you have greater power than when

 

      you dichotomize.  I assume that is why you

 

      specified that as the endpoint at the beginning of

 

      the trial.  A reason why you might not is that the

 

      medication helps maybe a majority but actually

 

      harms a minority and then you could actually see

 

      that if you dichotomize the percent to improve is

 

      statistically significantly greater in the

 

      fluoxetine group but the mean may not be

 

      significantly greater because there are some people

 

      who are harmed and they drag the mean down, whereas

 

      they have no effect on the dichotomized variable. 

 

                                                                98

 

      Did you look to see whether there was evidence that

 

      the variation in the standard deviation in the

 

      effect size differed between the two groups and

 

      might have been greater with fluoxetine?

 

                DR. MARCH:  That was actually the point

 

      that I made, that the standard errors are larger in

 

      the fluoxetine-treated group than in the combo or

 

      the placebo--

 

                DR. NEWMAN:  Actually, not just the

 

      standard errors but the standard deviation, meaning

 

      that, in fact, there are some people who are harmed

 

      by it and that diminishes the apparent benefit when

 

      you average.

 

                DR. MARCH:  It would be impossible to look

 

      at the standard errors or the standard deviation

 

      and make a judgment about harm because there is a

 

      fair amount of variability data point to data point

 

      which is intrinsic to the disorder.  Some patients

 

      get better; some patients deteriorate.

 

                We do have in the safety paper a whole set

 

      of analyses looking at shifts, which I am not

 

      confident enough in to have wanted to present

 

                                                                99

 

      today.  We will try to examine what percentage of

 

      patients are getting worse with respect to ideation

 

      and behavior, and how that relates to treatment

 

      classification and also how it relates to other

 

      adverse events like mania activation, anxiety

 

      disinhibition and so on.  I think the secondary

 

      paper is going to shed a fair bit of light on these

 

      questions.

 

                DR. GOODMAN:  Dr. Pfeffer?

 

                DR. PFEFFER:  I have two questions.  One

 

      is were there any differential dropout rates in the

 

      samples?  This also relates to the question of

 

      compliance in the different treatments.  My last

 

      question is these were intent-to-treat analyses?

 

                DR MARCH:  All very good questions.  The

 

      analyses are all intent-to-treat.  Although I

 

      didn't present the data, if we look at observed

 

      cases analyses, those who were still on their

 

      assigned arm at any given assessment point or

 

      completer analysis, the results are exactly the

 

      same.  About 10 percent of the kids in each

 

      treatment overall dropped before the week-12 data

 

                                                               100

 

      point.  Another 10 percent were what we call

 

      prematurely terminated.  That is, for ethical

 

      reasons.  They received an out of protocol

 

      treatment at some point during the first 12 weeks

 

      of the study.  There were no statistically

 

      significant differences across treatment groups in

 

      either the rate of dropping out or the rate of

 

      receiving an ancillary treatment, that is, a

 

      premature termination.

 

                You will see this afternoon when FDA

 

      presents its analysis of the TADS data that the

 

      odds ratios for being harmed by receiving

 

      fluoxetine are greater than we presented, or I

 

      presented this morning on behalf of the TADS team.

 

      That is because the FDA data set excluded those

 

      kids who were prematurely terminated and received

 

      another treatment.  That actually represented two

 

      kids in the placebo group and that, in turn,

 

      inflated the odds ratios in the FDA results versus

 

      the TADS results.  So, there is some method

 

      variance in there which accounts for the

 

      differences between the two findings.

 

                                                               101

 

                DR. GOODMAN:  Dr. Gorman?

 

                DR. GORMAN:  Does analysis of your data

 

      set allow interpretation of the time of onset of

 

      treatment to behaviors that we are studying today?

 

                DR. MARCH:  That is a very good question

 

      and, in fact, one that we will address in the

 

      secondary paper.  I can tell you that the majority

 

      of the events occurred within the first 6 weeks but

 

      not within the first 2 weeks.  But I don't have

 

      that data presented in slide form so I can show it

 

      to you, but it will be in the safety paper that we

 

      are currently preparing.

 

                DR. GOODMAN:  So you don't know what the

 

      differential rates are between the groups at this

 

      point, particularly between fluoxetine and placebo?

 

                DR. MARCH:  In terms of time?

 

                DR. GOODMAN:  Yes, in terms of the early

 

      events.

 

                DR. MARCH:  My general impression, looking

 

      at the data, is that the fluoxetine events occurred

 

      early and the placebo events occurred later, which

 

      is kind of what you would expect given what we know

 

                                                               102

 

      about the compounds.  But I wouldn't want to cite

 

      chapter and verse or have you base your decisions

 

      based on that because we haven't completed the

 

      final analyses of the data.

 

                DR. GOODMAN:  Dr. Rudorfer, you will be

 

      the penultimate questioner.

 

                DR. RUDORFER:  If I can go back to the

 

      characteristics of the patients for a moment, we

 

      will be looking at a number of studies that were

 

      submitted to the FDA by various sponsors, and it

 

      seems to me that the TADS inclusion criteria go

 

      beyond DSM-IV in terms of length of illness and

 

      degree of dysfunction in various spheres of life.

 

      Could you comment on that?

 

                DR. MARCH:  Sure, it is a very good

 

      question.  That is, the exclusion criteria included

 

      requirements that were designed to ensure a stable

 

      baseline.  So, we required at least six weeks of

 

      mood disorder symptoms that crossed two or three

 

      contexts--home, peers in school--which, of course,

 

      are not required in the DSM-IV criteria.  This was

 

      done in part to minimize the chance of a placebo

 

                                                               103

 

      response and to ensure that we had a sick patient

 

      population that would be both ethical to randomize

 

      and would offer some opportunity for the

 

      combination treatment to separate from the two

 

      monotherapy conditions.

 

                I think we actually designed a very good

 

      experiment, and looking at a 35 percent placebo

 

      response rate did exactly what we had intended to

 

      do.  But in that sense, this population is sicker

 

      perhaps than what is seen in the industry data sets

 

      and certainly sicker than what is seen in the CBT

 

      data sets on average.

 

                DR. GOODMAN:  I will permit two final

 

      questions and that is it, one from Dr. Pine and

 

      then Dr. Fant.

 

                DR. PINE:  I want to return to the first

 

      question from Dr. Goodman as far as how this study

 

      would be evaluated from an FDA perspective.  My

 

      sense from reading the paper is that there were two

 

      primary outcome measures and three analyses, and

 

      two of the three were positive so that the CGI

 

      analysis done categorically was positive, the CDRS

 

                                                               104

 

      analysis done categorically was positive, and it

 

      was only the third analysis, the CDRS continuous

 

      measure, that was not positive.

 

                So, my take on that from an FDA standpoint

 

      of, you know, do the primary outcome measures make

 

      it or not is that it would be closer to positive

 

      than negative.  Do I have that right?

 

                DR. MARCH:  You have it partially right.

 

      There is a CDRS slope analysis, and whether that is

 

      positive or negative depends on whether you treat

 

      the intercept term as random.  I mean, there is a

 

      fair amount of method variance on a subtle level

 

      that can tilt these things one way or the other

 

      when it is a near miss.  There is a CDRS endpoint

 

      analysis based on the predicted or marginal mean.

 

      There is a categorical analysis, logistic

 

      regression, and there is a self-report scale which

 

      was included, the Reynolds Adolescent Depression

 

      Scale, which was included because the CBT

 

      literature relies heavily on patient self-report.

 

      Three of those four measures, all but the CDRS

 

      slope analysis, were positive for the

 

                                                               105

 

      fluoxetine-placebo comparison.  The CDRS slope

 

      analysis, again, was a p value of 0.08, a near

 

      miss.

 

                So, I think the take-home message is

 

      actually in the effect sizes, not in whether you

 

      are looking at p values or not.  Clearly,

 

      combination and fluoxetine have larger effect

 

      sizes, meaningful effect sizes relative to placebo

 

      as contrasted to CBT.

 

                DR. FANT:  For the sake of the study I

 

      know it was necessary to exclude certain patients

 

      to optimize the conditions for the study, but I

 

      think in real-world practice a lot of the patients

 

      who were excluded would be patients who would be

 

      prescribed medication under various conditions.  Is

 

      there any reason, from your standpoint or

 

      perspective, to think that that population of

 

      patients may be at a different risk for fulfilling

 

      suicidal attempts, ideation, and carrying it

 

      through to the ultimate result, or may be affected

 

      differently by the medication than patients that

 

      are not excluded from the study?

 

                                                               106

 

                DR. MARCH:  That is a very good question.

 

      That is, is there some issue to believe that there

 

      would be a differential treatment response in

 

      patients who would be excluded, particularly

 

      excluded for harm to self or others, as compared to

 

      the TADS sample of patients?  I don't know of any a

 

      priori reason to believe that there would be a

 

      differential treatment effect relative to the TADS

 

      sample.  I do think it is quite clear from the

 

      treatment and epidemiologic literature that they

 

      would be at higher risk for adverse harm-related

 

      outcomes but whether they would be more at risk

 

      than, say, the TADS sample patient I don't think we

 

      know.  My guess as a clinician is probably not.

 

                We are actually doing an NIMH-funded study

 

      called the Treatment of Adolescent Suicide

 

      Attempter Study, in which we are comparing a

 

      medication algorithm to cognitive behavioral

 

      psychotherapy to the combination--no untreated

 

      control condition obviously in this sample--to try

 

      to understand something about treatment for this

 

      particular patient population precisely because

 

                                                               107

 

      they have been excluded from these other trials,

 

      and we need additional data on their care.  So,

 

      that trial is now under way and should be completed

 

      in the next couple of years.

 

                DR. GOODMAN:  Thank you very much, John.

 

      The final question that I will take the chairman's

 

      privilege to ask is do you have data that you

 

      haven't presented yet on long-term outcome based on

 

      this trial?

 

                DR. MARCH:  The final subjects in the

 

      trial are out in a naturalistic follow-up window so

 

      that 36-week data is in the can, but that data set

 

      has not been cleaned and locked yet.  We expect it

 

      will be cleaned and locked and ready for analysis

 

      in the spring, and we hope to have that data in

 

      press by this time next year.

 

                DR. GOODMAN:  Thank you very much, John.

 

                DR. MARCH:  Thank you.

 

                DR. GOODMAN:  I would like to ask our next

 

      speaker to come forward, Dr. Greg Dubitsky.

 

           Characteristics of Pediatric Antidepressant Trials

 

                DR. DUBITSKY:  Good morning.  You just

 

                                                               108

 

      heard about the TADS trial from Dr. March.  I would

 

      like to now go on and briefly summarize the other

 

      studies that were included in the FDA's primary

 

      analysis of suicidality.

 

                I do want to emphasize that my review and

 

      this presentation are really descriptive only.  I

 

      am not going to touch on efficacy outcomes or

 

      safety outcomes.  The discussion of the risk of

 

      suicidality in these trials with be presented later

 

      this morning by Dr. Hammad.

 

                The study pool, again excluding the TADS

 

      study, consisted of 23 placebo-controlled studies

 

      which were conducted between 1984 and 2001.  Each

 

      study was done with one of nine different

 

      antidepressant drugs and studied patients with one

 

      of five different diagnostic indications; major

 

      depression, obsessive compulsive disorder,

 

      generalized anxiety disorder, social anxiety

 

      disorder or attention deficit disorder.

 

                These studies all had some features in

 

      common.  They were all randomized, double-blind,

 

      placebo-controlled.  They utilized a parallel group

 

                                                               109

 

      design and a flexible dosing regimen.

 

                I did prepare a handout to go with this

 

      talk which should be in your packets, at least for

 

      the advisory committee members.  It consists of two

 

      tables which summarize some of the design

 

      characteristics of these 23 studies.  Table 1 has

 

      some basic study information, to include the

 

      diagnostic indication, the age range that was

 

      studied, number of patients by treatment group, the

 

      duration of double-blind treatment, and the dose

 

      range that was used in the particular study.

 

                I would like to point out though that I

 

      don't intend for everybody to read this and

 

      memorize it; this is really for reference for later

 

      this morning when you hear about the analysis of

 

      these trials.

 

                The second table in the handout includes

 

      some information on screening and exclusionary

 

      criteria.  Some of the studies used very extensive

 

      diagnostic screening.  I have indicated those in

 

      the table.  I have also indicated information on

 

      whether there was a placebo lead-in, and also

 

                                                               110

 

      whether certain exclusionary criteria were employed

 

      in the various studies to include whether people

 

      were excluded who had a history of treatment

 

      resistance, current suicide risk, history of a

 

      suicide attempt, bipolar disorder, or family

 

      history of bipolar disorder.

 

                My review of these studies did include a

 

      number of other variables.  I have listed in these

 

      two tables the most relevant ones but in my review

 

      that is on the Internet I do describe some other

 

      characteristics which you might be interested in,

 

      such as the location and number of sites, whether

 

      stratified randomization by age group was utilized

 

      and other exclusionary criteria such as homicidal

 

      risk or the presence of psychotic symptoms.

 

                There were a few notable differences

 

      between these studies that I would like to point

 

      out.  One study with Prozac, HCCJ, was a very small

 

      study.  It was the smallest of the 23 studies, with

 

      only about 40 patients and it was terminated early.

 

                Only one of the 23 studies included an

 

      active control arm.  That was study 329 with Paxil

 

                                                               111

 

      in major depressive disorder.  That included an

 

      imipramine control arm.  The others only had a

 

      placebo control.

 

                Two of the studies did include inpatients

 

      as well as outpatients, the Celexa study, 94404,

 

      and Wellbutrin, 75.

 

                Last, I did want to point out that three

 

      of the studies did use a rather extensive

 

      diagnostic screening of the patients, much more so

 

      than the other studies, Prozac studies X065 and

 

      HCJE, and Paxil study 329.  Those three studies

 

      were done in major depressive disorder.

 

                One other difference involves the

 

      treatment options after patients completed the

 

      acute phase of double-blind treatment.  This was

 

      quite variable across the trials.  In eight studies

 

      there was a taper of acute treatment before

 

      discontinuation.  Seven other trials just abruptly

 

      discontinued treatment, and there was no provision

 

      for continued treatment.  Five trials did allow for

 

      continuation of open-label treatment, and in three

 

      trials patients could continue double-blind

 

                                                               112

 

      treatment.

 

                However, this was also very variable

 

      within trials.  For instance, in Paxil 329

 

      responders could continue double-blind treatment

 

      but non-responders were tapered off treatment.

 

      This variability in the follow-up treatment

 

      following the acute phase made it very difficult to

 

      do any analysis of suicidality-related events post

 

      double-blind treatment.

 

                I would like to point out that none of

 

      these studies was specifically designed to assess

 

      suicidality.  Suicide attempts and ideation were

 

      detected only through routine safety monitoring,

 

      that is, through treatment emergent adverse events

 

      and through suicide-related items on various

 

      depression scales, such as the HAM-D and the CDRS.

 

      One problem with this is that often descriptions of

 

      possibly suicide-related events were rather vague

 

      or incomplete and often made it difficult to reach

 

      a classification.

 

                I have no specific conclusions since this

 

      is really a descriptive review and overview of the

 

                                                               113

 

      studies.  I think one of the important questions

 

      that arises from this information though is whether

 

      any of these differences in design characteristics

 

      could contribute to any observed differences in

 

      suicidality risk that we observed across these

 

      studies.  That is a question that will be addressed

 

      later this morning by my colleague, Dr. Hammad.

 

      So, that is all I have.

 

                DR. GOODMAN:  Thank you for being concise

 

      and providing us with an outstanding handout for

 

      our reference.  We have one question.  Dr.

 

      Rudorfer?

 

                DR. RUDORFER:  Thank you.  Could you

 

      clarify, of the 23 trials how many were submitted

 

      in response to the pediatric exclusivity rule?

 

                DR. DUBITSKY:  I don't have the exact

 

      number.  I believe most of them were but some of

 

      them were submitted well before pediatric

 

      exclusivity took place or came into effect.  I

 

      don't have the exact number off the top of my head.

 

                DR. GOODMAN:  Dr. O'Fallon?

 

                DR. O'FALLON:  Asking the question in a

 

                                                               114

 

      somewhat different way, the data that you have for

 

      this reanalysis, does any of that data come from

 

      outside, beyond the data that was submitted to the

 

      FDA?  That is, were you able to go in and obtain

 

      data from studies that were never submitted to the

 

      FDA for approval or whatever?

 

                DR. DUBITSKY:  Well, to my knowledge,

 

      there was one study that had not been submitted as

 

      part of an efficacy supplement or an approval

 

      package.  The other ones, I believe, were.  Dr.

 

      Hammad actually requested data sets for all these

 

      studies.  Correct me if I am wrong, but I believe

 

      we had relatively complete data sets to allow

 

      reasonable analysis for all these studies.

 

                DR. O'FALLON:  But I am asking whether

 

      there are, as some are claiming, studies that were

 

      done but were never submitted to the FDA.  Are

 

      there any of those data here, if they exist?

 

                DR. DUBITSKY:  There are some studies that

 

      are not included in this analysis, but those are

 

      mainly open-label continuation studies of the acute

 

      studies.  Also, there were a number of pediatric

 

                                                               115

 

      pharmacokinetic studies but I think for obvious

 

      reasons we didn't include those in the analysis.

 

      But, to my knowledge, I think we have everything.

 

                DR. GOODMAN:  Dr. Laughren, do you also

 

      want to respond to the question?

 

                DR. LAUGHREN:  I think I can respond to

 

      that.  The vast majority of these programs were

 

      submitted under pediatric exclusivity so the

 

      companies were required to submit every scrap of

 

      data they had as part of those supplements.  The

 

      only trial here that was not submitted as part of

 

      an application, in terms of a company trial, was

 

      the ADHD study for Wellbutrin.  The other study

 

      that we have included safety data for is the TADS

 

      trial and, of course, that was also independent.

 

      But those are the only two trials of the 24 that we

 

      looked at that were not submitted as part of an

 

      application.

 

                DR. GOODMAN:  Dr. Marangell?

 

                DR. MARANGELL:  How many of the studies

 

      excluded family history of bipolar disorder?

 

                DR. DUBITSKY:  Let's see, actually I think

 

                                                               116

 

      I have that in table 2.  I don't know the number

 

      off the top of my head.  It looks like about ten of

 

      the studies excluded a family history of bipolar

 

      disorder.

 

                DR. MARANGELL:  Thank you.

 

                DR. GOODMAN:  Dr. Perrin?

 

                DR. PERRIN:  You are saying basically that

 

      the extensive diagnostic screening occurred only in

 

      three studies, I believe.  Is that right?

 

                DR. DUBITSKY:  I am sorry?

 

                DR. PERRIN:  The extensive diagnostic

 

      screening occurred only I think in three

 

      studies--one of the points that you made.  Does

 

      that give us some information about the potential

 

      diagnostic heterogeneity and also raise questions

 

      about whether entrance into these studies of

 

      children, ages 7-17, might not have had MDD in the

 

      MDD studies?  My last related question is, since I

 

      am not a psychiatrist at all, what do we know about

 

      the ability to distinguish bipolar disorder from

 

      MDD in the 7-17 year-olds?

 

                DR. DUBITSKY:  Well, it is true that in

 

                                                               117

 

      looking across all 23 studies, those three studies

 

      did stand out as far as using more extensive

 

      diagnostic criteria.  I believe that it certainly

 

      is possible that we might have more confidence that

 

      those patients did actually have the diagnosis

 

      under consideration.  Whether that is actually true

 

      or not, I don't know and I don't know any good way

 

      of figuring that out.

 

                I am not a child psychiatrist so I can't

 

      answer your last question about the ability to

 

      diagnose.  I understand it is very tricky though.

 

                DR. GOODMAN:  Thank you again.  I would

 

      like to ask Dr. Kelly Posner to come up to the

 

      podium to present.  Dr. Posner is from Columbia

 

      University and she will be talking to us about the

 

      reclassification of the clinical trials data

 

      according to suicidality.

 

                  Classification of Suicidality Events

 

                DR. POSNER:  I would like to start by

 

      introducing my expert work group from Columbia that

 

      included myself, Dr. Maria Oquendo, Dr. Barbara

 

      Stanley and Dr. Madelyn Gould.  Dr. Stanley and Dr.

 

                                                               118

 

      Gould are here with me today.  Our statistical

 

      consultant was Mark Davies.

 

                Why was reclassification needed?  The

 

      problem is that the field is challenged by a lack

 

      of well-defined terminology and common language to

 

      refer to suicidal behavior, and this was reflected

 

      in the lack of standardized language used in the 25

 

      trials in question.  That is why there was

 

      difficulty in interpreting the meaning of all of

 

      these reported adverse events that occurred in

 

      these trials.  So, AEs that should have been called

 

      suicidal may have been missed and there may have

 

      been AEs that were inappropriately classified as

 

      suicidal.

 

                Here are some illustrative examples of the

 

      difficulties in adverse event labeling in the

 

      field.  I want to make sure to note that these

 

      labels have nothing to do with the labels the

 

      sponsor gave these events, but just original

 

      investigators at the site.  Again, they are extreme

 

      examples just to reflect the problem.

 

                You see the first one, it says patient

 

                                                               119

 

      attempted to hang himself with a rope after a

 

      dispute with his father.  Investigator did not

 

      consider this event to be a suicide attempt but

 

      called it a personality disorder in this 10

 

      year-old patient.

 

                The second one is one we have all heard a

 

      lot about.  The patient is reported to have engaged

 

      in an episode of auto-mutilation where she slapped

 

      herself in the face, called a suicide event.  Then,

 

      the patient took 11 tablets impulsively then went

 

      to school--called a medication error.

 

                So, how do we address this problem?  Well,

 

      a common set of guidelines needed to be applied and

 

      we needed to look at the data consistently across

 

      trials using research-supported definitions and

 

      concepts that had reliability and validity.  We

 

      also needed to broaden the range of adverse events

 

      that we were looking at.  This was for two reasons.

 

      The first one is to avoid bias in readings.  We

 

      wouldn't have wanted the expert raters only to have

 

      had what the sponsors had identified as possibly

 

      suicidal.  Also, to identify suicidal events that

 

                                                               120

 

      may have been missed.

 

                So, what was included in this broadened

 

      range of events?  Of course, the events originally

 

      identified by the sponsors as possibly suicide

 

      related, all accidental injuries which included

 

      accidental overdoses, and serious adverse events

 

      which includes life-threatening events and all

 

      hospitalizations.

 

                Why did we need experts in suicide?  Well,

 

      you all heard about the limited information

 

      provided in the narratives, particularly frequent

 

      lack of stated suicidal intent.  So, only experts

 

      in suicide would have allowed for inference based

 

      on details of behaviors and related clinical

 

      information.

 

                This is the list of our very distinguished

 

      international panel of experts.  I will just read

 

      their names very quickly, Drs. Bautrais, Brent,

 

      Brown, Van Herringen, King, Mazark, O'Carroll,

 

      Rudd, Spirido and Miller.

 

                So, what was the Columbia classification?

 

      I want to move to this slide because it goes

 

                                                               121

 

      through the definitions which I will just go

 

      through briefly.  Suicide attempt, of course, which

 

      is defined as a self-injurious behavior associated

 

      with some intent to die.  Intent can be stated or

 

      inferred by the rater.  It is important to know

 

      that no injury is needed.

 

                Then there was preparatory actions towards

 

      imminent suicidal behavior.  So, the person takes

 

      steps to injure himself but is stopped by self or

 

      other, anything beyond the threshold of a

 

      verbalization but not quite making it to a suicide

 

      attempt.

 

                Then we had self-injury behavior, intent

 

      unknown.  These are cases where we know there was

 

      some self-injury but we don't know what the intent

 

      was.  So, the associated intent to die is unclear

 

      and cannot be inferred.

 

                Self-injurious behavior with no suicidal

 

      intent is the next category.  That is where, again,

 

      we know there was deliberate self-harm but there

 

      was no intent to die so behavior is intended to

 

      affect other things.  This is what we think of

 

                                                               122

 

      self-mutilation typically.

 

                Suicidal ideation was the next relevant

 

      category, which can be passive or active thoughts,

 

      passive thoughts of wanting to be dead or active

 

      thoughts about killing oneself.

 

                Then we had all the other categories.

 

      That is essentially one rating, anything other than

 

      deliberate self-harm or something suicidal.  That

 

      could include accidents, psychiatric events or

 

      medical events.

 

                Finally, we had not enough information,

 

      which meant that there was insufficient information

 

      for a rater to be able to say whether or not there

 

      was some deliberate self-harm or something

 

      suicidal.

 

                The scheme is laid out conceptually here

 

      for you.  I think it helps make a little more sense

 

      of it.  The blue boxes refer to what you will hear

 

      later as the FDA's primary outcome.  These are

 

      ratings that are considered definitively suicidal,

 

      suicidal behavior and suicidal ideation.  You see

 

      codes 1, 2 and 6.  Suicide attempt, preparatory

 

                                                               123

 

      actions and ideation.  The next are non-suicidal

 

      events, all the other events and the self-injurious

 

      behavior without suicidal intent, and then

 

      indeterminants.  The green boxes are what will be

 

      referred to as the sensitivity analysis, things

 

      that could have been suicidal but there is no way

 

      to know.

 

                So, what was done?  The classification

 

      methodology involved, of course, choosing the

 

      expert panel who had expertise in adolescent

 

      suicide and suicide assessment, based on reputation

 

      and publications.  They had no involvement in

 

      industry youth depression trials in question, and

 

      no expert rater was employed by Columbia

 

      University.

 

                We had a training teleconference to review

 

      classification parameters, then training

 

      reliability exercise to ensure appropriate

 

      application of classifications.  All case

 

      narratives were blinded to any potentially biasing

 

      information, and I will review that in a minute.

 

      There was random distribution of 427 events to 9

 

                                                               124

 

      expert raters.  Each case was independently rated

 

      by 3 raters.  Each rater received approximately 125

 

      events to rate, and any group of 3 raters shared

 

      only 5 cases.  All ratings were reviewed for

 

      quality assurance and identification of

 

      non-agreement cases.  Consensus teleconferences

 

      were held for any disagreement cases, and there was

 

      double data entry for quality assurance.

 

                Now, what was the consensus process I

 

      referred to?  If ratings did not have unanimous

 

      agreement, then a consensus discussion was held.

 

      Each case was discussed by the three raters

 

      involved only.  Discussion of each case was led by

 

      an expert other than those originally assigned the

 

      case.  The goal of the discussion was to reach 100

 

      percent agreement.  If 100 percent agreement could

 

      not be reached, the case then became indeterminate.

 

      Sometimes the original majority opinion did not

 

      always end up as the final consensed

 

      classification.  In other words, if there was a

 

      minority rating, sometimes that ended up being the

 

      final outcome.

 

                                                               125

 

                Now, what was rated?  Blinding of event

 

      narratives to avoid bias included--we received the

 

      narratives from the FDA blind to all potential drug

 

      identifying information.  This included drug name,

 

      company sponsor name, patient identification

 

      numbers, whether they were on an active or placebo

 

      arm, and any and all medication names and types

 

      because there could be associated treatments that

 

      might bias somebody or tip them off as to what drug

 

      was being talked about and, of course, primary

 

      diagnosis.  We also did some additional blinding of

 

      potentially biasing information which included the

 

      original label of the event given by the

 

      investigator or sponsor and serious or non-serious

 

      labels.

 

                Rating guidelines--how was the

 

      classification scheme applied?  We wanted the

 

      experts to apply concepts using their clinical

 

      expertise and judgment; to use their experience to

 

      integrate clinical information and infer when

 

      appropriate.  We wanted them to have a reasonable

 

      certainty in order to commit to a rating, and

 

                                                               126

 

      rating was based on what was probable, not what was

 

      possible.

 

                The guidelines for intent inference

 

      involved inferring if something was clinically

 

      impressive, and I am going to give you an example

 

      of that in a moment, or using two smaller pieces of

 

      clinical information.  The clinical information

 

      that could inform inference of intent included

 

      clinical circumstances.  That could be method used,

 

      number of pills; past history of suicide attempt;

 

      past history of self-injurious behavior or

 

      self-mutilation; and family history of suicide or

 

      suicide attempts.

 

                Now, here is a case example of inferred

 

      intent, what we call clinically impressive

 

      circumstances.  This is the first time you are

 

      actually seeing one of these real narratives.  In

 

      this case clinical impressiveness actually

 

      overruled stated intent, so you see the subject

 

      attempted suicide by immolation.  Her siblings

 

      doused the flames immediately.  She was left with

 

      minor burns on her abdomen and on her left

 

                                                               127

 

      shoulder.  The subject admitted she was angry with

 

      her parents for going away and leaving her alone at

 

      home because she was fearful.  The subject admitted

 

      that she had acted impulsively and had not intended

 

      to kill herself.

 

                Here are more examples.  This is another

 

      example actually of clinically impressive

 

      circumstances which was ultimately called a suicide

 

      attempt.  It is also important to know that we had

 

      no idea what the sponsor ratings were but both

 

      these cases were consistent with what the sponsor

 

      had said as well.

 

                This case involved a 16 year-old who

 

      claimed to have ingested 100 tablets of study med

 

      after a fight with her mother.  The patient

 

      informed her mother.  The mother brought her to the

 

      ER.  The patient reported feeling shaky.  Emergency

 

      room physician said she was slightly tachycardic

 

      with a pulse of 100.  The tox. screen was negative

 

      but the patient did have some illness and she

 

      stayed in the ER until she was asymptomatic, and

 

      then was later admitted to the psych. unit.

 

                                                               128

 

                Another example of a suicide attempt, a

 

      patient age 17 took an overdose of 20 tablets.  In

 

      the father's opinion the overdose was 5 tablets.

 

      The patient didn't have any symptoms of an

 

      overdose, not even nausea, but it was classified as

 

      a suicide attempt, of course.

 

                More overdose examples.  You see in this

 

      first example there were 113 tablets and it

 

      exemplifies how medication types were blinded so

 

      you see all the different numbers there.  Then, the

 

      next one is patient aged 15, impulsively slit her

 

      wrist following an altercation with her mother.

 

      Finally, age 17, attempted suicide by taking 8

 

      tablets after a fight with her father, whom she

 

      considered harsh and rejecting.

 

                Now, these are examples of self-injurious

 

      behavior, intent unknown.  So, this is where we did

 

      some harm but we just don't know why.  A patient

 

      aged 10 had superficial scratches, left arm,

 

      scratched herself with scissors.  That was all the

 

      information that was there essentially.

 

                Patient, aged 14, ingested or simulated

 

                                                               129

 

      ingestion of 2-3 cigarettes.  The patient was

 

      reported as feeling tired and playing a theatrical

 

      role.  Subject, aged 9, reported he had ingested 4

 

      of his brother's tablets on a dare.  Finally,

 

      patient, aged 10, swallowed a small amount of

 

      after-shave lotion while angry.  It is hard to know

 

      what to make of those without information.

 

                Examples of preparatory actions, age 16,

 

      tried to hand herself and was prevented from doing

 

      so by her family.  The next case, age 18, a voice

 

      commanded him to jump from the roof.  Although he

 

      went up, he did not jump.  Next one, age 10, held a

 

      kitchen knife to her neck while alone but did not

 

      cut herself.  Event was not witnessed.  Finally, a

 

      patient, age 18, was noted to be hostile, hopeless

 

      and helpless and had written suicide notes.  As I

 

      said, anything beyond a verbalization was

 

      considered a preparatory action, including writing

 

      a suicide note.

 

                These are good examples of self-injurious

 

      behavior, no suicidal intent.  In the first case

 

      the patient stated there was increased family

 

                                                               130

 

      tension.  She made superficial cuts on her wrist

 

      with an Exacto knife.  The patient and mother

 

      reported the cuts weren't deep and they looked like

 

      cat scratches.  Patient adamantly denied any

 

      suicidal gestures or intent.  She stated she only

 

      wanted a release and that cutting and hitting her

 

      legs offers her a release.

 

                The second case, denied suicidal thoughts.

 

      The first time she cut herself was age 16.  She

 

      stated she did it for attention.  Today her cutting

 

      was more spontaneous. She reported that cutting

 

      gives her a good weird feeling.

 

                So, what were the results?  This slide

 

      just refers to what we are talking to in our

 

      results, or referring to, and there were 427 events

 

      but some patients had more than one event so we

 

      ultimately, in the reliability data, used 378

 

      cases.  We employed the same severity hierarchy

 

      that the FDA used.  So, we just took the most

 

      severe event for cases that had multiple events.

 

                Expert rater consensus--only two of 427

 

      cases had no agreement among the three raters.  So,

 

                                                               131

 

      each rater had a different rating in only two

 

      cases.  Fifty-nine cases had agreement among two of

 

      three raters, and those had to go to

 

      teleconference.  There were no cases in which

 

      consensus was not able to be reached during the

 

      teleconference and they, of course, had that

 

      option.

 

                Now, discordant cases between the sponsor

 

      and Columbia classifications, there were 40 out of

 

      the 427 cases in which the sponsor and the Columbia

 

      classification differed.  Twenty-six new cases were

 

      identified that had not been identified by the

 

      sponsor as possibly suicide-related.  There were

 

      two new cases of self-injurious behavior without

 

      suicidal intent that had been labeled something

 

      other than deliberate self-harm, and 12 cases were

 

      originally called possibly suicidal and were

 

      changed to something other than possibly suicidal.

 

                Here it breaks it down for you further.

 

      Of the 26 new possibly suicide-related events, one

 

      was a suicide attempt; one was a preparatory act;

 

      13 were ideation events; four were intent unknown

 

                                                               132

 

      acts; and seven were not enough information to say

 

      whether there was deliberate self-harm.

 

                Here is an example of one of the newly

 

      identified suicidal events.  This is a preparatory

 

      act.  The patient, age 11, held a knife to his

 

      wrist and threatened to harm himself.  The patient

 

      was hospitalized with an acute exacerbation of

 

      major depressive disorder.  The reason we have this

 

      is because, as I mentioned before, every

 

      hospitalization is a serious adverse event so that

 

      is why this preparatory act was caught.

 

                The events that were changed from suicidal

 

      to something other included two changed to

 

      psychiatric; one changed to an accident; and nine

 

      changed to self-injurious behavior with no suicidal

 

      intent.  Again, our famous example, a patient

 

      reported to have engaged in an episode of

 

      auto-mutilation where she slapped herself in the

 

      face.  The event resolved the same day without any

 

      intervention.

 

                These are actually the kappa, the

 

      agreement between the sponsor and Columbia.  So,

 

                                                               133

 

      Columbia's classification of possibly

 

      suicide-related and the sponsor's classification of

 

      possibly suicide-related, the kappa was 0.77.  You

 

      see in the 2 X 2 table that the numbers correspond

 

      to the numbers that I just went through with you.

 

                Now, if you want to look somewhat more

 

      specifically or at least what we think is more

 

      specific, we did a comparison of what Columbia said

 

      was definitively suicidal and what the sponsor said

 

      was possibly suicidal, and the kappa was 0.69.

 

                Here are the reliability results of the

 

      ratings with the nine expert raters.  The median

 

      ICC was 0.86 and what the FDA will refer to as the

 

      primary outcome variables, you can see the numbers

 

      here, suicide attempts is 0.81; preparatory

 

      actions, 0.89; suicidal ideation, 0.97.

 

                Where do we go from here?  We need to

 

      improve our adverse event reporting for

 

      suicide-related events by developing consistent

 

      terminology; developing guidelines for

 

      classification of suicidality so that adequate

 

      information is provided by the clinician;

 

                                                               134

 

      utilization of research assessment tools, what

 

      questions to ask, how to ask, and what measures aid

 

      this; finally, hopefully, that will lead to

 

      improved, more valid identification and

 

      documentation of suicidality.

 

                DR. GOODMAN:  Thank you very much.  Dr.

 

      Chesney?

 

                DR. CHESNEY:  Thank you.  This is a little

 

      bit of thinking outside the box, but we heard at

 

      the February meeting a number of examples of

 

      homicidal behavior.  I wonder if, in your

 

      speciality, homicidal behavior is ever identified

 

      as being self-injurious primarily to affect

 

      circumstance or to affect an internal state.

 

                DR. POSNER:  No, that did not represent

 

      any of those self-injurious, no suicidal intent

 

      ratings.  So, the classifications that you are

 

      referring to, internal state and circumstance, are

 

      not synonymous at all with the cases that had

 

      homicidal ideation or any kind of aggressive

 

      behavior.  It doesn't mean that it couldn't be

 

      looked at in another analysis but it wasn't

 

                                                               135

 

      represented in these cases.

 

                DR. CHESNEY:  I guess my more general

 

      question, I just wonder in the bigger question,

 

      homicidal behavior outcome is bound to be bad and

 

      self-injurious, and if it is just another factor

 

      that we should consider in this whole picture.

 

      Thank you.

 

                DR. GOODMAN:  Dr. Robinson?

 

                DR. ROBINSON:  Do you know how many of the

 

      events led to hospitalization and how it breaks

 

      down in terms of your classification?

 

                DR. POSNER:  Dr. Laughren, do you know?

 

                DR. LAUGHREN:  I don't have that figure

 

      off the top of my head.  There were a substantial

 

      number of events leading to hospitalization, I

 

      believe somewhere in the ballpark of maybe 40

 

      percent.  I don't have the exact number.  It was a

 

      common outcome.

 

                DR. POSNER:  It is important to know that

 

      we were very narrowly just looking at obtaining the

 

      most appropriate label for the particular event in

 

      question, and we didn't have any of the surrounding

 

                                                               136

 

      information or follow-up information in this

 

      particular piece of the project.

 

                DR. GOODMAN:  Dr. Wang?

 

                DR. WANG:  I have a question.  Do you know

 

      how many of the sponsors originally submitted

 

      reports that were categorized as serious?  The

 

      reason I am asking is to get a sense of how many

 

      cases may not have been originally reported.  I

 

      know you had these serious cases sent to you for

 

      adjudication, just to check in case there were

 

      cases that were being missed in what the sponsors

 

      were reporting, but did you look as to how many

 

      cases were not considered serious by the sponsor,

 

      jut to give us a sense of how many may be sort of

 

      out there in the non-serious pool?

 

                DR. POSNER:  Again, we were blinded to

 

      sponsors' classifications throughout the entire

 

      process.  I don't know if somebody from the FDA can

 

      answer that question for you.

 

                DR. LAUGHREN:  Again just a ballpark

 

      figure, I think it is probably somewhere in the

 

      vicinity of maybe 65-70 percent.  But you have to

 

                                                               137

 

      understand that a designation of serious is a

 

      judgment that is made by the sponsor fairly

 

      subjectively.  I mean, there are criteria for

 

      regulatory serious.  It is fatal, life-threatening,

 

      seriously disabling, leading to inpatient

 

      hospitalization.  But even though, you know, that

 

      on face appears to be fairly definitive, sponsors

 

      in many cases, in my view, made the judgment that

 

      if it was considered to be suicide-related it was,

 

      by definition, serious.

 

                So, if you look at many of the narratives

 

      that were classified as serious, I think no

 

      reasonable person looking at those would consider

 

      that, in a common sense notion, as a serious event.

 

      But the point is that that designation--how that

 

      judgment was made varied from sponsor to sponsor.

 

      So, you know, some of them classified many more of

 

      the events as serious than other sponsors.  But the

 

      answer to the question is that overall roughly

 

      two-thirds of these events that were included in

 

      the analysis were designated as regulatory serious.

 

                DR. GOODMAN:  Ms. Griffith?

 

                                                               138

 

                MS. GRIFFITH:  I have a question about

 

      cutting specifically.  It seems to me that most of

 

      the examples of cutting fall into self-injurious

 

      behavior, intent unknown or self-injurious behavior

 

      with no intent.  I am just curious as to are you

 

      confident that the reporting that you received and

 

      reviewed actually got to whether or not there was

 

      intent or no intent, and how subjective is the

 

      reporting likely to be?

 

                DR. POSNER:  Again, as you can see,

 

      cutting is a method that is used both in suicidal

 

      behavior and self-injurious behavior without

 

      suicidal intent.  If you remember the conceptual

 

      scheme, there was the category self-injurious

 

      behavior, intent unknown, because cutting can be

 

      used both ways.  I forget the exact number but

 

      there were 20-something cases in which they cut but

 

      we don't know if it was suicidal or not.  That is

 

      why we had to come up with a category just to

 

      categorize and deal with that issue.  The FDA will

 

      point out that the included that in the sensitivity

 

      analysis so just in case all of those were

 

                                                               139

 

      suicide-related events, they have those numbers.

 

                DR. LAUGHREN:  If the question you are

 

      asking were the narratives lacking in detail, they

 

      absolutely were.  These were not by any sense

 

      complete descriptions.  Ideally, many more

 

      questions would have been asked when these events

 

      occurred to help flesh them out.  That is why it

 

      was necessary to use inference as one approach to

 

      try and get at intent because intent was not

 

      included for the vast majority of these.

 

                DR. POSNER:  Which is why only experts in

 

      the field could have been able to infer from the

 

      surrounding information.  The narratives were

 

      limited with respect to suicidal intent often but

 

      there was significant surrounding information for

 

      the expert raters to be able to infer from in many

 

      cases.

 

                DR. GOODMAN:  Thank you, Dr. Posner.  I

 

      would like to welcome Dr. Solomon Iyasu, from the

 

      FDA, who will be presenting what I think is a

 

      vetting of the sample to establish reliability and

 

      validity of the classification system.

 

                                                               140

 

                      OCTAP Appraisal of Columbia

 

                       Classification Methodology

 

                DR. IYASU:  Good morning.  I am going to

 

      be speaking about the appraisal that we did

 

      regarding the classification scheme of Columbia

 

      University.

 

                In my discussion today I will give you a

 

      brief background and then give you what the

 

      objectives of the FDA audit or appraisal were.

 

      Then I will describe briefly the methods that were

 

      used and also present the results of the audit and,

 

      finally, discuss the limitations and the strengths

 

      of the methodology and give some conclusions

 

      regarding our appraisal.

 

                I just want to make clear that the

 

      objective of the FDA appraisal of the Columbia

 

      methodology was really to assess how reproducible

 

      or reliable the methodology is.  The objective was

 

      not to assess the validity of the methodology or

 

      the scale as we cannot really test it against a

 

      gold standard which is not available right now.

 

      So, I just wanted to make sure that the audience

 

                                                               141

 

      understand that this is really to assess

 

      reliability.

 

                Just like Columbia, we reviewed all the

 

      sponsor-submitted event narratives.  They included

 

      all the original ones as well as the subsequently

 

      requested narratives.  The FDA team also reviewed a

 

      computerized line-listing of these event narratives

 

      and from the review we drew a sample from those

 

      that were appraised or rated by Columbia.

 

                In our methodology we grouped the event

 

      narratives that were submitted into four predefined

 

      strata, and then we selected event narratives from

 

      the various strata via a stratified simple random

 

      sampling scheme.  We over-sampled for difficult to

 

      classify and reclassified events.

 

                Stratum 1 is defined as events

 

      reclassified by Columbia to non-suicidal or other

 

      events.  Stratum 2 was defined as events newly

 

      identified or classified by Columbia as possibly

 

      suicide related or other categories.  Stratum 3 is

 

      events that were difficult to classify as defined

 

      as events with discordant initial independent

 

                                                               142

 

      ratings by the Columbia reviewers.  Then the last

 

      stratum was events that are the straightforward

 

      cases that were concordant among all reviewers in

 

      the Columbia rating.

 

                We had 64 sample records out of 423.  You

 

      notice that it is only 423 because some events were

 

      in active control and were not included in our

 

      review, unlike the Columbia group.  We included 2

 

      events in stratum 1.  We over-sampled and took

 

      one-third each from stratum 2 and 3, and then from

 

      the last stratum, which were the straightforward

 

      cases, we only sampled one-tenth.

 

                This slide just shows how collaborative

 

      this process was.  There was a planning group that

 

      included individuals from the Division of Pediatric

 

      Drug Development and the Division of

 

      Neuropharmacologic Drug Products, and then the

 

      Office of New Drugs.  Clinical reviewers who served

 

      as independent reviewers of the case narratives

 

      included two individuals, pediatricians, from the

 

      Office of Counter-Terrorism and Pediatric Drug

 

      Development, and then from the Division of

 

                                                               143

 

      Neuropharmacologic Drug Products one pharmacist and

 

      one other psychiatrist.  None of these clinical

 

      reviewers had previously been involved in the

 

      review of any of these narratives or the trials.

 

      We had a consensus process, similar to what

 

      Columbia did, that was facilitated by a

 

      psychiatrist who was also not previously involved

 

      in any of the reviews.

 

                Basically, we wanted to replicate the

 

      training that was given to the Columbia reviewers

 

      so we had Dr. Kelly Posner provide a similar

 

      two-hour teleconference training to all the review

 

      team regarding the suicidality scale.

 

                Each sampled event was randomly assigned

 

      to three of four reviewers for independent and

 

      blinded review.  Therefore, each reviewer had 48

 

      events to review, and we received a total of 192

 

      reviews from the four reviewers that we had.

 

      Reviewers were similarly blinded to treatment

 

      assignment, sponsor, diagnosis and also to the

 

      final Columbia ratings.

 

                The planning group also wrote a memo

 

                                                               144

 

      outlining the procedures of the review to all and

 

      provided this to the audit team members.  Reviewers

 

      were not allowed to discuss the events among

 

      themselves or with colleagues during the

 

      independent review period.  However, we did allow

 

      reviewers to call Dr. Kelly Posner to clarify the

 

      classification scale or to obtain clarification on

 

      the scale, but no discussion of specifics of any

 

      case was allowed during this process.

 

                We also required reviewers to record on

 

      the rating form if they consulted with Columbia

 

      during the review process.  For recording the

 

      ratings, we used a modified and pre-coded rating

 

      form which is shown here.  The only difference is

 

      that this is pre-recorded and includes all the 12

 

      event categories.  At the bottom of the form is

 

      where they would indicate if they did consult with

 

      Columbia.

 

                The reviewers and the rating scores were

 

      returned to me in sealed envelopes and these were

 

      key-entered into an Excel database.  Then we

 

      identified the discordant ratings and then these,

 

                                                               145

 

      similar to the Columbia group, were taken to a

 

      consensus meeting which was facilitated by a Board

 

      certified childhood and adolescence psychiatrist

 

      who was external to the Division of

 

      Neuropharmacologic Drugs, who was actually from the

 

      Division of Scientific Investigations.  This

 

      individual had not been previously involved in the

 

      review of these records, as I mentioned before.

 

                The final consensus ratings were again

 

      entered into an Excel database and compared to the

 

      final Columbia ratings.  Then, finally, discordant

 

      ratings between FDA and Columbia were discussed by

 

      teleconference basically to understand the reason

 

      for the differences.

 

                How did we assess the concordance of

 

      ratings among FDA reviewers, as well as between FDA

 

      and Columbia?  With definition of concordance for

 

      categories 1 through 3, 6 and 10 and we required

 

      that there be an exact match between the two

 

      reviewers.  Then, for categories 4, 5 or 11, which

 

      all describe essential self-injurious behavior with

 

      no suicidal intent, we considered them as

 

                                                               146

 

      equivalent rating.  We didn't need to differentiate

 

      between these three.  Lastly, categories 7, 8, 9 or

 

      12, essentially other categories, non-suicidal and

 

      non-self-injurious behavior, are considered

 

      equivalent rating.

 

                What were the results?  Among the FDA

 

      reviewers, of the 64 that were rated, 47 were

 

      concordant among the three reviewers.  We had 17

 

      that were discordant.  These were taken to the

 

      consensus meeting and, similar to Columbia, we also

 

      arrived at consensus ratings for all 17 events.

 

                Once we got the final ratings by the FDA

 

      reviewers for the 64 sampled events, then we

 

      compared them to the final Columbia ratings and 57

 

      out of the 64 were concordant, which gives us an

 

      agreement rate of about 89 percent, with a kappa of

 

      0.84.  We did look at the discordant ratings, which

 

      were number 7.  We assessed severity hierarchy to

 

      sort of analyze where the ratings differed.  In

 

      general, compared to Columbia, the FDA audit team

 

      classified six out of the seven events with a

 

      higher severity score than Columbia, and one event

 

                                                               147

 

      was a lower severity.  I must point out that three

 

      of the six that were rated higher were events that

 

      were classified as not enough information or other,

 

      so not really pertinent to the suicidality events.

 

                I will point out now the limitations.  In

 

      this audit neither the quality of the narratives

 

      nor the clinical source material for the narratives

 

      were evaluated.  Secondly, the validity of the

 

      Columbia classification method was not assessed as

 

      this was not the objective, and there is also no

 

      gold standard to compare it to.

 

                The strengths are that despite the

 

      differences in expertise and experience between the

 

      two groups of reviewers and the short time line

 

      that we had for training and review, and finally,

 

      more importantly, intentionally over-sampling is

 

      difficult to classify events for review, we

 

      achieved a very high level of concordance between

 

      the reviewers.

 

                Therefore, from this activity we concluded

 

      that the Columbia suicidality classification

 

      methodology is robust and reproducible when used by

 

                                                               148

 

      a non-expert group to classify a similar group of

 

      events.

 

                Finally, I would like to acknowledge the

 

      team of auditors who participated in this review

 

      from OCTAP, DNDP, DSI and OND, and also I would

 

      like to acknowledge the contribution of Kelly

 

      Posner in terms of the training and classification

 

      scales.  Thank you.

 

                DR. GOODMAN:  Thank you very much.  I

 

      would now like to take a short break.  I am sorry,

 

      I missed somebody who had a question.

 

                DR. PERRIN:  Thank you.  I just wonder

 

      whether you know whether the five or six

 

      discrepancies between the Columbia review and the

 

      FDA review might have been highly represented among

 

      the cases that were considered cutting in the last

 

      presentation, or were ones that were reclassified

 

      by Columbia as non-suicidal from the original

 

      industry reports.

 

                DR. IYASU:  Well, there were seven

 

      discordant ratings, as I mentioned before.  Three

 

      of them were classified by the FDA reviewers to a

 

                                                               149

 

      10, which is not enough information, from a

 

      category that was other.  So, if you look at the

 

      severity hierarchy it sort of went towards the more

 

      severe hierarchy because 10 represents not enough

 

      information; not sure whether there is deliberate

 

      self-harm or self-injurious behavior.  So, when you

 

      are not sure you put them in that category.

 

                In the other cases, I actually have a

 

      slide to show the cases that were discordant.  I

 

      talked about the cases where not enough information

 

      was classified from a 12 and 7.  But for those that

 

      were important, critical elements in terms of the

 

      suicidality event, there were four and the FDA

 

      group rated one as a suicide attempt from a

 

      Columbia group that was self-injurious behavior,

 

      intent unknown.  Then there was a second one,

 

      self-injurious behavior according to the reviewers,

 

      and a 10 which was not enough information from

 

      Columbia.  Finally, there was a suicide ideation

 

      versus psychiatric.

 

                But we don't consider this to be critical

 

      in terms of numbers because the objective was not

 

                                                               150

 

      really to test the validity of one classification

 

      as opposed to another one.  It was really to test

 

      how reproducible it was so we are not really making

 

      a statement as to which one really measures

 

      suicidality.

 

                DR. POSNER:  The final case that you

 

      didn't talk about, the negative severity bias, was

 

      one in which your raters called it self-injurious

 

      behavior, intent unknown and we called it a suicide

 

      attempt--

 

                DR. IYASU:  Exactly.

 

                DR. POSNER:  --which was the only suicide

 

      attempt and we rated it as more severe.  I think,

 

      you know, it is just worth noting all of them.

 

                DR. IYASU:  Yes, that is right.

 

                DR. GOODMAN:  Thank you.  I wish to remind

 

      the committee members not to discuss any elements

 

      of today's presentations among yourselves during

 

      the break.  We will reconvene promptly at eleven

 

      o'clock so that doesn't give you much time to get

 

      back here for a very important presentation by Dr.

 

      Hammad.

 

                                                               151

 

                [Brief recess]

 

                DR. GOODMAN:  Anuja Patel has some

 

      clarification points for tomorrow's agenda.

 

                MS. PATEL:  We have been receiving a lot

 

      of inquiries regarding the times for tomorrow's

 

      meeting and I just want to clarify that the Federal

 

      Register Notice does state that the meeting will

 

      begin promptly at eight o'clock in the morning, and

 

      it is scheduled to end at approximately 5:00 p.m.

 

      tomorrow.  If you look at the agenda, it is pretty

 

      much deliberations for tomorrow.  There is no

 

      saying whether we will end earlier or not.  So, if

 

      you are making flight arrangement plans, I do

 

      encourage you to go ahead and make your

 

      arrangements for after five o'clock just to be

 

      safe.  So, I just wanted to make that clarification

 

      for tomorrow's agenda.  Thank you.

 

                DR. GOODMAN:  I am hoping that, at the

 

      current rate, we will be able to break for lunch at

 

      12:15.  So, that is my intermediate goal this

 

      morning.

 

                I would like to introduce our next

 

                                                               152

 

      speaker, Dr. Hammad, from the FDA, and this is one

 

      of the key presentations before the committee this

 

      morning, involving a reanalysis of the clinical

 

      trials data following the reclassification of

 

      suicidality.

 

          Results of the Analysis of Suicidality in Pediatric

 

                    Trials of Newer Antidepressants

 

                DR. HAMMAD:  Good morning, everyone.  I am

 

      here today to share with you the results of our

 

      analysis of suicidality in pediatric trials of

 

      antidepressants.  These are the elements that I

 

      will cover in my presentation.  After a brief

 

      statement of our objective, I will describe the

 

      data that we requested and then I will give you the

 

      highlights of the findings before I go over some of

 

      the limitations of the current investigation.  Then

 

      I will give you an overall summary of the findings.

 

                Our objective was to investigate the

 

      relationship between antidepressants and pediatric

 

      suicidality based on the adverse events reported,

 

      as well as the suicidality item scores in pertinent

 

      depression questionnaires.  So, it is important to

 

                                                               153

 

      keep in mind that we will be dealing with two

 

      different sets of outcomes, and I will draw your

 

      attention to that again at the transition.

 

                First, our data came from 25 clinical

 

      trials in nine drug development programs, in

 

      addition to the TADS trial.  Here is a list of the

 

      drugs and number of trials involving each drug.  At

 

      first glance you will notice that there are

 

      differences between the available trials for each

 

      drug, which have an implication actually for our

 

      ability to observe the event of interest.

 

                Here are the indications that these trials

 

      were conducted in.  As you can see, the majority of

 

      trials were done in depression patients.  Two

 

      trials were excluded, one because it was a relapse

 

      prevention trial and the other was simply

 

      uncontrolled.  So, we ended with 23 available

 

      trials in addition to the TADS trial.  All trials

 

      were comparable in design.  They were all parallel,

 

      controlled trials.

 

                Although trials started in the '80s, I

 

      think one trial or two, the majority were conducted

 

                                                               154

 

      in the late '90s and TADS was, of course, in '04.

 

      The duration of treatment ranged from 4-16 weeks.

 

                In the next section I will focus on the

 

      findings first for outcomes based on the adverse

 

      events, the ones that you see here.  I will go over

 

      them in detail.  Then, the ones that were based on

 

      the suicidality scores.

 

                That is the first set of outcomes.  These

 

      are four outcomes that we examined; these are the

 

      main outcomes we examined.  The first outcome we

 

      called suicidal behavior and it included cause 1

 

      and 2 from the Columbia classification.  You can

 

      see here the details of what 1 means and what 2

 

      means.  As you notice, this will stay up all the

 

      time so you will be able to have a chance to go

 

      back and see what everything means.

 

                The second outcome was suicidal ideation.

 

      It includes code 6.  You have 33 events here and 45

 

      events here.  Putting them together, we came up

 

      with outcome 3, which was the primary focus of the

 

      analysis.  This is simply the combination between

 

      number 1 and number 2.  It had codes 1, 2 and 6. 

 

                                                               155

 

      So, it ended up with 78 events.

 

                The so-called outcome 4, to construct that

 

      we added two more types of events, code 3 and code

 

      10.  Just to remind you, code 3 meant suicidal

 

      injury with intent unknown, and code 10 meant there

 

      was some injury but there was no information to

 

      help determine what the intent was.  So, this is

 

      sort of considered the worst-case scenario and it

 

      was used in the sensitivity analysis for the

 

      primary outcome.  The reason we chose this as a

 

      primary outcome--it was chosen a priori--is because

 

      it is the most pertinent and the one least likely

 

      to be subject to dilution because of

 

      misclassification.

 

                I will take you step by step over the

 

      events from the time that we sent them to the

 

      Columbia group.  We sent them 427 adverse events.

 

      We ended with 260 that were coded as "other" that

 

      are not really pertinent to the analysis.  Don't be

 

      surprised by the magnitude of the number.  The

 

      reason is because we cast a very wide web to start

 

      with to be able to capture every possible event. 

 

                                                               156

 

      So, we ended with 167 potential events with those

 

      particular codes.

 

                Those events boil down to 141 unique

 

      patients because many patients had more than one

 

      event.  Among those, we chose the most severe

 

      events.  For example, if a patient had an event

 

      that was coded as 6 and an event that was coded as

 

      4, then this particular patient would be labeled

 

      with the most severe event.

 

                Among those, we ended up with 21 that were

 

      not eligible.  The eligibility here is determined

 

      by when the event occurred.  If it occurred within

 

      the double-blind period, then we considered it

 

      eligible.  If it was outside, then it was not

 

      eligible.  So, we ended with 120 eligible.  Among

 

      the eligible, we had 109 that were pertinent, that

 

      were suicidal related.  You notice what is missing

 

      from here are codes 4, 5 and 11 which are

 

      self-injury but the intent is known not to be

 

      suicidal.  So, they were not pertinent to the

 

      analysis.  We ended up with 109.  You notice a few

 

      discrepancies between some of the numbers because

 

                                                               157

 

      it depends on if we are looking in the window or

 

      outside the window.  So, don't worry about the few

 

      discrepancies here and there.

 

                I showed you on the previous slide how we

 

      ended up with 109 events.  These 109 events were

 

      not exactly the same events that the sponsor

 

      reported initially.  So, in this light, I will walk

 

      you through the disposition of the sponsor original

 

      events.  We started with 115 possibly

 

      suicide-related events as reported by the sponsor.

 

      Now, we took out 11 because they were not

 

      pertinent.  Just to remind you, being pertinent or

 

      not had to do with how it was coded by the Columbia

 

      group.  So, they were coded as non-suicidal.  The

 

      15 were taken out of consideration because they

 

      were not eligible.  Some of them were suicidal but

 

      they were not within the double-blind period.  So,

 

      we ended with 87 pertinent events.  To those we

 

      added 29 new events from broader search and

 

      classification.  However, only 22 were pertinent.

 

      Others were not pertinent to the analysis.  So, we

 

      ended up with 109 events.

 

                                                               158

 

                Before I go on with the results, this is a

 

      list of caveats that I would like to draw your

 

      attention to because they have important

 

      implications on the interpretation of these

 

      findings.  There is always the possibility of a

 

      chance finding because we are dealing with post hoc

 

      analyses with multiple outcomes, complicated by

 

      having many sub-analyses.  So, keep in mind that

 

      there is always the possibility for a chance

 

      finding.

 

                It is also difficult to compare across

 

      drugs, unfortunately, because of the low power of

 

      individual trials and the differences in the

 

      databases among the trials, which is the point I

 

      mentioned earlier for each drug.  So, it will

 

      affect our chance of observing the event of

 

      interest.  In addition to this, there is the

 

      potential role for differences in the level of

 

      ascertainment of events and completeness of

 

      narratives between trials or between development

 

      programs.  Mind you, the sponsor actually is the

 

      one that puts together the narratives based on the

 

                                                               159

 

      case report form so you would expect to find some

 

      variability here also.

 

                Having said that, I will go on with the

 

      rest of the analysis.  The investigation followed a

 

      standard approach for examining the effect

 

      modification and confounding in the variables that

 

      we asked for.  First, the effect modification--this

 

      was slightly harder to do but by modification I

 

      mean that the effect of the drug is actually

 

      modified by another variable.  For example, if the

 

      drug was more risky among the males versus females,

 

      then the gender variable modified the effect of the

 

      drug and this would have important implications if

 

      it was true.

 

                Before I go on, it was difficult to figure

 

      out if there was interaction or not, so my approach

 

      was to look if there was any inconsistent finding

 

      across the trial when I stratified by the variables

 

      of interest.  As you can imagine, we have very

 

      small numbers of events.  But that is in this

 

      particular outcome.  Other outcomes had more

 

      events.

 

                                                               160

 

                The variables that I focused on were the

 

      age group, gender and history of suicidal attempt

 

      at baseline.  But none was found to meaningfully

 

      impact the risk estimates so there was no effect

 

      modification to report so I am not reporting any.

 

                In examining the confounding we were

 

      concerned about the possibility of perhaps some

 

      randomization failure at baseline.  So, there might

 

      be some randomization failure that might be

 

      responsible for the observation we have because we

 

      have very few events.  So, if this was true, then

 

      adjusting for these imbalances would have made a

 

      difference in the risk estimate.

 

                We examined several variables, at least 17

 

      variables, but the exact number of variables

 

      differed between trials because some trials had

 

      missing information about some variables so it was

 

      not exactly the same number of variables for all

 

      trials.  Again, none was found to meaningfully

 

      impact the risk estimates and I am not going to

 

      present any. I think the purpose of these two

 

      slides is to show you the process that we went

 

                                                               161

 

      through.

 

                In the next section I will go over

 

      suicidal behavior or ideation which, again, are

 

      codes 1, 2 and 6, by drug.  I will do it drug by

 

      drug.  Then, at the end of that section I will give

 

      you a summary of all the drugs in one table so you

 

      can have a snapshot of the whole picture.

 

                I will start with Celexa.  I ordered them

 

      alphabetically.  This graph has a lot of

 

      information  so I would like to take a minute to

 

      orient you with the graph.  First, this section

 

      will have the name of the outcome that we are

 

      trying to evaluate.  In this case it is suicidal

 

      behavior or ideation.  In the upper corner, here,

 

      we have the name of the drug and the indication of

 

      the trials.  Here it will give you the modeling

 

      approach.  The value of this section is to know the

 

      study number.  It is sort of redundant, you again

 

      have the indication and the drug name.  This

 

      section will draw your attention to the actual

 

      relative risks, risk ratios, with the confidence

 

      intervals.  This section gives you the percent

 

                                                               162

 

      weights which reflects the relative contribution of

 

      each trial of these two, for example, for the

 

      overall estimate of risk.  So, this trial had more

 

      weight in getting the overall estimate.  This

 

      actually is a standard approach for meta-analysis,

 

      and it takes into consideration both the sample

 

      size and the number of events.

 

                Just as an example for how to read the

 

      graph for this trial, that is the number of the

 

      trial, 94404.  The size of the box, if you notice,

 

      is slightly larger than this one because this

 

      reflects the percent weight.  So, all you need to

 

      do is just look at the graph and get a lot of

 

      information.

 

                Notice that the relative risk is more than

 

      1.  For those who are not familiar with relative

 

      risk, it is simply the ratio of the risk in a drug

 

      over the risk in the placebo group.  As you can

 

      imagine, if it is 1 then the risk is equal.  So, if

 

      any relative risk is 1 it would fall on this red

 

      line.  It will not be red in other graphs but I

 

      made it here to emphasize it.  Now, if you see the

 

                                                               163

 

      trial estimate on your right-hand side, this means

 

      the drug is worse.  If you see it on the left-hand

 

      side, that means the placebo is worse.  So, in this

 

      case, this is saying that the drug is slightly

 

      worse in one trial and not exactly the same in

 

      other trials.  So you can see immediately the

 

      divergent results.

 

                Now, one last thing to keep in mind is

 

      that this is just an estimate and that is why we

 

      provide the confidence interval.  It sort of

 

      reflects the amount of information we have and

 

      simply means that if we are to repeat this trial or

 

      the sampling process 100 times, 95 percent of the

 

      time the true effect of the drug will be somewhere

 

      between these two extremes.  So, it is important to

 

      put keep in mind that this is just an estimate.

 

                I will move on with Paxil.  It will be

 

      much quicker.  With Paxil, notice that all the

 

      trials are on your right-hand side, which means

 

      that all of them have a relative risk of more than

 

      1.  Overall it is 2.65, but the confidence interval

 

      is just at 1, the lower limit.  Notice here that

 

                                                               164

 

      this graph contains all indications.  Later on in

 

      the summary I will separate the depression-based

 

      trials and non-depression trials.

 

                For Prozac this graph shows you the

 

      results I have in my briefing document.  As you can

 

      see, there is not much going on in all the trials,

 

      and the overall estimate is almost 1.

 

                But after I finished my report we received

 

      information from the TADS trial and, as you can

 

      notice here, I am only using two arms of the four

 

      arms that you heard abut this morning, only the

 

      Prozac and the placebo because these were the two

 

      arms that were really blinded.  Again, the events

 

      were sent to the Columbia expert group and we ended

 

      up with 9 events total in the Prozac group and 2

 

      events in the placebo group.  So, I ran the

 

      analysis again and I added the TADS trial.  Note

 

      that based on these numbers the TADS trial is the

 

      only trial that you have in all the 24 trials that

 

      has a confidence interval that does not include 1.

 

      It has a considerably different picture than the

 

      sponsor-conducted trials.  As you can imagine, the

 

                                                               165

 

      overall the risk will increase.

 

                Zoloft had three trials, one in OCD and

 

      two in depression.  As you can imagine, when we

 

      take the OCD from the consideration, the overall

 

      estimate will actually be different; it will be

 

      higher.

 

                For Effexor we had four trials, two in

 

      anxiety and two in depression.  The two in anxiety

 

      did not have anything going on, but the two in

 

      depression really had the highest estimate in all

 

      the trials, and overall actually represents the

 

      only overall for a drug that does not include 1.

 

                This is kind of a busy slide but it gives

 

      you a snapshot of the whole picture so I would

 

      rather have it on one slide instead of giving it to

 

      you on two slides.  I will try to orient you with

 

      this slide.  This gives you the overall relative

 

      risks of suicidal behavior or ideation by drug.

 

      This column has the brand name alphabetically.  The

 

      first group is SSRI.  The first column here shows

 

      you the results in the depression trials and the

 

      last column shows you the results in all

 

                                                               166

 

      indications in all trials, regardless of

 

      indication.

 

                For example, let's take Celexa.  You will

 

      notice that the numbers here and there are the

 

      same.  That is because Celexa only had two

 

      depression trials.  It did not have any

 

      non-depression trials.  Luvox did not have

 

      depression trials but it had one OCD trial.  So,

 

      this really gives you a snapshot of all the

 

      findings in all the drugs whether by being a

 

      depression trials or overall.

 

                Notice that Paxil did not change much.

 

      Prozac did not change much whether you look at

 

      depression alone or depression and other

 

      indications.  Zoloft, as I told you, if you take

 

      out the OCD trial the overall estimate slightly

 

      increases.  Then, Effexor, if you take the MDD

 

      trial it is considerably increased actually whether

 

      you actually just focus on the depression or

 

      overall.  Both estimates do not include 1 in their

 

      confidence interval.  Remeron, again is the same

 

      because it had one trial with depression.  We did

 

                                                               167

 

      not have any events in with Serzone, so nothing is

 

      reported here.  Wellbutrin did  not have a

 

      depression trial and it did not have an event in

 

      the only trial it had, which is ADHD.

 

                The overall observation here is that all

 

      relative risks were more than 1 but, of course, as

 

      I mentioned earlier, there is always the

 

      possibility for a chance finding because, as you

 

      can see, the majority of numbers really overlap and

 

      they include 1 in their confidence intervals,

 

      except for Effexor.

 

                One thing that you observed in the slide I

 

      showed for drug by drug is that we observed

 

      differences between trials even within the same

 

      drug within the same development program.  So, we

 

      tried to examine some of the trial design

 

      attributes to try to understand where these

 

      differences come from.  But none was found to

 

      consistently explain the observed differences in

 

      the risk estimates between trials whether within or

 

      between development programs.  For example, you

 

      might find a trial that excluded placebo

 

                                                               168

 

      respondents and had a signal, and also find a trial

 

      that actually included those and also had a signal.

 

      So, there was really no consistent pattern.  So,

 

      there is a chance that what we are observing is due

 

      to some attributes that we have not captured, like

 

      how rigorously the trial was actually implemented

 

      and how closely the investigators were actually

 

      following the instructions of inclusion and

 

      exclusion criteria, and so on.

 

                Now, every time you lump things we might

 

      lose some valuable information.  So, after I did

 

      the overall analysis for suicidal behavior or

 

      ideation I did an analysis for the components of

 

      all outcomes which you can see on this other slide

 

      as outcome 1 and outcome 2.

 

                This is again a slide which gives you an

 

      idea of what is going on in all the drugs that have

 

      events.  First, again this just shows you the drug

 

      name.  Here is the relative risk of the suicidal

 

      behavior alone; then suicidal ideation alone; and

 

      then I repeated again the combination for ease of

 

      comparison.  If you notice, for example, with

 

                                                               169

 

      Celexa the behavior was slightly more frequent in

 

      the drug but the ideation was slightly more

 

      frequent in the placebo group.  But if you look at

 

      the combination you find that there is a slightly

 

      diminished signal if you compare it to the first

 

      outcome, which is the suicidal behavior.  It is

 

      slightly more when you look at ideation.  So, it

 

      really depends on what outcome you really can trust

 

      more.  Perhaps you can say that behavior is more

 

      readily captured and that ideation is something

 

      that might be missed.  However, the first three

 

      drugs are showing this pattern.  When you go to

 

      Zoloft, for example, it reverses itself and you

 

      have more ideation in the drug group than the

 

      behavior.  Anyway, of course, all this can just be

 

      due to chance findings because everything is

 

      actually overlapping but I thought you might be

 

      interested in knowing what exactly is going on

 

      behind the scenes of a combined outcome.

 

                The sensitivity analysis, as I mentioned,

 

      we actually added three events coded 3 and 10 to

 

      the pool of codes already in suicidal behavior or

 

                                                               170

 

      ideation, 1, 2 and 6 as the sort of worst-case

 

      scenario.  I have here the results, again, all

 

      trials, all indications and just SSRIs in

 

      depression trials.  As you can see, there is not

 

      much difference between 1.95 and 2.19.  All the

 

      confidence intervals did not include 1, which means

 

      they were all significant.  Again, perhaps there is

 

      some difference here but it still did not

 

      meaningfully change our perception that there is

 

      risk going on.

 

                This is a different way to look at the

 

      risk estimates.  We actually also did an analysis

 

      by the risk difference that is different from the

 

      way we just presented.  The analysis of risk

 

      difference estimates the absolute increase in the

 

      risk of the event of interest due to treatment.  It

 

      is simply the risk in that group minus the risk in

 

      the placebo group.  The overall risk difference for

 

      SSRIs in the patient trials ranged from 2-3

 

      percent, actually 2 percent for outcome 3 and 3

 

      percent for outcome 4.  So, that is the range that

 

      we have here.

 

                                                               171

 

                This can be interpreted as out of 100

 

      patients treated we might expect 2-3 patients to

 

      have some increase in suicidality due to short-term

 

      treatment because what we have is just a short-term

 

      treatment, and that is beyond the risk that occurs

 

      with the disease being treated.

 

                Now, this is a different section now.  We

 

      are moving to the outcomes based on the suicidality

 

      scores, which is totally different from the one

 

      that I just presented so far.  There were two

 

      outcomes.  One is worsening of the suicidality

 

      score and it was simply defined as an increase in

 

      the item score of pertinent depression

 

      questionnaires relative to baseline, regardless of

 

      subsequent change.  Emergence was defined the same,

 

      except that the patient had a normal baseline

 

      score.

 

                As you know, these questionnaires are

 

      actually collected regularly as part of the

 

      efficacy judgment.  We are only capturing here sort

 

      of the subscore that is pertinent to suicidality.

 

                For worsening, again, the same approach

 

                                                               172

 

      was used as for effect modification and

 

      confounding, and here we had a considerably larger

 

      number of events, but again none was found to

 

      meaningfully impact the risk estimate.

 

                This graph shows you all the trials that

 

      we have, and simply shows that there is not much

 

      going on overall.  It is almost 1, the relative

 

      risk.  There are only 3 trials that have some

 

      suggestion that there might be some signal going on

 

      there.  Interestingly, these trials also show the

 

      signal with the other set of outcomes.

 

                Now, the emergence--just to remind you,

 

      they are identical, except this one which required

 

      the patient to be normal at baseline.  Again,

 

      effect modification and confounding were examined

 

      but none was found to meaningfully impact the

 

      estimates.

 

                Here the same picture holds.  In the

 

      majority of trials there is nothing going on,

 

      except for a few trials that have a suggestion of a

 

      signal and, again, those trials show the signal in

 

      the other set of outcomes and here the overall was

 

                                                               173

 

      really not consequential.

 

                I did many other analyses, as you can see

 

      in my briefing document.  But in the interest of

 

      time I am not including them in my presentation.  I

 

      tried to focus on the highlights of the findings,

 

      and none of what I did present changed the

 

      conclusion about the risk.  But I will quickly go

 

      over the other list of things that were done and I

 

      can answer any questions about those.

 

                I also did another sensitivity analysis

 

      examining the effect or the modeling approach. I

 

      also did an analysis of the co-called completers

 

      analysis in which I stratified by discontinuation

 

      and I looked at the signal within those that

 

      discontinued and compared that to those that

 

      completed the study.

 

                Also, I did the time-to-event, both

 

      survival curves, and I estimated the hazard

 

      functions for all the SSRIs put together.  I am

 

      sure a question will come up about the timing of

 

      the events.  The finding of Dr. Jick's group did

 

      not hold.  There was no initial increase in the

 

                                                               174

 

      risk and chances that their finding was confounded

 

      by indication.

 

                I also did some preliminary look at the

 

      so-called activation syndrome.  The issue was

 

      raised at the last AC.  Then I did some post hoc

 

      power analyses to just show why none of the trials

 

      really had power to detect a signal on its own or

 

      even within the same drug.  So, I can share with

 

      you any of these if you have any questions.

 

                Anyway, before I conclude, I have a very

 

      few slides left.  The limitations, again just to

 

      recap what I said before, what we are dealing with

 

      here is post hoc analyses with multiple outcomes

 

      that in addition involved many subanalyses,

 

      therefore, caution is warranted in the

 

      interpretation of the findings.

 

                As you saw, there were observed

 

      differences between drugs but the differences in

 

      themselves are no a limitation but our ability to

 

      tease out where these differences come from is the

 

      limitation.  They can be due to chance findings

 

      because most of the confidence intervals actually

 

                                                               175

 

      overlap.  They can be due to true differences so,

 

      in effect, there is no class effect.  Also, they

 

      can simply be because we don't have much

 

      opportunity to observe the outcome.  Because the

 

      database sizes are different, they can simply

 

      reflect differences in the level of ascertainment

 

      of events and completeness of narratives.  As I

 

      mentioned earlier, the sponsors put together the

 

      narratives so there might be some differences

 

      there.  Also, there might be some differences in

 

      the trial design attributes that we were not able

 

      to capture or quantify.

 

                Now, just a quick reminder that we are

 

      dealing here with short-term exposure and we don't

 

      have any information on the risk beyond 16 weeks.

 

      It might increase; it might decrease.  It is very

 

      difficult to extrapolate.

 

                Medication non-compliance might have

 

      influenced the occurrence of the events of

 

      interest.  However, the determination of

 

      non-compliance was suboptimal in the way it was

 

      defined and the way it was assessed actually.  Some

 

                                                               176

 

      companies did it post hoc; some had pre-planned it

 

      in the protocol.  It was very difficult to really

 

      get hold of ascertainment of the non-compliance.

 

                Again, after everything is said and done,

 

      it is important to know that the observed rate of

 

      suicidality associated with the use of

 

      antidepressants might not reflect the actual rates

 

      among patients in the general population.  Because

 

      we are dealing with volunteers we have the

 

      volunteer bias.  We have the whole logistics of

 

      conducting the trial, the very close care for

 

      example that patients take and the detection bias

 

      that can result from that.  So, it is important to

 

      appreciate this issue.

 

                Most trials were conducted with a flexible

 

      dosing scheme, eliminating our ability to examine

 

      the dose effect.  So, none was examined.

 

                Now to give you an overall summary of the

 

      findings, the broader search for adverse events in

 

      various drug development programs and the blinded

 

      classification process identified many new events

 

      and also eliminated several events that were not

 

                                                               177

 

      appropriately classified.  It is important to note

 

      that there were no completed suicides.

 

                The next point is that many individual

 

      trials had a relative risk of two or more for

 

      suicidality and some confidence intervals of

 

      overall estimates did not include 1.  I think the

 

      key here is not really the statistical

 

      significance, because of the caveats I mentioned,

 

      as much as the consistency.  You can see most of

 

      the trials falling on your right-hand side of the

 

      graph, which means that there is some suggestion of

 

      signal coming from many trials even though none of

 

      them was really significant perhaps.

 

                The next point is that the sensitivity

 

      analyses did not yield a meaningful difference in

 

      the evaluation of the estimated risk.  This gives

 

      more confidence in the finding that we might really

 

      be dealing with some real finding.

 

                None of the examined covariates was found

 

      to be an effect modifier or to meaningfully impact

 

      the risk estimates as a confounder.  But, mind you,

 

      this might be simply a function of power because

 

                                                               178

 

      there might be some slight imbalance but the sample

 

      size is not large enough to really detect it or

 

      detect its effect.

 

                Among the examined trial design

 

      attributes, none was found to consistently explain

 

      the observed differences in the risk estimates

 

      between trials.  But I believe they can partially

 

      perhaps explain some of the differences, as I am

 

      sure you saw in my briefing document.

 

                My last point is that no signal was

 

      observed in the outcomes based on the suicidality

 

      scores, unlike what we saw with the adverse events.

 

                I have like 70 backup slides so if you

 

      have any questions, feel free.

 

                DR. GOODMAN:  Thank you, Dr. Hammad.  I am

 

      sure you will be here tomorrow so I would ask the

 

      committee members to limit your questions to

 

      clarification because we will have an opportunity

 

      to ask additional questions tomorrow as we

 

      deliberate over the questions that are posed to us.

 

      With that in mind, Dr. Marangell?

 

                DR. MARANGELL:  It doesn't appear that you

 

                                                               179

 

      included family history of bipolar disorders.

 

                DR. HAMMAD:  No.

 

                DR. MARANGELL:  How come?

 

                DR. HAMMAD:  This was an attribute of the

 

      trial.  It is not patient-level data so what I have

 

      is that this trial did this or didn't do that and

 

      none of the actual attributes explain any of those

 

      differences anyway.  So, the non-inclusion was

 

      because they were not patient-level data; they were

 

      trial-level data, and it really did not make much

 

      difference.  You can see that some excluded and had

 

      a signal and some did not exclude and still had

 

      signal.

 

                DR. GOODMAN:  Dr. Leslie?

 

                DR. LESLIE:  I just wanted to make sure of

 

      the SSRI alone analyses and the activation syndrome

 

      analyses, if we can do that tomorrow.  Since one of

 

      our questions is to think about these drugs as a

 

      whole versus certain classes versus specific

 

      medications, I just want to make sure we can do

 

      that.

 

                DR. GOODMAN:  Dr. Perrin?

 

                                                               180

 

                DR. PERRIN:  As I understand it, the

 

      nefazodone sample, which is about 450 kids in the

 

      MDD trials, has zero events noted.  Can you help us

 

      understand why that might be true, and what might

 

      be different about those trials and those sample

 

      selections compared to the other trials?

 

                DR. HAMMAD:  I have not reviewed the

 

      actual protocols of the trials.  That is something

 

      that Dr. Rabitsky did so perhaps he can comment on

 

      that tomorrow.

 

                DR. GOODMAN:  Dr. Gibbons, do you have a

 

      question?

 

                DR. GIBBONS:  First, I think you have done

 

      a great job.  Apparently getting four degrees in

 

      your lifetime was a good benefit!  I have a couple

 

      of general questions and lots of specific questions

 

      which I will hold for tomorrow.  But the most

 

      general question is this, most of your analyses

 

      focused on the relative risks, which really in some

 

      ways goes away from the idea of using the

 

      patient-level data and using patient-level

 

      characteristics or covariates.

 

                                                               181

 

                Now, I think you have done a very nice job

 

      of conditioning on things using stratification, but

 

      the analyses, even though in some sense are similar

 

      for the time-to-event, the survival kinds of

 

      analyses which do make use of the individual

 

      patient-level data--it seems to me those would be

 

      much stronger because they adjust for time at risk.

 

      The relative risks ignore the differential time--a

 

      study was conducted for the differential time that

 

      an individual within a study participated, whereas

 

      that is exactly the time-to-event analysis.  So, I

 

      would just like your general comments on that.

 

                DR. HAMMAD:  The first thing was to

 

      actually make sure if there was any imbalance in

 

      the exposure time between trials, and I did not

 

      find much difference in the actual time for every

 

      trial between placebo and intervention.  In spite

 

      of that, I realized that the time-to-event can

 

      answer other questions, other than taking into

 

      account imbalance between both.  That is why I did

 

      it both ways actually.  They are giving more or

 

      less similar conclusions.  I didn't see that there

 

                                                               182

 

      was that much difference in conclusions whether we

 

      looked at it as relative risk or as time-to-event

 

      analysis.

 

                DR. GIBBONS:  Just one follow-up question

 

      to that, one of the things you see throughout your

 

      analysis is that if you condition on prior history

 

      of suicide attempts or ideation, what you find is

 

      that the effects tend to go away.  So, the

 

      development of new suicidal effects or worsening of

 

      suicidal effects shows absolutely nothing.  When

 

      you conditioned on prior history the risk ratio

 

      went down to 1.2 essentially for those people who

 

      didn't have a prior history.  What is your sense of

 

      this kind of what you bring to the table and then

 

      the effect of the drug?

 

                DR. HAMMAD:  I think this actually draws

 

      our attention to the fact that when you are dealing

 

      with a patient that is at higher risk to start with

 

      you might expect the drug to be--I don't want to be

 

      more risky because quantitatively the difference is

 

      not significant, the difference you are referring

 

      to.  There is some trend towards that but if you

 

                                                               183

 

      actually look at within trial you find that it goes

 

      both ways.  Sometimes it is more in those patients;

 

      sometimes it goes the other way.  So, I don't think

 

      actually there was much meaningful--that is why I

 

      used, if you noticed, the word "meaningful"

 

      difference.  I don't think this particular

 

      covariate, which I believe is the single most

 

      important risk factor, plays much of a role in

 

      modifying the risk estimates.

 

                DR. GIBBONS:  Thank you.

 

                DR. GOODMAN:  Dr. O'Fallon?

 

                DR. O'FALLON:  I am interested in the

 

      missing data essentially.  That is the thing that

 

      is bothering me all through this retrospective

 

      analysis.  There are two issues that I am concerned

 

      about.  One of them is how many of the patients

 

      had, in essence, missing follow-up?  I mean, they

 

      disappeared from the study and, therefore, they

 

      could have had an event that was never observed or

 

      recorded.  What percentage of missing data

 

      disappeared?  I know you talked about last

 

      follow-up carried forward and that sort of thing in

 

                                                               184

 

      your analyses.

 

                DR. HAMMAD:  Not in my analyses.

 

      Actually, I don't have information in my database

 

      about the lost to follow-up.  However, we did

 

      something that is sort of similar that sort of

 

      talks to the same idea.  When I stratified by

 

      discontinuation, those that end up as discontinuing

 

      without us really capturing them, you would expect

 

      that among those who discontinued, because we know

 

      they discontinued--among those the signal would be

 

      greatly diminished.  They would look as if nothing

 

      is going on--

 

                DR. O'FALLON:  Yes.

 

                DR. HAMMAD:  --but when I stratified by

 

      that, as a matter of fact there was a tendency for

 

      the majority of trials to observe a signal among

 

      those that discontinued, which simply sort of means

 

      that those that have events usually discontinue but

 

      it sort of allayed anxiety about the fact that we

 

      might be losing or missing information.

 

                DR. O'FALLON:  Yes, but I am still worried

 

      about the fact that there are some that could have

 

                                                               185

 

      dropped out and then had an event and it was never

 

      recorded.  So, you may be missing events.

 

                DR. HAMMAD:  Sure.

 

                DR. O'FALLON:  The other part of it was

 

      that I am concerned about the timing of events with

 

      respect to dose changes.  I realize, again, with

 

      the retrospective analysis you may not have the

 

      information in your database, but that is one of

 

      the issues here, whether the events are occurring

 

      in connection with a dose change of any sort, and

 

      can you get at that or not with your data set.

 

                DR. HAMMAD:  No, we can't.  The issue of

 

      the non-compliance, as I mentioned, is to some

 

      extent similar to dose change.  I mean, it doesn't

 

      matter who changed it, the physician or the patient

 

      decided not to take it.  I don't think we can

 

      capture that, unfortunately.

 

                DR. GOODMAN:  Dr. Robinson?

 

                DR. ROBINSON:  I understand that on the

 

      Paxil trial 329 there was an active control.  I

 

      think it was imipramine.  Could you tell us was

 

      there a difference between imipramine and Paxil in

 

                                                               186

 

      terms of--

 

                DR. HAMMAD:  No, I have not compared it to

 

      Paxil actually.

 

                DR. GOODMAN:  Could you repeat the

 

      question, please?

 

                DR. ROBINSON:  The Paxil trial 329 had

 

      another active antidepressant as a control and I

 

      believe that was imipramine, and I was asking if

 

      there had been any comparison of the effects of

 

      Paxil and the imipramine cell.

 

                DR HAMMAD:  I did not do a formal

 

      comparison but if you look in my review, on page

 

      101, you will see that there were two events in the

 

      active control and four events in the SSRI and one

 

      event in the placebo in this particular trial, with

 

      the sample size almost identical.  So, it gives you

 

      an idea that it was about half of the ones observed

 

      on Paxil but double the ones observed on placebo.

 

                DR. GOODMAN:  Dr. Santana?

 

                DR. SANTANA:  Based on your expertise in

 

      this area, and I confess that I am not a behavioral

 

      scientist, can you give me some general sense, if

 

                                                               187

 

      you look at these outcomes in adults are the

 

      relative risks for these outcomes the same when

 

      these drugs are used, or is this a universe that is

 

      particular to pediatrics, based on the data that

 

      you know of?

 

                DR. HAMMAD:  No, I am not aware of any

 

      data that actually looked at this particular

 

      question among adults.

 

                DR. GOODMAN:  You said that you have not

 

      examined those data in adults?

 

                DR. HAMMAD:  No, I don't have that.

 

                DR. GOODMAN:  Is there somebody from the

 

      FDA who can respond to that question?  Tom?

 

                DR. LAUGHREN:  Yes, the adult data have

 

      not been looked at with the same level of scrutiny.

 

      But there are a couple of things I can tell you.

 

      First of all, this issue first came to our

 

      attention with Prozac back in the early '90s, and

 

      based on reports, from spontaneous reports of

 

      suicidality events in association with Prozac, the

 

      company went back and looked at all their

 

      controlled trials for Prozac, looking at them in

 

                                                               188

 

      two different ways.

 

                One thing they looked at are the item

 

      scores, roughly the same thing that we did here,

 

      and they did not find any signal for excess risk on

 

      the item scores, as we did not here.  They also

 

      looked at event data and they did not find any

 

      signal with event data either.

 

                Now, they didn't go back and try to

 

      reclassify the events in the same way that was done

 

      here.  But subsequent to the Prozac experience, all

 

      subsequent NDAs for all antidepressants were looked

 

      at in the same way.  The companies did an item

 

      analysis and they looked at their own event data,

 

      using their own approaches to classification.  With

 

      all these subsequent NDAs, we have never seen a

 

      signal for excess suicidality, either looking at

 

      event data or looking at item data.

 

                In addition to that, we now have a much

 

      larger database for completed suicides in adult

 

      data that we are currently looking at.  Based on

 

      the analysis that we have done to date, we have not

 

      seen a signal for excess completed suicides in a

 

                                                               189

 

      very large adult database.  I mean, this comprises

 

      I think 240 trials, over 40,000 patients.  But,

 

      again, none of these data in terms of event data,

 

      short of completed suicide, have been looked at

 

      with the same level of scrutiny for adults.

 

                DR. GOODMAN:  Tom, let me follow-up to

 

      that question.  When you say that there has never

 

      been a suicide signal, I take that to mean a

 

      greater rate in the drug versus placebo group.

 

      What is the denominator there?  How many studies

 

      are we talking about in adults?

 

                DR. LAUGHREN:  Again, this has only been

 

      looked at by individual programs so it is however

 

      many trials exist in the different databases, and

 

      generally, you know, we are talking about--this is

 

      ballpark again, I don't have the numbers in front

 

      of me but generally we are talking about anywhere

 

      from probably 4-10 trials per drug.  So, it has

 

      been looked at within individual programs.  It may,

 

      in fact, be larger than that if you include trials

 

      for indications other than depression.  You know, I

 

      am just giving rough estimates here.  So, it has

 

                                                               190

 

      not been looked at across programs the way we have

 

      looked at it here for the pediatric data--complete

 

      suicides has been but not the event data or the

 

      item data.

 

                DR. GOODMAN:  One final follow-up

 

      question, from me at least, on these data, I don't

 

      imagine that you have stratified in the adult data

 

      by age, such that you would look at whether there

 

      is a relatively increased risk of suicidality in

 

      the younger adults versus the older.

 

                DR. LAUGHREN:  I don't believe that has

 

      been done.  Again, these NDAs came in over a period

 

      of 10-12 years.  I don't recall that being done.

 

                DR. GOODMAN:  Dr. Pollock?

 

                DR. POLLOCK:  Just a quick question for

 

      Dr. Laughren, the 40,000 database that you spoke

 

      of, was that what was published in the Kahn report

 

      in The American Journal of Psychiatry, 2003, or has

 

      this been published?

 

                DR. LAUGHREN:  No, I believe it is a

 

      larger database than Kahn included in his analysis

 

      that was done several years ago.  So far it has

 

                                                               191

 

      only been published in abstract form, a little over

 

      a year ago.  It is an analysis that we are still

 

      working on but basically so far we have not seen a

 

      signal.

 

                DR. POLLOCK:  Thank you.

 

                DR. GOODMAN:  Dr. Rudorfer?

 

                DR. RUDORFER:  Yes, I have a

 

      question/comment for both Dr. Hammad and Dr.

 

      Laughren.  It seems to me that one issue that we

 

      are up against that is unique here, unlike the

 

      adult data, is the relative dearth of positive

 

      efficacy in these trials so that the Celexa data

 

      that we just saw are particularly interesting

 

      because, as I understand it, those are the only set

 

      of studies where there is one positive efficacy

 

      trial and one negative.  As I understand the

 

      suicidal risk ratio, there is an inverse

 

      relationship so that the study that was done in the

 

      U.S. and showed positive efficacy had a suicidal

 

      risk ratio less than 1 and the study that was done

 

      in seven different countries--we can talk about

 

      that tomorrow--and had negative efficacy result

 

                                                               192

 

      showed a suicidal risk ratio greater than 1.

 

                So, I wonder if there is any way we have

 

      for working around that issue, namely, if we are up

 

      against a couple of dozen studies that maybe were

 

      not done very well, or not done very seriously, or

 

      were not done in the right people, and then we are

 

      looking at adverse effects but in the context of a

 

      drug that is not doing what it is supposed to be

 

      doing.

 

                DR. GOODMAN:  Was that rhetorical?

 

                DR. RUDORFER:  That was the comment.

 

                DR. GOODMAN:  Well, thank you very much.

 

      Dr Pfeffer?

 

                DR. PFEFFER:  You gave us relative risks

 

      and the confidence intervals very rarely reached 1.

 

      What would be the power or the size of samples

 

      necessary to show the effects with more

 

      assuredness?

 

                DR. HAMMAD:  I have one in my backup

 

      slides that I can share with you.

 

                DR. NEWMAN:  While he is getting that,

 

      could I make a comment?

 

                                                               193

 

                DR. GOODMAN:  Okay.

 

                DR. NEWMAN:  When you have randomized,

 

      double-blind trials the main thing that you worry

 

      about is lack of power.  Most of the errors will

 

      leave you being unable to show a difference.  So,

 

      it is relevant I think to look not just at the

 

      confidence interval but what the p values were for

 

      these estimates when you pool all the trials

 

      together.  That is what I was just doing with my

 

      spreadsheet.  I don't know if Dr. Hammad did that

 

      or not, but for the confidence interval that is

 

      furthest from 1 the p value is about 5 times 10                         

 

                                                                              

 

  -5.

 

      So, the probability that these are chance findings

 

      is very, very low.  The confidence intervals are

 

      far from 1, at least for the outcome that is most

 

      impressive.

 

                So, I think to think that these are chance

 

      findings is not a viable explanation, even given

 

      the number of subgroups and even given the

 

      differences in the trials.  Most errors will be in

 

      the other direction, will be false negative.  This

 

      also addresses what you have on the slide but if

 

                                                               194

 

      you calculated the p values for the difference

 

      between the risk ratios and 1, you know, the p

 

      values for the pooled estimates.

 

                DR. HAMMAD:  No.

 

                DR. NEWMAN:  Well, I can share my

 

      spreadsheet.  Just from the confidence intervals

 

      and the width of the confidence intervals you can

 

      do that.

 

                DR. HAMMAD:  No, I didn't do that.  I

 

      thought the confidence interval gives you more

 

      information.

 

                DR. NEWMAN:  Yes, well, I disagree.  I

 

      think if you are talking about chances and

 

      explanation, how low the p value is, is actually

 

      very relevant and something that most people around

 

      the table can understand, and they are very low.

 

                DR. HAMMAD:  But they are not equivalent

 

      to each other actually.  So, you might have two

 

      confidence intervals that hardly overlap and then

 

      the p value is not significant, or the reverse.

 

      So, I thought that the confidence interval would

 

      give you more information, that is all.

 

                                                               195

 

                Back to your question, it actually depends

 

      on the incidence in the placebo group.  The red is

 

      assuming an incidence of 1 percent in the placebo

 

      group and the blue is assuming an incidence of 5

 

      percent in the placebo group.  So, for example, if

 

      you want to design a trial to be able to detect a

 

      relative risk of 3 or more, then you would actually

 

      need around 200 patients per group here and around

 

      800 patients per group there.  So, it depends on

 

      your assumptions of how many events would occur in

 

      your placebo group.  And, one of the limitations in

 

      this particular effort is the great variation even

 

      in the rate in the placebo group.  So, it would be

 

      hard to really plan for the future, but that is

 

      your range.

 

                DR. GOODMAN:  Dr. Pine and then Dr.

 

      Gorman, and those will be the last questions for

 

      the speaker.

 

                DR. PINE:  I wanted to return to the

 

      summary by Dr. Laughren and ask two questions about

 

      it.  It sounded like a meta-analysis of 40,000

 

      patients as opposed to a bunch of individual

 

                                                               196

 

      studies, I just wanted to confirm that I understood

 

      that correctly, that you were talking about a

 

      global meta-analysis, number one.

 

                Then, number two, I notice that you

 

      started your comment by stating that those studies

 

      have not been looked at with the same level of

 

      detail as the studies and analyses that have just

 

      been presented, oon the one hand.  On the other

 

      hand, I wondered if the level of review was

 

      comparable to kind of the first-pass review from

 

      the pediatric studies where there appeared to be a

 

      signal on more fine grade analyses.  Was that

 

      meta-analysis comparable to the initial pediatric

 

      one or not?

 

                DR. LAUGHREN:  Let me again distinguish

 

      between the analysis that is focusing on completed

 

      suicides in adults.  That is a very different

 

      matter from the analyses that the individual

 

      companies did, looking at either event data or item

 

      data.  I would say, in answer to one of your

 

      questions, that probably the quality of the

 

      analyses looking at event data and item data were

 

                                                               197

 

      comparable to the initial data that we got from

 

      Paxil in that sense.  But, again, none of those

 

      data have been reclassified using the more critical

 

      approach that we have used for these data, but

 

      probably comparable to what we have seen for Paxil,

 

      and from that standpoint may have some validity,

 

      the fact that we never saw anything in any of those

 

      trials.

 

                The adult completed suicide data--Tarek

 

      can speak more to that than I can, but that is a

 

      completely different thing.  That is something that

 

      we have done based on data that we have obtained

 

      from companies and a relatively small number of

 

      completed suicides.  I think the total number of

 

      completed suicides in that 40,000 patient database

 

      is only about--what?--30, Tarek?

 

                DR. HAMMAD:  Around 30, yes.

 

                DR. LAUGHREN:  Would you characterize that

 

      as a meta-analysis?

 

                DR. HAMMAD:  Yes, it is because we had a

 

      couple of hundred trials that were all pooled

 

      together, but the analysis was not the trials; it

 

                                                               198

 

      was the actual patients.  So, it is slightly

 

      different.  And, there were only eight trials that

 

      were actually positive--not positive, that had some

 

      event in one of the arms.  All other trials did not

 

      have anything at all.  So, it is sort of

 

      controversial to take findings from eight trials

 

      and pool them with others and then try to get a

 

      conclusion.  But even with those eight trials, our

 

      statistical group did a review and they found no

 

      signal, even focusing on those eight trials alone.

 

                DR. GOODMAN:  Dr. Gorman?

 

                DR. GORMAN:  This question is motivated by

 

      trying to answer some questions for the agency

 

      tomorrow.  When you looked at the relative risks of

 

      the suicidal scores that were used, you found them

 

      to be not predictive of the behaviors that you may

 

      be observing.  But we don't generally think of

 

      screening tests or predictive tests in terms of

 

      relative risk; we usually think of them in terms of

 

      sensitivity and specificity.  Can you reanalyze

 

      your data for us to see if these scores actually

 

      predict the behaviors you then observed?

 

                                                               199

 

                DR. HAMMAD:  I have this in my review.  I

 

      did a sort of clustered relation between the two

 

      types of events regardless of the treatment between

 

      the worsening and between outcome 3, which is the

 

      primary focus.  In some trials there was a

 

      significant association; in some there wasn't.  So,

 

      in some trials it was predictive to some extent; in

 

      some trials it wasn't.  But the word predictive

 

      implies that one is occurring before the other and

 

      we don't have this exact timing associated in the

 

      data.

 

                DR. GORMAN:  I was more interested in the

 

      patient-level data.  Were the ones that actually

 

      participated in behaviors that were ranked in

 

      outcome 3, in fact, predicted by the screening

 

      tools that we use?

 

                DR. HAMMAD:  But this assumes that you

 

      know the outcome occurred and then you have the

 

      screening tool before it, but we don't know that.

 

      The finding is not in my database.

 

                DR. GORMAN:  Thank you.

 

                DR. GOODMAN:  Thank you, Dr. Hammad.  We

 

                                                               200

 

      look forward to further interrogation of the

 

      data--not you but the data--tomorrow.

 

                DR. HAMMAD:  Thank you.

 

                DR. GOODMAN:  Now I am pleased to

 

      introduce Dr. Andrew Mosholder, from the FDA.

 

            Comparison Between Original ODS and Current DNDP

 

              Analyses of Pediatric Suicidality Data Sets

 

                DR. MOSHOLDER:  Thank you very much.

 

                [Applause]

 

                Thank you.  I was asked to present a brief

 

      comparison of the original analysis done in the

 

      Office of Drug Safety with the current analysis

 

      that Dr. Hammad just presented.  I will present

 

      that and then I will touch on two or three

 

      additional points that were covered in the March

 

      consult document that is in your briefing packages

 

      that weren't really part of the analysis we just

 

      heard, just to supplement that.  So, during this

 

      talk I will refer to the ODS analysis as the

 

      original one that I completed, and then the

 

      Division of Neuropharmacological Drug Products

 

      analysis as the one that Dr. Hammad just presented

 

                                                               201

 

      to you.

 

                This is just to orient you to the ODS

 

      analysis.  It was the same trials as in the DNDP

 

      analysis, with the important exception that the

 

      TADS data has been added to the DNDP analysis.  The

 

      events were determined from the responses to the

 

      July, 2003 data requests.  Dr. Laughren mentioned

 

      these requests earlier, but just to amplify on

 

      that, last July the agency asked all the sponsors

 

      of the drugs in question to essentially reproduce

 

      the analysis that GlaxoSmithKline had done for

 

      their Paxil pediatric trials.  This involved

 

      basically two components.  One was an electronic

 

      search of specific terms in the adverse event

 

      databases for those trials, then followed by a

 

      manual review of all the serious adverse events in

 

      those trials.  These were the data that I used for

 

      the ODS analysis.

 

                I chose to emphasize the sponsor

 

      identified suicide-related events, that were

 

      identified by the means I just described, that were

 

      also classified as serious adverse events and I

 

                                                               202

 

      will show you the exact definition of that in a

 

      moment.  This, of course, predated the Columbia

 

      University reclassification.

 

                There are some differences in the analytic

 

      methods.  This just gives a brief summary.  In the

 

      ODS analysis person-time was used as the

 

      denominator rather than the number of patients.

 

      The post-treatment window for including events was

 

      30 days versus 1 day in the DNDP analysis.  Events

 

      during down-titration I included in the ODS

 

      analysis.  Also, in the Mantel-Henzel calculations

 

      Dr. Hammad's analysis employed a correction for

 

      zero cells, whereas my method did not.

 

                To give you an overview of the data set

 

      for the analysis, there was a total of roughly 2200

 

      drug-treated patients and 1900 placebo-treated

 

      patients.  This yields a total exposure of about

 

      407 patient-years for drug, almost 350

 

      patient-years for placebo.  Just to remind people,

 

      patient-year is a unit of exposure.  It is a

 

      cumulative measure so that it could be represented

 

      by one patient receiving the drug for a year; two

 

                                                               203

 

      patients receiving a drug for six months; 12

 

      patients for a month, and so forth.

 

                As we have heard, one of the limitations

 

      of these data is that they are all short-term

 

      trials so that there is no implication that there

 

      is any year-long treatment data here.  In neither

 

      treatment group were there any completed suicides.

 

      Then, there was a total of 74 sponsor-defined

 

      suicide-related events with drug; 34 with placebo;

 

      and then a subgroup of those, 54, were serious and

 

      24 for placebo were serious.

 

                This slide gives the definition of

 

      seriousness.  It has already been mentioned this

 

      morning but, basically, if the event is fatal,

 

      life-threatening, involves hospitalization, is

 

      disabling or is a congenital defect it is

 

      considered to be a serious event according to the

 

      FDA regulations.  Now, in this case the events

 

      would fall under these two categories since there

 

      weren't any completed suicides, as has been

 

      mentioned, and the other two categories aren't

 

      relevant.

 

                                                               204

 

                Each sponsor determined whether the

 

      adverse event was serious, and that is routine in

 

      the conduct of clinical trials.  I will show you

 

      the comparison between the outcome that I

 

      emphasized, which is serious suicide-related

 

      events, to the Columbia University outcome 3, as we

 

      see over here, which is the suicidal

 

      behavior/ideation.  The reason for concentrating on

 

      seriousness was to eliminate some of the events

 

      that were of questionable clinical importance, such

 

      as superficial self-cutting or the girl who slapped

 

      herself.  Cases like those were not part of the

 

      serious events by and large.

 

                So, this gives the comparison for those

 

      two categories.  For the ODS serious

 

      suicide-related events there was a total of 78, and

 

      61 of these were also eventually classified by

 

      Columbia University as definitive suicidal

 

      behavior/ideation.  Of the remaining 17 cases, 13

 

      were considered self-injurious behavior with

 

      unknown intent, which is over here.  So, they were

 

      not part of outcome 3 essentially because the

 

                                                               205

 

      intent was unknown.  Then, conversely, for the

 

      Columbia University category--and this is ignoring

 

      the time following double-blind treatment so that

 

      this is a somewhat higher number because events

 

      occurring after treatment discontinuation are being

 

      shown here--there was a total of 95 in that

 

      category.

 

                As I said, 61 overlapped with the previous

 

      category.  There were 18 new cases disclosed by the

 

      expanded search algorithm that you head about

 

      earlier.  Then, there were 16 sponsor-defined

 

      suicide-related events which did not meet criteria

 

      for seriousness so that they were not included in

 

      the ODS analysis but they were considered to be

 

      definitive suicidal behavior/ideation by the

 

      Columbia University team.

 

                First I am going to show the results of

 

      relative risk for both analyses, and first for

 

      individual drugs.  These are the drugs for which

 

      both analyses were able to calculate a relative

 

      risk.  Just to orient you, first of all, let me

 

      point out this is a logarithmic scale because some

 

                                                               206

 

      of the confidence limits are quite broad here.

 

      Then, I have highlighted the value of 1 here to

 

      remind you that values above 1 indicate a risk with

 

      drug and below 1 indicate a protective effect of

 

      the drug.  For the ODS analysis the values are on

 

      the left and the DNDP are on the right.

 

                First of all, we see that just in general

 

      the new relative risks from the DNDP analysis fall

 

      within the confidence limits of the previous

 

      results.  So, from that standpoint there is

 

      agreement.  Then, if you look at particular cases,

 

      some are similar; some are a little different.  For

 

      sertraline the value decreased just slightly--let's

 

      see, this is 2.5 to 1.5 based on the addition of a

 

      single placebo case.  For paroxetine, 2.2 versus

 

      2.7.  Venlafaxine actually showed an increase, 1.8

 

      to 5 and the confidence limit, you see, just

 

      touches 1.  Fluoxetine in both cases is just below

 

      1.  However, with the inclusion of the TADS data

 

      you see that the new relative risk for fluoxetine

 

      is 1.5.  Then, for citalopram, 2.5 versus 1.4.

 

                Next we are going to look at some

 

                                                               207

 

      groupings of trials.  First, on the left are SSRI

 

      major depressive disorder trials.  Again, the value

 

      here, 1.9; the new analysis, 1.4.  The confidence

 

      limit extends below 1 in this case.  But then,

 

      again, with the addition of the TADS data the

 

      relative risk is 1.7.  Then, for the category of

 

      all trials the relative risk is 1.9 versus 1.8.

 

      Then, with the addition of the TADS data, just

 

      below 2.  You see in all cases that the confidence

 

      limit excludes 1.

 

                That concludes a brief overview of

 

      comparison of the two analyses.  I just wanted to

 

      touch on three additional topics.  First is the

 

      incidence rate difference analysis.  Secondly, and

 

      this has already come up in the discussion, there

 

      is one case in which we have direct comparison to

 

      adult data, and that is for paroxetine.  Finally, a

 

      little bit of data on treatment discontinuation

 

      events.

 

                This is an analysis of rate differences.

 

      This is a little different from what you have been

 

      seeing.  Again, the events are per patient-year

 

                                                               208

 

      but, of course, as I said, there is no implication

 

      that patients received the drug for longer than the

 

      short-term trials.  Here I have highlighted zero

 

      because, as you realize, a value above zero would

 

      indicate a risk of the drug because it is drug

 

      minus placebo.  A value below zero would indicate a

 

      protective effect of the drug.  This is actually

 

      statistically a rather crude method.  This is a

 

      simple totaling of the data for each drug's

 

      clinical trial database.

 

                But with those things in mind, we see

 

      first of all that the pattern is that in every case

 

      here for the individual drugs, except for

 

      fluoxetine, the risk difference is positive,

 

      indicating an excess rate on drug compared to

 

      placebo.  For fluoxetine I did not have the TADS

 

      data so one would expect, as we have seen with the

 

      addition of that data, that the fluoxetine risk

 

      difference would likely be above zero as well.  For

 

      fluvoxamine there were no events.  Unlike the DNDP

 

      analysis, there was one event for nefazodone,

 

      giving us a positive value.

 

                                                               209

 

                So, for the individual drugs, those you

 

      see, the confidence limits are rather broad.  For

 

      the set of all MDD trials the rate difference is

 

      about 0.09 events per patient-year.  For all trials

 

      it is somewhat lower.  Taking this one as the worst

 

      case, that translates to one excess serious

 

      suicide-related event for about every 12

 

      person-years of treatment with the drug.  In

 

      summary, this is just a slightly different way to

 

      look at the same data set.

 

                This is a summary of the analysis that

 

      GlaxoSmithKline did in which they applied the same

 

      search algorithm to their adult clinical trial

 

      database that had found the signal in the pediatric

 

      trials.  First of all, I need to point out, of

 

      course, that these events are not reclassified.

 

      These are simply the sponsor-defined

 

      suicide-related events.  These are, again, rates

 

      per patient-year.        There are a couple of things

 

      to point out.  First of all, if we look at the

 

      placebo rates we see, first of all, that in major

 

      depressive disorder compared to all indications the

 

                                                               210

 

      rate is a bit higher, and that is true for the

 

      pediatric group as well.  That is not unexpected,

 

      given the association of suicidality with major

 

      depressive disorder which is being diluted in the

 

      larger pool of trials with other indications.

 

                Secondly, we see that actually the placebo

 

      rates comparing adult and pediatric data sets are

 

      actually rather comparable, similarly for the MDD

 

      trials, not too dissimilar.

 

                Third, we notice that for the adult trials

 

      the rates between drug and placebo are really not

 

      that discrepant.  That could, of course, mean that

 

      some drug-treated patients are getting worse and

 

      others are getting better but there is no net

 

      imbalance.  Also, I should point out that, of

 

      course, these trials are not designed to measure

 

      impact on suicidality because, as we know, most

 

      suicidal patients are excluded from these studies.

 

      But be that as it may, there doesn't seem to be

 

      much discrepancy in the rates for the adult

 

      studies.

 

                However, for the paroxetine pediatric

 

                                                               211

 

      trials that is not the case.  You see that there is

 

      an excess for the MDD trials, and also in the

 

      larger pool of all trials which did reach

 

      statistical significance.  So, it is not perfect

 

      data but I think it suggests, at least to me, that

 

      there could be a difference between the pattern of

 

      these events for pediatric patients and adults.

 

                Finally, this is just to look at the

 

      possibility that drug discontinuation plays a role.

 

      These are going back to the serious suicide-related

 

      events now.  This is all trials, all indications.

 

      As you recall, in the DNDP analysis events were

 

      included up to one day after the end of

 

      double-blind treatment.  Here that is extended out

 

      to up to four weeks.  This shows the pattern.  We

 

      see that there is sort of this cluster here in the

 

      first week.  In fact, all those occurred within the

 

      first four days of treatment discontinuation.

 

                It may not be projecting real well, but

 

      paroxetine accounts for the largest number.  Five

 

      of the nine events were in the paroxetine trials.

 

      Not too much is really seen in the subsequent

 

                                                               212

 

      weeks.  Again, it is just a suggestion.  This is

 

      not perfect data but suggests that there may be

 

      some phenomenon happening early in the period after

 

      treatment discontinuation.

 

                In conclusion, both the original ODS

 

      analysis and the current DNDP analysis indicate an

 

      association of suicidal adverse events with

 

      antidepressant drug treatment in this set of

 

      short-term placebo-controlled clinical trials.

 

      Thank you.

 

                DR. GOODMAN:  Thank you very much.  Any

 

      questions?  Dr. Rudorfer?

 

                DR. RUDORFER:  Thanks.  Andy, a question

 

      about your discontinuation data, did you get the

 

      sense, or could you tell from the data whether

 

      there were discontinuation issues during the course

 

      of the trial?  I mean, some of the data we have

 

      seen suggest that in some of the trials adherence

 

      could have been a problem and I am wondering,

 

      particularly with paroxetine which you showed was

 

      being problematic after the end of the trial, if a

 

      child in the study is taking the drug only

 

                                                               213

 

      intermittently wouldn't they be exposed to repeated

 

      discontinuations?

 

                DR. MOSHOLDER:  Yes, of course, that is

 

      true.  I think that has been hard to capture in the

 

      clinical trial data though.  I think in some cases

 

      patients were discontinued by the investigator if

 

      they admitted to not having taken their medication

 

      in several days, but that might not always be the

 

      case.  So, it is very hard, at least in the data I

 

      looked at, to really get a sense.  It was much

 

      easier to look at what happened when double-blind

 

      treatment was known to have been discontinued.

 

                DR. RUDORFER:  Right.  Just as a

 

      follow-up, I am wondering if that could play a role

 

      in the difference you noted between the pediatric

 

      and the adult data for paroxetine, that is, if

 

      medication use is more continuous in the adult

 

      samples than in the pediatric ones.

 

                DR. MOSHOLDER:  That is a hypothesis.  I

 

      don't know if there is any data that directly

 

      compares compliance for pediatric and adult

 

      patients.  I think we know that compliance could

 

                                                               214

 

      always be better, wherever one looks, but whether

 

      it is really worse in the pediatric group or not--I

 

      think people suspect that but I know if that has

 

      been documented.

 

                DR. GOODMAN:  Dr. Fant?

 

                DR. FANT:  Yes, I was struck by your

 

      fluoxetine data when you included the TADS trial,

 

      you know, showing more concern than the previous

 

      trials had shown, and it really makes me wonder,

 

      with the inclusion of children with other

 

      coexisting comorbidities and other medications on

 

      board, whether or not this may be pointing to a

 

      subset of kids, maybe in a distinct minority but

 

      who may be at higher risk for potential adverse

 

      events related to these medicines.  It is just a

 

      comment.

 

                A question, when you looked at the TADS

 

      data, when you included that, did you look at all

 

      of the kids who were given the drug or did you

 

      split it up into how they looked when they were

 

      given the drug alone or given the drug plus CBT?

 

                DR. MOSHOLDER:  I think I have to defer

 

                                                               215

 

      this to Dr. Hammad who gave me those results so I

 

      could include them here.

 

                DR. FANT:  Since CBT seemed to suggest

 

      perhaps an enhanced effect on efficacy.

 

                DR. HAMMAD:  In my presentation I actually

 

      mentioned that I did not include CBT patients.  The

 

      two arms were excluded because they were not really

 

      blinded.  I only included the blinded ones.

 

                DR. GOODMAN:  Dr. Temple?

 

                DR. TEMPLE:  I was just going to mention

 

      that before the TADS data came in one of our

 

      explanations for why Prozac might have been

 

      different is that it is not so easy to discontinue

 

      with its several week half-life.  Now that the TADS

 

      data seem to go in the same direction, the

 

      discontinuation hypothesis seems less strong.

 

                DR. GOODMAN:  Dr. Gibbons?

 

                DR. GIBBONS:  In your person-time analysis

 

      how did you handle people who had multiple events?

 

                DR. MOSHOLDER:  I took the first event.

 

                DR. GIBBONS:  So, they counted just once?

 

                DR. MOSHOLDER:  Right.  I believe Dr.

 

                                                               216

 

      Hammad took the clinically worst event; I took the

 

      first event.  As a practical matter, that didn't

 

      involve large numbers.

 

                DR. GIBBONS:  Great!

 

                DR. GOODMAN:  Dr. O'Fallon?

 

                DR. O'FALLON:  In your discontinuation

 

      data, is there any chance that in that week-1 group

 

      there are people who were discontinued because they

 

      were doing badly?  In other words, are these people

 

      who went all the way to the end of the planned

 

      analysis and then had an event?  I mean, you are

 

      looking at this event in the week after they

 

      discontinued therapy.  Were they the ones who

 

      completed the therapy or were they possibly having

 

      their therapy discontinued because they weren't

 

      doing well?

 

                DR. MOSHOLDER:  Yes, I don't have the

 

      numbers on that to break it down by whether they

 

      were prematurely discontinued or completed the

 

      intended length of treatment.  I believe it is a

 

      mixture of both but I can get you those numbers.

 

                DR. GOODMAN:  Last question?

 

                                                               217

 

                DR. PINE:  Yes, I found the direct

 

      comparison of the data for paroxetine in the adults

 

      and children very helpful, and I was wondering if

 

      that was volunteered by the company or was there a

 

      specific request and, if the latter, are there

 

      plans to do comparable analyses for other agents?

 

                DR. MOSHOLDER:  Well, by way of answering,

 

      I can say it is included in my March memorandum and

 

      it was a submission that actually I believe went to

 

      another regulatory agency which FDA was copied on.

 

      As far as whether neuropharm. is asking other

 

      sponsors, I will defer to one of the people from

 

      neuropharm. for that.

 

                DR. LAUGHREN:  Yes, we don't have any

 

      current plans to do this in terms of adult data.

 

      Since we have this fairly large database with

 

      completed suicides which, after all, is the event

 

      that is of greater interest right now we are

 

      focusing on that.

 

                DR. GOODMAN:  Momentarily we will break

 

      for lunch.  Before we do so, this is the last call

 

      for registered open public hearing speakers to sign

 

                                                               218

 

      in.  We are going to reconvene and, hopefully, be

 

      seated and ready for presentations by 1:15.  We

 

      have three presentations that need to be given

 

      before we begin the public hearing at 2:00.  For

 

      the benefit of the committee members sitting around

 

      the table, there are reserved places for you at

 

      lunch in the restaurant in the lobby.  A final

 

      reminder once again, we are not to discuss matters

 

      that are germane to our deliberations during our

 

      break.

 

                [Whereupon, at 12:26 p.m., the proceedings

 

      were adjourned for lunch, to reconvene at 1:15

 

      p.m.]

 

                                 - - -

 

                                                               219

 

                A F T E R N O O N  P R O C E E D I N G S

 

                DR. GOODMAN:  We are about to hear three

 

      presentations from representatives of the

 

      pharmaceutical industry.  We are going to get

 

      started with the presentations.  Our first speaker

 

      is representing Forest Laboratories.

 

                         Sponsor Presentations

 

            Citalopram and Escitalopram Product Safety Data

 

                          Forest Laboratories

 

                DR. JONAS:  Good afternoon.  My name is

 

      Jeffrey Jonas, and I am the vice president for the

 

      central nervous system therapeutic area at the

 

      Forest Research Institute.  Thank you for allowing

 

      me to address you today.

 

                I will be presenting some new analyses

 

      today based on our three studies of pediatric major

 

      depression.  Two of these studies you have already

 

      seen involving citalopram.  Another involves a

 

      recently completed study of escitalopram, the

 

      S-isomer of citalopram which we believe to be the

 

      active component, also in pediatric major

 

      depressive disorder.

 

                                                               220

 

                I will be presenting an analysis of the

 

      SREs, presenting an integration of these three

 

      studies.  Then I will discuss our Lundbeck study,

 

      European Union study 94404 which was conducted by

 

      our licensor, Lundbeck, and talk a little bit why

 

      we think this study is distinct from our other

 

      studies and, indeed, from most of the other studies

 

      under consideration today.  Finally, I will be

 

      concluding with some exploratory analyses, looking

 

      at some alternative explanations for SREs, in

 

      particular, an examination of activating adverse

 

      events and a look at responder analyses of patients

 

      with and without serious suicide-related activities

 

      and events.

 

                As I mentioned, there are three completed

 

      placebo-controlled studies in pediatric major

 

      depressive disorder, two with citalopram and one

 

      with escitalopram.  The citalopram studies are

 

      MD-18, which was a U.S. study looking at children

 

      and adolescents, conducted in outpatients in the

 

      United States.  The second study is a European

 

      Union study, 94404.  This is a study of adolescents

 

                                                               221

 

      only that enrolled both inpatients and outpatients.

 

                The escitalopram study, MD-15, studied

 

      children and adolescents and in most respects was

 

      similar in design and implementation to the U.S.

 

      citalopram study MD-18.  This study was recently

 

      completed.  The safety data were just recently

 

      submitted to the FDA, in May, and the efficacy data

 

      were completed afterwards, sometime in June, and

 

      then submitted to the FDA.  We will be presenting

 

      integrated analyses for this study with our other

 

      two studies, but I should point out that the SREs

 

      were not reclassified by the Columbia group.

 

                The escitalopram study was an 8-week,

 

      double-blind, flex-dose study, basically

 

      conventional design.  It studied patients with

 

      DSM-IV major depressive disorder.  Of note,

 

      patients who were at high risk for suicidality were

 

      excluded and this study studied only outpatients.

 

                I will be focusing on safety today but I

 

      just want to highlight the efficacy results of

 

      these three studies.  Study MD-18 in citalopram was

 

      a positive study utilizing as its primary endpoint

 

                                                               222

 

      the CDRS-R.  Study MD-15 also had the same

 

      endpoint.  This was a negative study.  I should

 

      note, however, that recent analyses have shown

 

      clear trends in the adolescent subpopulation in

 

      MD-15.  Also of note, both of these studies had

 

      similar decreases in the CDRS-R of about 22 points,

 

      the differentiating feature being the placebo

 

      response in MD-15 which was largely driven by the

 

      placebo response in the children's group.  Study

 

      94404 utilized the K-SADS and this was a negative

 

      study.

 

                This slide now shows the SREs for the

 

      three studies combined.  The middle row shows you

 

      the data for MD-15 which is the recently completed

 

      study in escitalopram.  We analyzed the study using

 

      the FDA-provided algorithms that were used in the

 

      other studies for the analyses we have been

 

      discussing today.  In the study there were three

 

      SREs, two in placebo and one in escitalopram.  None

 

      of these was categorized as SAEs.

 

                As you can see here, for both the U.S.

 

      studies the risk for an SRE was greater in the

 

                                                               223

 

      placebo group than in the escitalopram group.  The

 

      reverse was true in the European Union study.

 

      Overall, however, the risks for placebo or active

 

      treatment are roughly comparable when all three

 

      studies are combined.

 

                This slide depicts that in terms of

 

      relative risk.  As you can see, the confidence

 

      intervals all cross unity and, again as you can see

 

      for the U.S. studies, the relative risk for an SRE

 

      is greater for the placebo patients rather than

 

      patients on active drug, and the reverse is true

 

      for patients in the 94404 study.

 

                Dr. Hammad, in his report, did comment

 

      that in most respects our European study was

 

      dramatically different or differed in almost every

 

      respect from our U.S. studies.  So, we spent a

 

      little time looking to see if we could understand

 

      some of these differences.

 

                We think the most important

 

      differentiating features involve the inclusion and

 

      the exclusion criteria utilized in the U.S. and the

 

      E.U. studies.  This slide shows some of the major

 

                                                               224

 

      differences.  For example, inpatients could be

 

      enrolled in the E.U. study.  I should point out

 

      that most of these inpatients were complex

 

      psychiatric cases with many psychosocial stressors,

 

      many coming from dysfunctional families, many on

 

      multiple medications.  In addition, patients could

 

      have recent psychiatric hospitalizations, even

 

      suicidality, could be included in the study, and

 

      patients with a history of suicide attempts, even a

 

      recent one, could also be included.  About 15

 

      percent of the patients in the European study were

 

      inpatients.  About a fifth had a history of

 

      psychiatric hospitalization and about a third had a

 

      history of a suicide attempt.

 

                Few other studies of the studies we have

 

      looked at today had these features.  In addition,

 

      the complex nature of the inpatients may have made

 

      it hard to have successful randomization balance in

 

      these studies.  In particular however, we think the

 

      features of including inpatients and patients with

 

      significant psychiatric hospitalizations may have

 

      been a major differentiating feature of this study

 

                                                               225

 

      from the other studies we examined today.

 

                We, therefore, did a somewhat

 

      straightforward analysis and simply looked at

 

      relative risk in 94404, excluding the patients who

 

      had a history of hospitalization or who were

 

      inpatients at the start of the study.  As you can

 

      see, when you do this analysis the risk for SREs is

 

      similar between placebo and citalopram.

 

                Looking at the relative risk, we now see

 

      an analysis that in some ways makes these three

 

      populations and three studies comport more closely

 

      to each other.  Here you see that overall the

 

      relative risk for an SRE is greater for placebo

 

      than for drug.

 

                If one accepts the possibility that

 

      medication may not be the only factor or a factor

 

      in inducing SREs, one must look for other

 

      explanations.  One common theory is that patients

 

      experience activating adverse events in association

 

      with SSRI treatment.  This has been postulated also

 

      in relationship to other therapies but today we are

 

      speaking about SSRIs.  In particular, there is a

 

                                                               226

 

      theory that SSRI treatment induces early stage AAEs

 

      that, in turn, are precursors to SREs.  As a

 

      corollary, there is some clinical theory, I would

 

      says, that patients sometimes have to get worse to

 

      get better, and that is, patients who are

 

      responding to treatment undergo an energizing

 

      effect that may be confused or may be heralded as

 

      an activating adverse event--so-called getting

 

      worse to get better.

 

                Regardless of how we postulate the role of

 

      AEs, we thought this was worthy of examination.

 

      So, we cast a broad net at looking at AEs in our

 

      studies in order to make sure that we basically

 

      subsumed any adverse event that might be considered

 

      to be activating.

 

                This slide presents the risk data for the

 

      three studies.  As you can see, overall there is

 

      not very much difference between active therapy and

 

      placebo.

 

                We also conducted other analyses looking

 

      at activation adverse events.  We looked at the

 

      pattern of onset and we found no difference between

 

                                                               227

 

      drug and placebo.  We also noted that the large

 

      majority of patients who have AAEs do not go on to

 

      develop SREs.  Conversely, if one looks at patients

 

      with SREs, we found that if one looks for close

 

      proximity of AAEs to the SRE there is very little

 

      difference between the drug and placebo groups.

 

      Taken as a whole, we found no preferential

 

      relationship between AAEs and medication therapy.

 

                This slide shows the relative risk for

 

      developing AEs in drug versus placebo.  As you can

 

      see, in the two U.S. studies the relative risk was

 

      actually greater than in the European study, 94404,

 

      and we found this to be an interesting finding.

 

      You may recall that the signal for SREs in the U.S.

 

      studies was weaker than in the 94404 study where

 

      the risk of SREs was felt to be greater for drug

 

      treatment.  This is not what one would expect if

 

      one thought that SREs were associated with AAEs.

 

      As a result, we feel that there is not very good

 

      data in our data set to suggest a relationship

 

      between AAEs and SREs.

 

                Finally, we explored what we thought was

 

                                                               228

 

      perhaps a more parsimonious explanation for SREs,

 

      that is that patients who develop SREs are simply

 

      patients who are not responding to therapy, whether

 

      they are being treated with drug or placebo.  We

 

      hypothesized that SREs were simply associated with

 

      the course of depression, exacerbation of

 

      depression or clinical deterioration rather than

 

      associated with medication treatment.

 

                We conducted a series of analyses to look

 

      at this question.  The one I am going to show you

 

      now compared the course of response in patients

 

      with and without SREs using the change from

 

      baseline in a primary efficacy measure. the K-SADS.

 

                This is the data from study 94404, looking

 

      at all the patients who had SREs.  There are a

 

      number of points to make.  First, there is good

 

      separation between the groups.  However, the groups

 

      here are patients with and without SREs.  The top

 

      two lines represent patients who had SREs; the

 

      purple, patients on placebo; the blue, patients on

 

      citalopram.  This is an LOCF analysis and I should

 

      point that if you plot this with the OC analysis

 

                                                               229

 

      the curves are virtually the same.  Approximately

 

      50 percent of these patients went on to completion,

 

      likely, of course, because these patients could be

 

      hospitalization in this study even during the

 

      course of the study.

 

                If you look at this slide, this suggests

 

      to us that it is lack of response that may be

 

      responsible for the development of SREs, regardless

 

      of treatment group, rather than a distinct effect

 

      of medication.

 

                We have done a number of other analyses

 

      looking at this theory and some of them are still

 

      in development.  However, if you look, for example,

 

      at the patients in this study who were classified

 

      by the Columbia group as having SREs, of the nine

 

      patients on citalopram with SREs, none met

 

      protocol-defined endpoints for response.  In the

 

      patients on placebo, there were five.  Only one met

 

      protocol-defined criteria for response.

 

      Considering that in this study both the placebo

 

      group and the active treatment group had

 

      protocol-defined measures of response at 60

 

                                                               230

 

      percent, we think this is an interesting difference

 

      and we, again, think that these data suggest that

 

      it is exacerbation of depression, regardless of the

 

      treatment group, that may play an important factor

 

      in the development of SREs.

 

                In conclusion, we found that the numerical

 

      rate of SREs in the two U.S. studies was lower in

 

      active drug groups versus placebo.  In the E.U.

 

      study, when one corrects for patients who might not

 

      have been included in the U.S. studies, this

 

      removes the signal for SREs from that study.

 

                We found no evidence overall of an

 

      increased rate of AEs in the active drug group

 

      relative to placebo, and really no evidence

 

      suggesting that AAEs were etiologically related to

 

      the induction of SREs.

 

                Finally, our data suggest that patients

 

      with SREs were typically poor responders whether

 

      they received placebo or active drug.  Thank you

 

      very much.

 

                DR. GOODMAN:  Thank you.

 

                DR. MCGOUGH:  Did you elicit your

 

                                                               231

 

      activating AEs by structured interview or rating

 

      form, or was it simply open-ended questioning?

 

                DR. JONAS:  The AAEs in the European study

 

      had a questionnaire and we actually got our AAEs by

 

      searching the data strings for the preferred terms

 

      in the studies.

 

                DR. MCGOUGH:  How about in the U.S.

 

      studies?  Was there a structured rating to elicit--

 

                DR. JONAS::  No, in the U.S. it was

 

      spontaneous.

 

                DR. MCGOUGH:  Because there is good work

 

      that shows that you get under-reporting of AEs if

 

      you don't have a structured instrument.

 

                DR. GOODMAN:  Dr. Fant?

 

                DR. FANT:  Your second conclusion or

 

      summary point is that patients with SREs are

 

      typically poor responders, suggesting that it had

 

      more to do with their non-responsiveness than the

 

      drug itself.  Based on your data, can you exclude

 

      the possibility that there is something about the

 

      makeup of those patients that the introduction of

 

      altered chemistry might predispose certain

 

                                                               232

 

      behaviors in those particular patients?

 

                DR. JONAS:  We looked to see--

 

                DR. FANT:  --which may coexist with

 

      non-responding in general.

 

                DR. JONAS:  We looked to see, when we did

 

      these analyses and, as I say, some of these are

 

      still ongoing, whether or not there were any

 

      differences between the groups in terms of pattern,

 

      onset and so forth, and we just found none.  It

 

      simply looked as though this was a pattern that was

 

      common to patients whether they received placebo or

 

      drug.  So, we had no clue, for example, of any

 

      prognostic factors that might herald this. if I am

 

      answering your question.

 

                DR. GOODMAN:  Thank you very much, Dr.

 

      Jonas.  Our next speaker will be representing

 

      Pfizer Pharmaceuticals.

 

                 Sertraline Use in Product Population:

 

                A Risk/Benefit Discussion, Pfizer, Inc.

 

                DR. ROMANO:  Thank you very much.  My name

 

      is Steve Romano.  I am the therapeutic head for

 

      psychiatry in our worldwide medical organization. 

 

                                                               233

 

      That is not the name you see on your agenda.

 

      Charlotte Kremer is a colleague of mine.  The title

 

      there though is mine.

 

                What I am going to be talking about today

 

      briefly is sertraline use in the pediatric

 

      population and I am going to talk a bit about a

 

      risk/benefit discussion.  Of course, I also want to

 

      say that I appreciate the opportunity to address

 

      this joint committee.

 

                There are some critical points I think

 

      that are worthwhile considering in the assessment

 

      of risk/benefit for any antidepressant for use in

 

      pediatric patients and adolescent patients with

 

      MDD.  Clearly, MDD is a very serious illness.  It

 

      affects many children and adolescents in the U.S.

 

      and is associated with suicidal behavior.

 

      Unfortunately though, physicians have limited

 

      approved treatment options for pediatric patients

 

      with MDD.  Pfizer believes that the risk/benefit of

 

      antidepressant use in pediatric depression should

 

      be assessed on an individual product basis, and

 

      this is for a number of reasons.

 

                                                               234

 

                Antidepressants do differ with regard to

 

      chemical structure, pharmacological profile,

 

      pharmacokinetics, adverse events and

 

      discontinuation symptom profiles, and I think that

 

      all of them may potentially translate into a

 

      differential effect in the real world.  Also, in

 

      support of this, as a result of the studies

 

      reviewed in the FDA analysis, they do vary from

 

      drug to drug.  We believe that approaching this

 

      issue as a class effect might jeopardize or at

 

      least fail to highlight potential beneficial

 

      treatments for children or for some children and

 

      adolescents with MDD.

 

                The suicide-related behavior in MDD in the

 

      pediatric population is a huge medical concern and

 

      a public health concern.  It is the third leading

 

      cause of death in adolescents 15-19 years old.  The

 

      annual present prevalence rate of MDD in children

 

      is roughly 2-3 percent but about 2-3-fold that in

 

      adolescents.  The diagnostic criteria, as we all

 

      know, clearly clarify suicidality as a part of the

 

      disorder itself and that is clearly captured in our

 

                                                               235

 

      diagnostic nomenclature, DSM-IV for instance.

 

                In one study, it is important to note that

 

      suicidality in depressed children and adolescents,

 

      at the time of study entry was quite significant,

 

      in fact, about 1/10 individuals had a previous

 

      suicide attempt and up to 66 percent, or about

 

      two-thirds of the patients, actually had a previous

 

      history of suicidal ideation.  I say this because I

 

      think the latter may very well complicate our

 

      ability to evaluate suicidal ideation in clinical

 

      trials.  It is frequent and it is very difficult to

 

      assess the intent.  Suicide attempts are a much

 

      clearer manifestation of potential suicidality.

 

                We are now shifting to the Pfizer

 

      sponsored placebo-controlled trials.  These are the

 

      trials done in pediatric patients with sertraline.

 

      As you can see, there are approximately five

 

      studies.  The three studies I am going to talk

 

      about are the first three, a study in OCD and two

 

      studies identically designed in major depressive

 

      disorder.  Those are the three studies that have

 

      contributed to the analyses that you are going to

 

                                                               236

 

      review today, or have reviewed to this date.

 

                The last two studies, one a PTSD study

 

      that is being conducted in response to a pediatric

 

      request, and the last, a non-IND OCD study, are

 

      both continuing and are blinded so they have not

 

      contributed to any events that you are going to see

 

      in any of the analyses and I am not going to talk

 

      anymore about those today.

 

                What I do want to point out though is that

 

      all of these studies include both children and

 

      adolescents in the age range of 6-17.  There is, by

 

      the way, and it is worth noting one NIMH-sponsored

 

      study that Pfizer has provided sertraline to, and

 

      it is not so dissimilar from the TADS study that

 

      was reported this morning.  It is called the POTS

 

      study and it is looking at OCD patients.  We do

 

      understand from communication from John March, and

 

      this is personal communication, that there were no

 

      events in any of the arms of that study that looked

 

      at CBT, sertraline, a combination as well as

 

      placebo, and that is a randomized trial.  That has

 

      been submitted for publication but is not yet in

 

                                                               237

 

      press.  That was not a Pfizer sponsored study.  I

 

      just share that for completeness.

 

                The main discussion today, obviously is in

 

      MDD but I do want to show you that, in fact, we

 

      have met the rather rigorous criteria for a

 

      regulatory submission and an indication in OCD in

 

      children.  This just shows that in our study, the

 

      ITT analysis, LOCF, change from baseline to

 

      endpoint.  We did show a robust difference, a

 

      statistically significant difference between drug

 

      and placebo for OCD.  We have been on the market

 

      for OCD and have had an indication in OCD since

 

      1997.

 

                Turning now our attention to the studies

 

      in major depression, we used the CDRS as the

 

      primary outcome measure and the primary efficacy

 

      analysis was a change on scores from baseline to

 

      endpoint in the ITT population, the LOCF analysis.

 

      As you can see, in both individual studies, study

 

      1001 and study 1017, neither study showed a robust

 

      separation from placebo although, as Dr. Laughren

 

      pointed out this morning in his summary of all the

 

                                                               238

 

      trials, study 1001 on the primary analysis of the

 

      change score on CDRS did show a trend of 0.8.

 

                But, interestingly, we did have an a prior

 

      defined analysis which was a pooled analysis of

 

      those two identically designed trials, and that was

 

      also reported in an article by Wagner in JAMA about

 

      a year ago.  In that particular pooled analysis, in

 

      fact, we showed separation from placebo on both the

 

      primary outcome measure of the CDRS change score,

 

      as well as on the responder analysis, the

 

      categorical analysis of those patients who met a

 

      greater than 40 percent change in CDRS at endpoint.

 

                Now, I think the interesting point to

 

      highlight is really when we look at this data, why

 

      is it that we are not seeing a more robust or

 

      significant difference between drug and placebo in

 

      pediatric patients with depression?  In other

 

      words, it doesn't mirror that which we see in

 

      adults.  And, I think this slide is somewhat

 

      helpful in clarifying, at least for the sertraline

 

      database, what might be contributing to that.

 

                This is looking at the placebo-controlled

 

                                                               239

 

      pediatric MDD studies with sertraline, but at this

 

      case we are looking at the CDRS responder rate, the

 

      categorical analysis.  I have it divided, on the

 

      left for children and on the right for adolescents.

 

      I think the important point here is that the

 

      placebo response in both children and adolescents

 

      is quite high but it is even more significantly

 

      elevated in children.  We did include children in

 

      all of our trials and in both MDD studies.  So, as

 

      you can see, there was a separation in the

 

      adolescent subgroup.  This is a post hoc

 

      subanalysis.  There is separation on this

 

      particular indicator of improvement--there is not,

 

      but both placebo and drug showed significant

 

      improvement on both subgroups.

 

                Just for completeness, you saw the

 

      presentation of the item 13 score this morning in

 

      previous presentations, this is just to highlight

 

      that item 13 of the CDRS, which is suicidal

 

      ideation score, did improve in patients with major

 

      depression in our sertraline clinical trial

 

      database from baseline to endpoint.  As you can

 

                                                               240

 

      also see though, there is no significant difference

 

      between active treatment, in this case sertraline,

 

      and placebo but both groups showed improvement from

 

      baseline to endpoint.  I think the fact that

 

      children can get in, present for their illness and

 

      actually get treated and are seen on some regular

 

      basis does impact on a child's outcome.

 

                Let's move specifically to talk about the

 

      events of suicidal attempts and suicidal ideation.

 

      None of what I am showing you is new.  This is in

 

      the briefing documents and was included in the

 

      analysis that the FDA and Columbia have done.  I

 

      think it is also important to point out that the

 

      FDA analysis is consistent with the Pfizer

 

      analysis.  In other words, no events were relabeled

 

      or significantly changed.  They did not find new

 

      events.  So, this really is consistent with the

 

      analysis that was done by both FDA and Columbia.

 

                What I want to show now is suicide

 

      attempts first.  We feel strongly that we need to

 

      look at suicide attempts separately from suicidal

 

      ideation.  Suicidal attempts are a much clearer

 

                                                               241

 

      and--it is a much clearer indicator of suicidality.

 

      As you can see here, for patients in the MDD trials

 

      as well as the patients in the OCD trial the rate

 

      for suicide attempts was quite low.  In fact, it

 

      was exact in the case of subjects experiencing

 

      these events in MDD.  We had two patients in the

 

      MDD trials who received sertraline and reported an

 

      event that was classified as a suicide attempt.  We

 

      had two subjects in the placebo group, although one

 

      of those subjects contributed two events of

 

      suicidal attempt.  But the incidence rate based on

 

      the subject numbers is the same and as you can see

 

      by the confidence intervals, they overlap zero.

 

      There is no difference.  In the OCD study there

 

      were no events in either the placebo group or the

 

      sertraline group and in the combined, as you can

 

      see, we are showing the exact incidence.  Looking

 

      at suicidal ideation, again, in this case this is a

 

      very common adverse event and it is quite difficult

 

      to assess intent around suicidal ideation.  So, we

 

      really do feel it is worth looking at them

 

      separately and not combined.  Again, as you can see

 

                                                               242

 

      here for MDD and OCD, there was a relatively low

 

      rate of events across these studies.  In the MDD

 

      studies, again, we were looking at the pooled

 

      analysis of those two MDD trials.  There were three

 

      patients on sertraline for a rate of 1.6.  There

 

      were no patients on placebo that experienced the

 

      event of suicidal ideation during the course of

 

      those MDD trials.

 

                In the OCD trial, which was a 12-week

 

      short-term trial, we see that there were no events

 

      in the sertraline group but one event out of 95

 

      patients in the acute phase of that particular

 

      trial.  As you can see, neither in MDD nor in OCD

 

      or for sertraline or placebo was there a

 

      statistically significant difference across the

 

      groups, and that is true also for the combined

 

      analysis.

 

                Now, one of the issues that has arisen as

 

      being very important to consider is, is there a

 

      temporal association between the onset of a

 

      particular event, like suicide attempt or ideation,

 

      and the initiation of double-blind therapy or

 

                                                               243

 

      titration of drug during the course of the study.

 

      This is looking at all the cases of suicidal

 

      ideation and suicide attempt for sertraline and for

 

      placebo in our trials, both the MDD trials and the

 

      OCD trial, so for those three trials.

 

                As you can see, if you look to the far

 

      end, the last column, day of event, the day of

 

      double-blind therapy, in fact in sertraline-exposed

 

      patients none of these events occurred in the first

 

      week or two of exposure to drug, and there was no

 

      pattern of response that was based on changes or

 

      titration of drug during the course of the therapy.

 

      For placebo, there were two patients in the first

 

      week and a half, one in depression and one in the

 

      OCD trial, where the event was associated with

 

      initiation of treatment but in this case, of

 

      course, we are looking at placebo.

 

                So very importantly, there was no specific

 

      pattern in time of event.  It was fairly random.

 

      There was no association between time of event and

 

      dose increases.  I think more importantly as well,

 

      when we get down to the narrative level most of

 

                                                               244

 

      these events were actually associated with some

 

      psychosocial stressor or precipitant that was

 

      captured.

 

                In summary, for the placebo-controlled

 

      pediatric studies with sertraline we can say that

 

      sertraline is effective and safe in the treatment

 

      of pediatric OCD, and we were granted that

 

      indication about eight years ago.  The a priori

 

      pooled analysis of the sertraline clinical studies

 

      in pediatric MDD did demonstrate a statistically

 

      significant effect on the CDRS but, admittedly, the

 

      benefit relative to placebo was modest.  The effect

 

      size was relatively low, and there was a high

 

      placebo response, as I showed you previously.  That

 

      was primarily driven in the subpopulation, children

 

      ages 6-11.

 

                There were no completed suicides in any

 

      pediatric study with sertraline.  You are well

 

      aware of that.  There were also no statistically

 

      significant differences between sertraline and

 

      placebo in placebo-controlled studies of MDD or OCD

 

      with respect to suicide attempts, as I just showed

 

                                                               245

 

      you, or suicide ideation.  Again importantly, no

 

      temporal association was seen between onset of

 

      double-blind therapy or dose increases and

 

      suicide-related events, either suicide attempts or

 

      suicide ideation.

 

                So, just to highlight the points that we

 

      really think are very important to consider are the

 

      fact that this is a very serious illness; that

 

      physicians really do have limited approved

 

      treatment options for the treatment of pediatric

 

      patients with MDD; and that the risk/benefit of

 

      antidepressant use in pediatric depression should

 

      really be assessed on an individual product basis

 

      for the reasons I mentioned earlier.  Again, I

 

      think it is worth underlining that approaching this

 

      issue as a class effect might jeopardize or at

 

      least limit the likelihood of clarifying some

 

      benefit in some population of patients with MDD in

 

      the pediatric group.

 

                Lastly, I just want to highlight a

 

      position of Pfizer's, we currently feel that class

 

      labeling for monitoring during treatment with

 

                                                               246

 

      antidepressants accurately reflects the risk of

 

      suicidality in adult as well as pediatric patients.

 

      We think that such labeling should be applied to

 

      all medications indicated for the treatment of

 

      depression and simply not just to the SSRIs or

 

      SNRIs, and I think we heard earlier from Tom

 

      Laughren that that may, in fact, be a consideration

 

      of the FDA's as well.

 

                We also feel that if the FDA does consider

 

      a label change necessary that product specific

 

      labeling would be most beneficial to prescribers

 

      and patients.  I guess an example of that might be

 

      the inclusion of specific event rates of

 

      suicide-related behavior for the placebo-controlled

 

      clinical trials, and perhaps the best place for

 

      that would be in the adverse section of the label.

 

      We do this for other dimensions of tolerability

 

      like weight, for instance, and that has been very

 

      helpful to our prescribers and I think it might

 

      actually clarify potential risk as well as a

 

      possible benefit in some patients treated with

 

      sertraline.  Thank you.

 

                                                               247

 

                DR. GOODMAN:  Thank you, Dr. Romano.

 

      Questions from the committee?  If not, I would like

 

      to proceed with our next speaker who will be

 

      representing Wyeth Pharmaceuticals.

 

                         Wyeth Pharmaceuticals

 

                DR. CAMARDO:  Good afternoon.  I am Dr.

 

      Joseph Camardo.  I am head of medical affairs for

 

      Wyeth, located in Pennsylvania.  Wyeth developed

 

      and has marketed venlafaxine, brand name Effexor,

 

      since 1994 and I want to start by expressing my

 

      appreciation for the opportunity to speak before

 

      the committee.

 

                As we have heard today, mental illness,

 

      including depression in pediatric patients, is a

 

      complex medical condition and it is associated with

 

      the risk of suicide.  More than two million

 

      children and adolescents in this country suffer

 

      from depression in one form or another.  Physicians

 

      need to treat individual children and they have

 

      cautiously used the newer antidepressants,

 

      including venlafaxine, even though most are not

 

      indicted in the pediatric population.

 

                                                               248

 

                Wyeth has never labeled or recommended

 

      venlafaxine for such use but we, and other

 

      manufacturers, have conducted clinical studies of

 

      antidepressants in children.  However, despite all

 

      of our research efforts many of the drugs that have

 

      been very beneficial in adults have not been proven

 

      to be effective in clinical studies in pediatric

 

      patients.  The studies of antidepressants in

 

      children have shown an apparent increase in

 

      suicidal thoughts and possibly suicidal attempts

 

      which is a concern for us, for the patients, for

 

      the parents and for the physicians.  Thankfully, no

 

      child committed suicide in any of these studies.

 

      It is important that we learned about these effects

 

      and now we need to make use of this information

 

      that is the subject of this meeting.  I want to

 

      take just a few minutes to describe Wyeth's point

 

      of view.  The first is that we should make use of

 

      this information that was gleaned from these

 

      studies and provide this information to physicians.

 

      In our pediatric clinical studies there were

 

      increased reports of hostility and suicide-related

 

                                                               249

 

      events, such as ideation and self-harm.  We, at

 

      Wyeth, updated our label and we provided our

 

      pediatric safety information to over 450,000

 

      healthcare professionals in 2003 in a "dear

 

      healthcare provider" letter.

 

                Studies with other antidepressants,

 

      carried out by other pharmaceutical companies in

 

      pediatric patients, have shown similar adverse

 

      events.  As an industry, we should continue to

 

      provide safety information broadly and in a

 

      consistent way to physicians, and the information

 

      should be similar for all antidepressants.

 

                Second, although the FDA's and the

 

      Columbia University's cross-study analyses were

 

      done carefully, one cannot conclude that a

 

      difference among the drugs has been demonstrated.

 

      This is largely due to limitations inherent in the

 

      various study designs, and I think you heard a lot

 

      about these caveats from Dr. Hammad already.  The

 

      reviews, by necessity, included post hoc analyses

 

      with multiple outcomes and no statistical

 

      corrections.  They are complicated by the lack of

 

                                                               250

 

      statistical significance for many of the

 

      subanalyses.  This increases our level of

 

      uncertainty.  So, we have to exercise caution if we

 

      try to draw definitive conclusions about the true

 

      relative risk of these events.

 

                Also, these trials were designed for

 

      efficacy and were not sufficiently large to detect

 

      differences in the less frequently reported events.

 

      Moreover, the studies did not include a direct

 

      comparison of one antidepressant with another.

 

      There was insufficient commonality among the

 

      studies to make valid comparisons.  For example,

 

      the studies we venlafaxine did not exclude patients

 

      with treatment resistance, history of suicide

 

      attempt or homicidal risk, but some of the trials

 

      with other medications did exclude these patients.

 

      Therefore, while we recognize that there were

 

      larger risk ratios reported for venlafaxine than

 

      for some other products, we do not, on the basis of

 

      these observations, believe it is appropriate to

 

      advise that a physician could apply special

 

      precautions for one antidepressant and not the same

 

                                                               251

 

      special precautions for another.

 

                Third, it would, in our opinion, represent

 

      good medical judgment to allow physicians to use

 

      these products in pediatric patients if they

 

      believe the products to be necessary, and if they

 

      determine that other ways of treating depression

 

      are unsuccessful.  Companies should provide

 

      warnings.  Prescribers should be fully aware of the

 

      risks and fully capable of identifying and managing

 

      suicidal thoughts, hostile behavior and suicide

 

      attempts.  The parents should be well informed of

 

      these risks as well in order to recognize the

 

      emergence of these symptoms.

 

                Let me summarize our point of view.

 

      First, we should continue to provide information to

 

      physicians about what we have learned in our

 

      studies about suicidal thoughts, suicide attempts,

 

      and we need to emphasize the need to be vigilant.

 

                Second, the information we provide should

 

      be consistent for all of the antidepressants since

 

      the data do not allow us to distinguish among them

 

      for the appearance of this particular risk.

 

                                                               252

 

                Third, we should keep these products

 

      available to physicians to use when needed,

 

      according to their expert judgment, because

 

      depression in children is a complex, serious

 

      problem and it may be extremely difficult to treat.

 

                I want to thank you for giving Wyeth the

 

      opportunity to present our position.

 

                DR. GOODMAN:  Thank you very much.  Any

 

      questions?  Yes?

 

                MS. GRIFFITH:  I appreciate the time you

 

      took, and I don't mean to pose a hostile question

 

      to you but as a parent, looking at the data that

 

      Dr. Hammad gave us, it is so dramatically

 

      different, the presentation for effects and the

 

      overall risks of suicidal behavior and ideation.  I

 

      mean, it wasn't just a couple of points difference,

 

      you know, 8.84 as opposed to 1.37 for Celexa; 2.15

 

      for Paxil.  I am not a clinician but that would

 

      alarm me as a parent and I don't quite understand

 

      how you excuse a result that is so dramatic.

 

                DR. CAMARDO:  I purposely acknowledged the

 

      risk, and your question is not at all hostile,

 

                                                               253

 

      first of all, and we in fact believe that

 

      notification of the risk is critically important to

 

      any physician who is trying to use the product.  I

 

      don't want what I said to be misinterpreted as not

 

      being forthcoming about the risk and the

 

      differential risk observed.  I just am recommending

 

      that we be cautious about treating one drug as so

 

      dramatically different from another that you could

 

      apply a warning or precaution in one case and not

 

      in another case when we have seen that one trial

 

      can be different another; one condition, such as

 

      anxiety, could be different from depression; and

 

      sometimes the differences in the way the studies

 

      were done may lead to differences in the outcomes.

 

      So, I think we just need to be careful about

 

      believing that we have distinguished between the

 

      drugs on the basis of magnitudes of effect that

 

      might be suspicious when you look at them

 

      carefully.

 

                DR. GOODMAN:  Dr. Fant?

 

                DR. FANT:  Could you just reiterate the

 

      comment you made about differences in exclusion

 

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      criteria in your studies and some of the other

 

      studies with the other drugs?  If I am remembering

 

      your comment correctly, and validate this for me, I

 

      think you said you included kids who potentially

 

      had more problems that were excluded in other

 

      studies.

 

                DR. CAMARDO:  I am actually basing what I

 

      say only on the basis of what I know about our own

 

      studies.  In fact, Dr. Hammad outlined in his

 

      review some differences between different studies,

 

      and that information is only available to me from

 

      that review.  But having said that, we did include,

 

      for example, children who had not responded to

 

      other antidepressants.  I don't know if that is

 

      true in the other studies or not.  We have included

 

      in the venlafaxine studies children who actually

 

      may have had a previous suicide attempt.  Our only

 

      exclusion criteria were if the child was considered

 

      to be a high risk of suicide.  So, I only know a

 

      little bit about those.

 

                DR. FANT:  Now, if you went back and

 

      excluded those kids in your group and reanalyzed

 

                                                               255

 

      the data using different exclusion criteria, how

 

      would the risk look?

 

                DR. CAMARDO:  I don't know the answer to

 

      that question.  It is a very good question but I

 

      can't answer it.

 

                DR. GOODMAN:  Any other questions?  If

 

      not, we are going to take a very brief break but I

 

      am asking people not to leave the room.  You can

 

      just stretch as we prepare for the open public

 

      hearing.  I am going to hand the microphone over to

 

      Anuja Patel.

 

                MS. PATEL:  I would like at this time for

 

      all registered open public hearing speakers to make

 

      sure they are sitting in the reserved open public

 

      hearing section on the left-hand side of the

 

      audience, which is the committee's left-hand side,

 

      just to help us be more efficient in recognizing

 

      the registered speakers.  Thank you.

 

                [Brief recess]

 

                          Open Public Hearing

 

                DR. GOODMAN:  We are about to begin.  I

 

      would like everybody to find their seats.  For the

 

                                                               256

 

      next four hours we will be holding the open public

 

      presentation portion of the meeting.  Let me begin

 

      by making a statement.   Both the Food and Drug

 

      Administration and the public believe in a

 

      transparent process for information gathering and

 

      decision-making.  To ensure such transparency at

 

      the open public hearing session of the advisory

 

      committee meeting, FDA believes that it is

 

      important to understand the context of an

 

      individual's presentation.  For this reason, FDA

 

      encourages you, the open public hearing speaker, at

 

      the beginning of your written or oral statement, to

 

      advise the committee of any financial relationship

 

      that you may have with any company or any group

 

      that is likely to be impacted by the topic of this

 

      meeting.  For example, the financial information

 

      may include a company's or a group's payment of

 

      your travel, lodging, or other expenses in

 

      connection with your attendance at the meeting.

 

      Likewise, FDA encourages you at the beginning of

 

      your statement to advise the committee if you do

 

      not have such financial relationships.  If you

 

                                                               257

 

      choose not to address this issue of financial

 

      relationships at the beginning of your statement,

 

      it will not preclude you from speaking.

 

                We have approximately 70 speakers in the

 

      next four hours who will each be allocated, for the

 

      most part, three minutes a piece.  To describe the

 

      process more clearly to you, let me turn the

 

      microphone to Igor Cerney, who is the Director of

 

      the Center for Drug Evaluation and Research

 

      Advisors and Consultant Staff.

 

                DR. CERNEY:  As Dr. Goodman has said,

 

      everyone will have three minutes, except for one

 

      group that has a consolidated presentation which

 

      will be allowed five minutes.  When you have 30

 

      seconds left the green light which has been on your

 

      timer will turn yellow and that is your wrap-up

 

      time of 30 seconds.  Then, when you are out of time

 

      the light will turn red.  It will flash, it will

 

      beep, and will cut the sound off automatically at

 

      that point.  So, that is just letting you know what

 

      the ground rules are for the open public hearing.

 

      Thank you.

 

                                                               258

 

                DR. GOODMAN:  At first blush, it may seem

 

      insensitive to cut off the sound but we have to

 

      achieve the right balance between giving an

 

      individual an opportunity to express his or her

 

      opinion but also ensure that there is sufficient

 

      time for everyone here who wants to speak.  We are

 

      not going to be making exceptions in the timing.

 

      It is going to be a relatively automatic process so

 

      please gauge your presentation to ensure that you

 

      have reached the high points before the mike is

 

      turned off.

 

                I also apologize in advance for addressing

 

      each of you by a number.  The data I have here, at

 

      least the most valid data, just gives me a number

 

      of each speaker presentation and then I ask you,

 

      when you get to the podium, to introduce yourself.

 

      No surprises here, we are going to be starting with

 

      speaker number one.  I would appreciate it if you

 

      would stand up to the microphone.

 

                DR. DUCKWORTH:  Good afternoon.  My name

 

      is Ken Duckworth and I am a Board certified child

 

      and adolescent psychiatrist.  I work part-time as

 

                                                               259

 

      the medical advisor to the National Alliance for

 

      the Mentally Ill, also known as NAMI.  NAMI has

 

      220,000 people who have serious mental illness or

 

      have people in their families who have serious

 

      mental illness.  Because I work for NAMI, they have

 

      paid for my trip here but I do no work for the

 

      industry of any kind and I get my income from

 

      clinical practice and taking care of patients.

 

                NAMI would like to start by saying we

 

      believe there is sufficient reason to demand better

 

      research, which I think is evident from your

 

      conversations today.  It is very clear that the

 

      studies don't answer all the questions that

 

      parents, doctors and teenagers need. We feel that

 

      longitudinal research is one of the things that is

 

      missing from this conversation.  We know that it is

 

      hard to do and expensive but we feel that it is an

 

      incredibly aspect of this work.

 

                The TADS study is a very important and

 

      good start, but it is only a start.  We still don't

 

      know so many aspects of the risk/benefit assessment

 

      that parents and doctors need to make when they

 

                                                               260

 

      make decisions about whether to start a compound, a

 

      medication or psychotherapy on an adolescent who

 

      walks into the office with suicidality.  In that

 

      TADS study 20 percent of the patients were

 

      presenting with suicidality before they entered the

 

      study.  To me, this is emblematic of the problem of

 

      suicidality that is endemic to the condition of

 

      adolescent depression.

 

                I just want to also say that the

 

      President's Freedom Commission has told us that the

 

      mental health system is a shambles.  That is

 

      important because if you think cognitive behavior

 

      therapy and thoughtfully applied medications, with

 

      good monitoring, is going to happen on a routine

 

      basis, there is not much evidence to suggest that

 

      the system is set up for that, and that is

 

      something that NAMI wants to acknowledge, that you

 

      know that the work force issues around getting good

 

      care for people is a major problem that relates to

 

      this.

 

                Monitoring--monitoring is a very important

 

      piece of this whole conversation and I would like

 

                                                               261

 

      you to reflect on your success with monitoring

 

      clozapine for people with treatment-resistant

 

      psychoses.  People with treatment-resistant

 

      psychoses have a 10 percent chance of killing

 

      themselves.  This is people with schizophrenia.

 

      Your system for monitoring clozapine enables me to

 

      give people a medicine which is risky, may save

 

      their life and may cause the rare chance of a

 

      catastrophe.  Your system for monitoring for this

 

      rare thing enables me to prescribe this, give good

 

      informed consent, and the patients and the families

 

      make good decisions.

 

                We also need to remember that as you are

 

      constructing whatever risk/benefit information you

 

      are giving to people everybody should know what

 

      akathisia is.  Every person should know if their

 

      kid has a family history of bipolar illness and,

 

      finally, every person should know, and you should

 

      communicate to them, that untreated depression also

 

      kills people.  Thank you.

 

                DR. GOODMAN:  Thank you very much, and I

 

      welcome our next speaker, number two.

 

                                                               262

 

                MS. TOTTEN:  Hello.  My name is Julie

 

      Totten, and I am the president and founder of

 

      Families for Depression Awareness.  Regarding

 

      financial disclosure, there is no industry money;

 

      we just took it out of our operating dollars for

 

      coming here today.

 

                Families for Depression Awareness--I would

 

      like to speak on behalf of our members who are

 

      families coping with depressive disorders, our

 

      board of directors and our advisory board.  Many of

 

      us have lost a family member to suicide and I lost

 

      my brother to suicide 14 years ago.  He was

 

      undiagnosed but afterwards, when I learned about

 

      depression, it was very apparent that he suffered

 

      from this condition.

 

                I would like to make three points.  One is

 

      that family care-givers are the ones who need to be

 

      active in monitoring treatment.  Number two,

 

      monitoring is the key issue and, number three, more

 

      monitoring advice is needed, first, regarding

 

      family care-givers.  Families for Depression

 

      Awareness is very pleased and enthusiastic that you

 

                                                               263

 

      have put out a warning that families, patients and

 

      clinicians all need to monitor depression treatment

 

      and we are so glad that you have included family

 

      care-givers, people like me who are in a position

 

      to help when patients are not capable and doctors

 

      are too busy, which is most of the time.  Please

 

      make sure to include family care-givers.  They are

 

      the ones who can make a difference.

 

                Six months after my brother took his life

 

      I helped my father get diagnosed and treated for

 

      major depression.  I am a family care-giver and I

 

      am proof that family care-givers can make a

 

      difference if we are given a chance.

 

                The second issue is that monitoring needs

 

      to be the main issue here.  People with depression

 

      need medical treatment and every person's reaction

 

      to medication is different and has to be handled on

 

      a case-by-case basis, as we all know.  So,

 

      monitoring is what we need to focus on to prevent

 

      suicides right now.  But the problem is that

 

      families and patients do not know how to monitor

 

      treatment.  So, families need more explicit

 

                                                               264

 

      monitoring advice.  They don't even know how often

 

      to make a doctor's appointment.

 

                Families for Depression Awareness is

 

      developing a depression treatment monitoring tool

 

      for medication, psychotherapy or both to help

 

      families and patients track their symptoms, side

 

      effects and treatment, and we would welcome

 

      collaboration.  We can only do so much and we need

 

      your help.  Please focus on family care-givers make

 

      monitoring an issue right now, immediately, and

 

      help us develop more specific monitoring advice.

 

      Thank you.

 

                DR. GOODMAN:  Thank you very much.  I

 

      would like to invite our next speaker, number

 

      three.

 

                MR. WILKINS:  Hello.  I am Ronnie Wilkins,

 

      with the ACNP.  Depression in youth, as you have

 

      talked about today, is a serious disorder.  It

 

      affects every aspect of a child's life and

 

      increases the risk of more drug, alcohol use, adult

 

      depression and suicide.  Allowing to go untreated

 

      delays improvement and it increases the likelihood

 

                                                               265

 

      of long-term negative outcomes.

 

                Controlled trials have shown that

 

      fluoxetine is effective in the treatment of

 

      depression, and the recent data from the

 

      NIMH-funded TADS trial provides further support and

 

      justification for the use of this medication,  In

 

      addition, the TADS trial compared fluoxetine to

 

      cognitive behavior therapy and found some evidence

 

      that both CBT and placebo were inferior to

 

      treatment with fluoxetine alone.

 

                The ACNP strongly supports more research

 

      comparing psychological and medication treatment

 

      for depression in children and adolescents, more

 

      methodologically sound research with other SSRIs,

 

      more studies of non-SSRI agents such as tricyclic

 

      antidepressants, and studies testing strategies to

 

      treat depressed children and adolescents who have

 

      failed treatment on an SSRI.

 

                Depression as a significant risk factor

 

      for suicide is something to be concerned about as

 

      well.  Treatment of depression is likely to

 

      decrease overall suicide rates.  Epidemiological

 

                                                               266

 

      data tends to support this view.

 

                In over 4000 children and adolescents

 

      treated in controlled trials with antidepressants

 

      there have been no suicides, however, there are

 

      indications that there may be an increase in

 

      suicidal ideation and suicidal behavior.  Recent

 

      data from the U.K. in adults are consistent with an

 

      increase in suicidal ideation during the initial

 

      phases of antidepressant treatment with all

 

      medication treatments.  These uncontrolled

 

      observations need additional rigorous study in

 

      depressed children and adolescents before we will

 

      have a final understanding of these issues.

 

                The ACNP supports the FDA recommendation

 

      that clinicians carefully monitor all patients

 

      treated with antidepressants for worsening of

 

      symptoms and emergence of suicidality, as well as

 

      for agitation and mania.  This has always been good

 

      clinical practice and adding that information to

 

      antidepressant labeling is highly justified.

 

                The TADS study also shows that overall the

 

      impact of treatment on depression significantly

 

                                                               267

 

      decreased suicidal ideation.  It is important to

 

      put into perspective that while some adolescents

 

      may demonstrate a worsening of suicidal ideation,

 

      up to 40-60 percent will demonstrate an improvement

 

      in suicidal ideation, and similar proportions will

 

      demonstrate a meaningful reduction in other

 

      symptoms of depression.

 

                It is only through further

 

      methodologically sound research that we will

 

      increase our understanding of age-specific issues

 

      of safety and effectiveness of both medications and

 

      psychotherapy in the pediatric population.

 

      Limiting clinician choices because of lack of

 

      available information would not be in the best

 

      interest of patients and it would be unfortunate if

 

      these controversies resulted in stifling of

 

      research just when more research is needed.

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker number five, you have five minutes.

 

                MS. TRACY:  I am Ann Blake Tracy, head of

 

      the International Coalition for Drug Awareness.  I

 

      am the author of "Prozac: Panacea or Pandora."  My

 

                                                               268

 

      house is mortgaged to the hilt to pay for the last

 

      15 years that I have devoted to nothing but

 

      research on SSRI antidepressants and to fund my

 

      trip here.

 

                I testified for twelve and a half years in

 

      court cases involving these drugs.  Research on

 

      serotonin has been clear from the very beginning,

 

      that the most damaging thing that could be done to

 

      the serotonergic system would be to impair one's

 

      ability to metabolize serotonin, yet that is

 

      exactly how SSRI antidepressants exert their

 

      effects.  For decades research has shown that

 

      impairing serotonin metabolism will produce

 

      nightmares, hot flushes, migraines, pains around

 

      the heart, difficulty breathing, worsening of

 

      bronchial complaints, tension and anxiety which

 

      appear from out of nowhere, depression, suicide,

 

      especially very violent suicide and repeated

 

      attempts, hostility, violent crime, arson,

 

      substance abuse including cravings for alcohol and

 

      other drugs, psychosis, mania, organic brain

 

      disease, autism, anorexia, reckless driving,

 

                                                               269

 

      Alzheimer's, impulsive behavior with no concern for

 

      punishment, and argumentative behavior.

 

                How anyone ever thought it would be

 

      therapeutic to chemically induce these reactions is

 

      beyond me, yet these reactions are exactly what we

 

      witnessed in our society over the past decade and a

 

      half as a result of the widespread use of these

 

      drugs.

 

                Can you remember two decades ago when

 

      depressed people used to slip away quietly to kill

 

      themselves rather than killing everyone around them

 

      and then themselves, as they do while taking an

 

      SSRI antidepressant?

 

                A study out of the University of Southern

 

      California, in 1996, looked at a group of mutant

 

      mice that had been genetically engineered.  In an

 

      experiment that had gone terribly wrong, they were

 

      the most violent creatures they had ever witnessed.

 

      They were born lacking the MAOA enzyme which

 

      metabolizes serotonin.  The end result is the same

 

      as if they were taking an SSRI antidepressant which

 

      does inhibit the metabolism of serotonin.

 

                                                               270

 

                This has been a national holocaust.  It

 

      must end.  These are extremely dangerous drugs that

 

      should have been banned as similar drugs were in

 

      the past.  As a society, we once thought LSD and

 

      PCP to be miracle medications.  We have never seen

 

      drugs so similar to LSD and PCP as these SSRI

 

      antidepressants are.  All of these drugs produce

 

      dreaming during periods of wakefulness.  The higher

 

      serotonin levels overstimulate the brain stem

 

      leading to a lack of muscle paralysis.  That was

 

      seen clearly in the case of comedian Phil Hartman

 

      and his wife in the terrible murder-suicide.  Thank

 

      you.

 

                MS. GOLF:  Thank you for allowing me to

 

      speak here today.  My name is Marion Golf.  I am

 

      here today with my other daughter.  It was her twin

 

      sister who was put on SSRIs.

 

                I would like to ask all of you a few

 

      questions.  Why is it easier to have

 

      antidepressants prescribed to our children than to

 

      have antibiotics prescribed for them?  Why are

 

      antidepressants handed out so easily to our

 

                                                               271

 

      children?

 

                During the fall of 2002 my nine year-old

 

      twin daughter was diagnosed with an eating disorder

 

      by a doctor who never did a sufficient medical or

 

      psychological workup.  Up to that point she had

 

      been a happy and beautiful child, a sweet child.

 

      We told him that this was unlike her, that it had

 

      come on suddenly and severely.  Instead, within a

 

      week of seeing this eating disorder specialist, she

 

      was given Zoloft up to 75 mg, which was then

 

      switched to Paxil.  At one point she was given 30

 

      mg of Paxil and up to 10 mg of Zyprexa at the same

 

      time.  These drugs did not help her.  They made her

 

      suicidal and abusive to herself and to our family.

 

      We almost lost our child twice.

 

                My daughter was finally diagnosed with

 

      chronic Lyme's disease, in January of this year.

 

      Because of the delay in treatment she has been on

 

      intravenous antibiotics and continues in this way,

 

      but she has made incredible progress while on these

 

      antibiotics.

 

                The antidepressants that were given to my

 

                                                               272

 

      daughter are dangerous.  Would any of you prescribe

 

      these medications for you own children?  Why are we

 

      turning to drugs before we truly understand the

 

      problem?  My daughter could still be on these

 

      mind-altering drugs if my husband and I were not so

 

      persistent in getting to the truth.

 

                When a child presents with a

 

      multi-systemic problem why isn't Lyme's disease

 

      ruled out first?  Lyme's disease is the fastest

 

      growing infectious disease in this country...

 

                DR. GOODMAN:  Thank you for your

 

      testimony.

 

                [Applause]

 

                Speaker number five?

 

                MR. CHONILEWSKY:  My name is Andrew

 

      Chonilewsky.  I am not affiliated with--

 

                DR. GOODMAN:  Could you bring the

 

      microphone closer to you?

 

                MR. CHONILEWSKY:  Surely.  My name is

 

      Andrew Chonilewsky.  I am not affiliated with any

 

      organization at all, just totally on my own.  If

 

      you notice from slide one, this is the name of my

 

                                                               273

 

      ex-wife.  She is a VA psychiatrist currently

 

      practicing.  She is homicidal, suicidal.  She is a

 

      psychiatric drug user, mother, child abuser and dog

 

      killer.  This is what she is.  I can document

 

      everything.  It is certainly in the court records.

 

      Nevertheless, she is still practicing.  That is her

 

      workplace, where she is.  I am not afraid of

 

      exposure.

 

                I would request slide two.  I received

 

      this, an affidavit in support of preliminary child

 

      protection order from the State of Maine regarding

 

      my son.  This is an affidavit made before Gail

 

      D'Agostino, State of Maine, Department of Human

 

      Services, being duly sworn.

 

                Next slide, please.  This is rather

 

      interesting.  It comes down to, for all the talk

 

      and all the minutia given psychiatric drug trials,

 

      regression analysis--I am rather reminded in a

 

      far-off time, in a far-off land of the dialectics

 

      of Marxism and class struggle.  It is meaningless.

 

      However, you have one of your colleagues here, a

 

      trained, Board certified psychiatrist with added

 

                                                               274

 

      qualifications in geriatric psychiatry, and I am

 

      inclined to believe this time what Dr. Runden wrote

 

      about herself in revealing her set of depressions,

 

      suicidal feelings regarding my child and herself

 

      for she planned to kill my child first, then

 

      herself, but there was a snowstorm that she did not

 

      expect so she did not.  That is her reasoning.

 

                Her comments are very interesting.  She

 

      has forged my signature, forged documents, perjured

 

      herself, stolen, lied.  She is a whore.

 

      Nevertheless, I am inclined to believe what she

 

      writes in terms of her status, mental status.  I am

 

      inclined to give her credibility for the so-called

 

      mentally ill, besides being self-indulgent and

 

      being control freaks...

 

                DR. GOODMAN:  Thank you.  Number six,

 

      please.

 

                MS. FURLOUGH:  Hello.  My name is Susan

 

      Furlough.  I am not affiliated with anyone.  This

 

      is my son's letter to you.  Good afternoon--

 

                DR. GOODMAN:  You need to bring the

 

      microphone closer.

 

                                                               275

 

                MS. FURLOUGH:  Is that better?  This is a

 

      letter from my son.  He says, good afternoon to

 

      everyone.  My name is Ryan Furlough.  Please excuse

 

      me for not being there in person for, at present, I

 

      am currently incarcerated.  I was only 16 when I

 

      started taking the antidepressant Effexor XR.  I

 

      started out with a small dose of 75 mg and over a

 

      short period of time was up to 300 while I was only

 

      17.  While I was on the drug my depression got

 

      worse, completely affecting all aspects of my life.

 

      Negative thoughts filled my mind night and day.  I

 

      wasn't living at all; I was just existing.  I felt

 

      like I was on the outside looking in on life.  I

 

      believe that everyone hated me and nothing seemed

 

      to be right for me.  I gave up on life and it

 

      seemed like everyone else had no purpose.

 

                Unfortunately, solving this problem meant

 

      the death of the best friend I ever had.  I felt

 

      uncontrolled hate towards him because, beyond my

 

      comprehension to where I acted like I was an

 

      emotionless puppet, having someone else pulling my

 

      strings to what my fate would be.  Now the worst

 

                                                               276

 

      thing has happened and I can't fix it now.  I am

 

      off Effexor XR and I can't understand what I was

 

      then.  This medication changed me, who I was then

 

      and who I am now.  There is no other Ryan there.

 

      There is a new Ryan, the Ryan that used to be there

 

      before medicines.  I know who I am now, just like I

 

      did before.

 

                As I said to you, it is too late now.  His

 

      family and friends are forever traumatized and my

 

      own family feels the same way, except they are

 

      relieved that I am emerging from a dark cloud of

 

      Effexor.  I ask you to please take action and stop

 

      these drugs now.  Too many times have I read about

 

      people like me having problems with Effexor and

 

      other antidepressants.  Too many times have I put

 

      the shoes on of the other cases similar to mine,

 

      knowing how much pain and suffering they are going

 

      through.  Too many times have I had to see people

 

      die because nobody will take action.

 

                It is sickening to know that cases such as

 

      mine will continue to show up, and unless you do

 

      something now more men, women and children will

 

                                                               277

 

      die.  Please don't let this continue to happen.

 

      Other countries have started to pay attention and

 

      step up, shouldn't we do the same for our children?

 

      Thank you, Ryan Furlough.

 

                As you have heard from my son, many people

 

      are suffering from these drug adverse reactions.

 

      These drugs change kind, gentle children into

 

      monsters.  Please listen now before it happens to

 

      your family.  You have the proof in front of you

 

      from all the families that are in this room today.

 

      Even if the drugs can help some people, it is not

 

      acceptable to lose one more life.  Doctors are

 

      busy.  I am a registered nurse, I know that.  They

 

      don't read everything they get.  These drugs need

 

      to be taken off the market to protect our precious

 

      children, and also to protect the young adults that

 

      are also having reactions, but nobody is listening.

 

                My son says to you stop the drugs now as

 

      every day is a potential for another death.  My

 

      life is forever changed...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much. 

 

                                                               278

 

      Speaker number seven, please step forward.

 

                MS. VAN SYCKEL:  Good afternoon.  My name

 

      is Lisa Van Syckel.  The FDA and the pharmaceutical

 

      industries have repeatedly stated that it is the

 

      disease, not the drug, that causes our children to

 

      become violent and suicidal.  It wasn't the disease

 

      that caused my daughter to viciously mutilate

 

      herself; it was the drug.  It wasn't the disease

 

      that caused my daughter to become violent and

 

      suicidal and out of control.  It wasn't the disease

 

      that caused her to scream the words "I want to

 

      die."

 

                And, it sure as hell was not the disease

 

      that caused Christopher Pittman to kill the two

 

      people he loved the most, his grandparents.  He had

 

      been on Zoloft just three weeks and he was 12 years

 

      old.  Christopher is now facing life in prison as

 

      an adult.

 

                I am asking everyone in this room to help

 

      me to help Joe Pittman to save Christopher

 

      Pittman's life.  It is a life worth saving.

 

      Christopher is an honor roll student, doing well in

 

                                                               279

 

      psychotherapy since he has been off the medication.

 

      Does he deserve life in prison because you, as

 

      adults, cannot accept responsibility to tell the

 

      truth, to come forward?  I think it is time, ladies

 

      and gentlemen, that you become adults and you come

 

      forward and you help this young boy.

 

                Pfizer refers to me and others as a

 

      detractor of SSRIs and that I am misinforming

 

      legislators with oversight responsibilities.  As an

 

      adult, I am considered fair game for verbal attacks

 

      but, ladies and gentlemen, Pfizer crossed the line

 

      the day they attacked a dead child.  They viciously

 

      attacked a dead child and you all know it.  And

 

      you, ladies and gentlemen, as adults, need to tell

 

      Pfizer that they need to stop.

 

                I would like to end by saying thank you to

 

      Congressman Mike Ferguson of New Jersey who has

 

      oversight responsibilities, who has spent countless

 

      hours with me and other family members in showing

 

      compassion.  I thank him for his assistance in

 

      allowing me, and supporting me in my pursuit for

 

      congressional hearings because we need criminal

 

                                                               280

 

      charges to be filed against many.

 

                I would like to end the rest of my time in

 

      a moment of silence for all of those children and

 

      adults who have lost their lives to

 

      antidepressant-induced violence, homicide and

 

      suicide.  Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker number

 

      eight, please.

 

                MR. LAGURRE:  Good afternoon, ladies and

 

      gentlemen.  My name is Raul Lagurre.  I am here on

 

      behalf of my son, whose name I cannot mention, and

 

      all the other victims that shall remain nameless.

 

      The American government was formed to protect and

 

      serve and help the people, yet it has failed us.

 

      The FDA was formed to protect consumers in showing

 

      that the drugs we consume are, indeed, safe but

 

      they still allow companies to distribute dangerous

 

      antidepressant drugs on the market even though

 

      there are severe side effects to children and

 

      adolescents.

 

                My son was under the influence of an

 

                                                               281

 

      antidepressant drug and now he faces a long prison

 

      term and an innocent person was hurt.  Before he

 

      took these drugs he was a gentle, lovable kid who

 

      never hurt himself or any other person.  Because of

 

      this failure of a major drug company in releasing

 

      information on suicide effects of antidepressant

 

      drugs, I may lose my son to the system.  He is one

 

      of a thousand of victims who suffered severe side

 

      effects, and continues to do so, yet this company

 

      continues to supply the market with them.

 

                The FDA needs to step up, protect the

 

      consumer and crack down on these drug companies

 

      before more lives are lost.  Thank you very much.

 

                [Applause]

 

                DR. GOODMAN:  Speaker number nine?

 

                MS. PULP:  Distinguished committee

 

      members, my name is Gloria Pulp and I am here on

 

      behalf of DBSA, the Depression of Bipolar Support

 

      Alliance.  We are a national patient-driven

 

      advocacy organization, with more than 1000 support

 

      groups throughout the country that assist the more

 

      than 25 million Americans living with a mood

 

                                                               282

 

      disorder.

 

                Untreated depression is the number one

 

      risk for suicide among youth.  With suicide as a

 

      third leading cause of death among 15-24 year-olds

 

      and the fourth leading cause in 10-14 year-olds,

 

      medication treatment options for youth are

 

      absolutely critical.  As an organization, DBSA has

 

      been actively involved with the youth population.

 

                On the screen before you is the cover of

 

      the "Storm in my Brain," a publication compiled by

 

      DBSA and the Child and Adolescent Bipolar

 

      Foundation.  As you can see, this art work, created

 

      by young people with mood disorders, graphically

 

      displays the feelings they associate with their

 

      illness.  These illnesses, if left untreated, can

 

      lead to tragic consequences.

 

                DBSA does not believe there should be

 

      limits to therapeutic options open to doctors and

 

      families.  But we do believe that whatever

 

      treatment is selected, whether it is medication,

 

      psychotherapy or support groups, parents and

 

      physicians need to be diligent in monitoring

 

                                                               283

 

      symptoms to avoid self-harm of all types.

 

      Therefore, we support strict monitoring of existing

 

      and emerging treatment options.

 

                DBSA appreciates and supports the very

 

      hard work of these two advisory committees in

 

      examining whether certain medications increase the

 

      risk of suicidality in adolescents.  Like NAMI,

 

      DBSA believes even further research is needed and

 

      that the results of clinical trials should be made

 

      available to the public.

 

                We urge the National Institute of Mental

 

      Health to increase research on the proper

 

      treatments for children.  Depression and bipolar

 

      disorder are real treatable medical illnesses that

 

      affect both children and adolescents.  While we

 

      recognize that there may be consequences or

 

      occurrences where, without adequate monitoring,

 

      certain patients have responded negatively to

 

      certain medications, in many others they have.

 

                Take, for example, a woman named Tara who

 

      contacted the DBSA to say that after trying a

 

      number of medications her 12 year-old son had found

 

                                                               284

 

      a treatment that appeared to be working.  My child

 

      never actually laughed until he was 12 years old,

 

      she said.  Imagine what a joy when he finally did.

 

                As FDA looks to potentially regulate

 

      certain medications, DBSA urges these advisory

 

      committees to look closely at the successes as well

 

      as the shortcomings in existing treatment options

 

      and act accordingly.  We can help children quell

 

      the storms in their brains.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker number ten?

 

                MR. VICKERY:  Good afternoon.  My name is

 

      Andy Vickery.  I am a trial lawyer from Houston,

 

      Texas, and for the bulk of the last nine years I

 

      have represented the families of victims of

 

      SSRI-induced violence.

 

                I have three separate and different things

 

      to share with you if my time permits.  First, when

 

      I was here in February the written materials and

 

      the presentation I made expressed a concern that

 

      when you search the databases you are looking for

 

                                                               285

 

      the needle in a haystack--Eli Lilly's words, not

 

      mine--needle in a haystack because the clinical

 

      trials were not designed to capture suicidality.

 

      They use rating scales that have only one item on

 

      the rating scale even though there are others that

 

      are more refined and difficult to find because we

 

      know that there is a redistribution of risk.

 

                Tischer and Cole wrote about this in '93.

 

      Dr. Gordon Parker, from Down Under, wrote to Lilly

 

      about it in 1990.  It may help some over here and

 

      harm some over here.  So, if you are looking for a

 

      signal, you are looking for a needle in a haystack.

 

      Miraculously, in spite of that, you have found the

 

      needle but I still am concerned that you are

 

      looking the wrong way.

 

                Lilly knew in 1990, when they met with the

 

      FDA, the best way to answer this question in a

 

      scientifically proper way was through a rechallenge

 

      protocol, not through RCTs and not through epi.

 

      studies.  They pledged to the FDA that they would

 

      conduct such a study.  They never did it.  You

 

      never made them.

 

                                                               286

 

                The second item I would like to bring to

 

      your attention is that in the interim, since this

 

      committee met last, the FDA has blessed a new drug

 

      on the market, duloxatine released just a couple of

 

      months ago.  It is an SNRI.  There are completed

 

      suicides in the clinical trials, including one of a

 

      healthy volunteers, on February 7th of this year.

 

      It was, nonetheless, approved.  If you are going to

 

      differentiate in the warnings, ladies and

 

      gentlemen, that one needs a black box on it.

 

                Finally, I wish you could hear from some

 

      of the victims themselves.  I only have 55 seconds.

 

      I would tell you if I could--my name is Christopher

 

      Joseph Gangwich.  Two weeks from today would be the

 

      fourth anniversary of my death.  I got the Paxil

 

      because my girlfriend wasn't being nice to me.  I

 

      went to my mom.  They put me in the hospital.  The

 

      doctors increased the Paxil.  A week later I was in

 

      the hospital again--more Paxil.  Four days later I

 

      hanged myself in the closet.  Before I did, I

 

      carved a message, a message for you, the

 

      words--"dying; help," in my own groin--in my own

 

                                                               287

 

      groin.  Ladies and gentlemen, kids are still dying.

 

      Will you help them?

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.  Is

 

      speaker number 11 here?

 

                MS. SHARAV:  My name is Vera Sharav, and I

 

      am the president of the Alliance for Human Research

 

      Protection.  In contrast to today's presentations,

 

      every independent analysis of the data, including

 

      FDA's own, has corroborated King's 1991 report

 

      describing the development of intense

 

      self-injurious ideation and behavior in six

 

      children who received fluoxetine.

 

                The Mosholder report, which was embargoed

 

      for six months and didn't see the light of day

 

      until we put it up on our website, confirmed that

 

      children exposed to an antidepressant are twice as

 

      likely to suffer suicidal-related adverse events

 

      compared to those given a placebo.  Dr. Mosholder

 

      identified 78 cases and recommended discouraging

 

      off-label pediatric use of SSRIs.  Columbia's

 

      reclassification identified 17 additional cases.

 

                                                               288

 

                The FDA and drug companies have known the

 

      risks and concealed them for over a decade, and the

 

      blinders are still on.  Physicians and parents

 

      continue to be deceived with false assurances that

 

      the drugs are safe and effective.  FDA's excuses

 

      for its inaction insult our intelligence.  Dr.

 

      Temple maintains that both the data and Mosholder's

 

      interpretation were imperfect, and behaviors

 

      labeled suicidal could have been accidents.

 

                When a fire erupts, the fire department

 

      doesn't wait until it has absolute proof of

 

      causality before it acts.  The committee's charge

 

      is not to answer why or how the drugs increase

 

      suicide risk.  Given that the drugs' failure in

 

      controlled clinical trials to show an effectiveness

 

      for children, and given the link between drug

 

      exposure and increased risk of suicidal behavior

 

      has been scientifically established, the

 

      committee's charge ought to be how to best protect

 

      children.

 

                In addition to suicide risk, SSRIs are

 

      linked in children to stunted growth, cardiac

 

                                                               289

 

      abnormalities, mania and a tremendous rise in manic

 

      depression.  How many children need to be harmed

 

      before action is taken?  Children's safety in these

 

      trials is a concern as well.  FDA's review

 

      identified Prozac study HCJE as, quote, one of four

 

      trials with the largest number of definitive...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.  We are

 

      skipping number 13 because the FDA is

 

      superstitious--no, actually number 13 has not

 

      shown, and we are turning to number 14.

 

                MS. TIERNEY:  Hello.  My name is Jennifer

 

      Tierney, and I have no financial ties to anyone but

 

      my husband--

 

                [Laughter]

 

                My daughter, Jamie, and I attended the

 

      last advisory meeting during which she described

 

      her experience on Effexor.  Jamie was prescribed

 

      Effexor for migraine headaches, not--and I want to

 

      emphasize--not for depression.  She became suicidal

 

      on Effexor for the first time in her life and, to

 

      make matters worse, when she tried stopping Effexor

 

                                                               290

 

      she suffered tremendous withdrawal reactions.

 

                Following the February PDAC, I met with

 

      members of HHS and Dr. Temple.  I followed up with

 

      a letter to the FDA which I cc'd to the entire

 

      advisory panel, detailing the history of FDA's

 

      failure to protect the public health related to

 

      antidepressants and suicidality.

 

                I have returned today to make a couple of

 

      points.  First, I want to thank the panel from the

 

      February meeting for actually listening to us and

 

      for taking us seriously about our concerns.

 

      Second, I would like to say that I am appalled that

 

      the FDA would not allow the maker of Effexor to

 

      place stronger warnings in its label, stating that,

 

      quote, in pediatric clinical trials there were

 

      increased reports of hostility, and especially in

 

      major depressive disorder suicide-related adverse

 

      events such as suicidal ideation and self-harm,

 

      unquote.  This is what the data shows, yet the FDA

 

      will not allow it.

 

                One has to ask whose interest is the FDA

 

      protecting here?  I honestly do not know how the

 

                                                               291

 

      individuals responsible for this can even sleep at

 

      night.  Now the U.K. has all but banned these drugs

 

      in children and adolescents.  Dr. Mosholder found

 

      an increased risk of suicidal behavior in children

 

      and adolescents taking the drugs, which certain

 

      people within the FDA tried to suppress.  Now the

 

      review by the Columbia group, despite its flaws,

 

      seems to confirm that risk.

 

                Well, it doesn't take a rocket scientist

 

      to figure out that if a drug lacks efficacy, which

 

      has been a problem for the drug companies in both

 

      child and adult clinical trials, and it has serious

 

      risks such as suicidality, you probably should not

 

      be prescribing it to as vulnerable population as

 

      children and adolescents.  The argument that one

 

      doesn't want to deter people from taking them

 

      doesn't hold water when you consider the lack of

 

      efficacy.  But for those families who still argue

 

      that drugs have been helpful to their child, that

 

      does not justify withholding warnings that would

 

      have helped my child and save lives.

 

                One last comment I would like to make is

 

                                                               292

 

      that Pfizer's very personal attack on Dr. David

 

      Healy and the father who lost his 13 year-old

 

      son--he hung himself while on Zoloft--is nothing

 

      short of reprehensible.  It appears that Pfizer is

 

      getting down and dirty.  Dr. Healy is a pioneer

 

      whose bravery and strength of character has saved

 

      lives.  As for the boy, even if Pfizer's facts were

 

      accurate, the drug is...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker number 15, please come forward to the

 

      microphone.

 

                DR. SALERIAN:  Good afternoon.  I am Dr.

 

      Salerian.  I am a psychiatrist and medical director

 

      of a private psychiatric clinic, and I primarily

 

      practice psychopharm.

 

                As a society, we are wonderful at

 

      developing villains and heroes, and it is

 

      impossible for me to sit in this room and not to

 

      realize that it is as if we had two groups of

 

      people, good people and bad people, and depending

 

      on what side you are taking, the other side is the

 

                                                               293

 

      enemy and we are questioning their values and

 

      integrity.  The truth is, as a psychiatrist, I am

 

      very ashamed of how poorly we have served the

 

      nation in terms of educating about the dangers of

 

      side effects of antidepressants, and this is the

 

      truth.  So, in that way, I personally apologize to

 

      anybody--to mothers and fathers, whose children

 

      have been affected adversely by antidepressants.

 

                It is also true that depression is a real

 

      illness. It exists.  It existed before

 

      antidepressants.  I grew up in Turkey and I can

 

      tell you that even today not many people take

 

      antidepressants, but a good number of people manage

 

      to commit suicide or have miserable lives.  The

 

      significant thing to know for all of us is that

 

      depression is a dangerous disease, so are

 

      antidepressants.

 

                Now, in terms of our approach and the

 

      numbers--recently I published an article and

 

      reviewed an article in Lancet about antidepressants

 

      and safety.  My analysis is that we are making a

 

      big mistake by not realizing that depression is a

 

                                                               294

 

      heterogeneous group of depressed kids and

 

      adolescents; it is not just one group.  When a

 

      child is depressed he may grow up and develop

 

      nothing; may grow up with a bipolar illness; may

 

      grow up and become an adult with schizophrenia or

 

      any other serious psychiatric illness.  Our current

 

      technology and science is not enough to

 

      differentiate one diagnosis, particularly children

 

      who present with depression and who are dormant

 

      candidates to become severely ill as adults.  This

 

      itself causes tremendous vulnerabilities and,

 

      therefore, monitoring is essential to prevent side

 

      effects and dangerous consequences such as suicide.

 

      So, better monitoring would be my advice.  Thank

 

      you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker number 16, please come forward.

 

                MS. BOSTOK:  Over ten years ago, in the

 

      article,

 

      "Antidepressant Drugs and the Emergence of Suicidal

 

      Tendencies," Harvard doctors described nine

 

                                                               295

 

      mechanisms by which antidepressants can induce

 

      suicidality.  My daughter, Cecily, who stabbed

 

      herself to death after three weeks on Paxil,

 

      exhibited behavior on antidepressants that closely

 

      fit these mechanisms.  We need warnings for all of

 

      them.

 

                One, energizing--antidepressants may

 

      provide the energy to enable depressed patients to

 

      act on preexisting suicidal plans.  The authors

 

      affirm the relevance of this mechanism to other

 

      classes of antidepressants besides SSRIs but state

 

      that in no case was there evidence that strong

 

      preexisting self-destructive urges were energized

 

      by Prozac.  Cecily had no history of suicidality.

 

      She was not given Paxil for depression but for

 

      racing thoughts and her energy did not improve.

 

                Two, paradoxical worsening--Cecily's mood

 

      did worsen on Paxil.

 

                Three, akathisia--in the last days of her

 

      life Cecily was jittery.

 

                Four, panic anxiety--after Cecily started

 

      treatment she became very fearful upon waking.  The

 

                                                               296

 

      last day of her life she came shrieking from her

 

      bedroom, terrified by the noise of a

 

      plane--completely uncharacteristic.

 

                Five, manic or mixed states--although

 

      Cecily had no confirmed diagnosis for mood

 

      disorder, she was being treated for manic-like

 

      symptoms.  Paxil was exactly the wrong medication

 

      for her.  Patients should be closely monitored for

 

      the emergence of mania which can enhance violent

 

      and aggressive behavior or a mixed state can

 

      augment suicide risk.

 

                Six, sleep disturbances--on the first

 

      night she took an antidepressant she walked in her

 

      sleep.  She had never done this before.  There is

 

      evidence she was sleepwalking when she died.  She

 

      did not turn on any lights or make any noise when

 

      she stabbed herself at 2:00 a.m.  Quote, Prozac

 

      produced a dramatic increase in rapid eye movement

 

      even during non-REM sleep stages.  It reduced delta

 

      sleep, causing emergence of day terrors similar to

 

      unmedicated patients with a history of suicidal

 

      attempts.

 

                                                               297

 

                Seven, suicidal preoccupation--on the last

 

      day Cecily confessed uncharacteristic fears, and

 

      after dinner stared strangely at her knife.  This

 

      frightened me but I never dreamed she was

 

      contemplating self-harm; she had never done so

 

      before.  Quote, strong obsessive, remarkably

 

      violent suicidal thoughts emerged after Prozac

 

      treatment.

 

                Eight, borderline state--symptoms of

 

      borderline disorder suggest a state of serotonin

 

      dysregulation.  Cecily's autopsy revealed a very

 

      high blood level of Taxol and, thus, acute

 

      dysregulation.  Quote, patients who do not suffer

 

      from borderline disorder may have drug-induced

 

      borderline reactions that include emergence of

 

      uncharacteristic aggression, self-mutilation and

 

      suicide.

 

                Nine, EEG activity--Cecily said when she

 

      took a pill she felt like it was frying her brain.

 

      One study reported a...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much. 

 

                                                               298

 

      Speaker number 17, please come forward to the

 

      microphone.

 

                DR. FASSLER:  Thank you.  My name is David

 

      Fassler.  I am a child and adolescent psychiatrist,

 

      from Burlington, Vermont.  I am speaking on behalf

 

      of the American Psychiatric Association.  No

 

      pharmaceutical or other industry support was used

 

      in conjunction with my appearance here today.

 

                I would like to emphasize a few key

 

      points.  First, childhood and adolescent depression

 

      are very real illnesses which affect between 3-5

 

      percent of all young people.

 

                Second, these are extremely serious

 

      conditions with very significant consequences.

 

      Research tells us that over half of all kids who

 

      suffer from depression will eventually attempt

 

      suicide at least once, and over 7 percent will

 

      actually die as a result.  Fortunately, effective

 

      treatment is available.  Medication, including the

 

      SSRI antidepressants, can be extremely helpful and

 

      even life-saving for some children and adolescents,

 

      but medication alone is rarely an adequate or

 

                                                               299

 

      sufficient intervention for complex child

 

      psychiatric disorders such as depression.

 

                With respect to the SSRIs, I would offer

 

      the following comments and observations.  The

 

      studies currently available do suggest that the use

 

      of these medications may be associated with an

 

      increased risk of certain suicide-related thoughts

 

      and/or behaviors in some children and adolescents.

 

      However, the data is far from clear.

 

                For example, as we heard this morning, the

 

      same data indicates that there is no significant

 

      increase in the worsening or emergence of suicidal

 

      symptoms.  As you have also heard, concerns about

 

      suicidal thoughts and behaviors early in the course

 

      of treatment are not new.  They are also not

 

      limited to the SSRIs, nor are they limited to the

 

      treatment of children and adolescents.  Thoughts

 

      about suicide are also not uncommon, especially

 

      during the teenage years.  According to the CDC,

 

      one adolescent in six thinks about suicide each

 

      year.  Fortunately, the overwhelming majority of

 

      young people who have suicidal thoughts do not

 

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      actually commit suicide.  But every suicide is a

 

      tragedy and any increased risk of suicidal thoughts

 

      or behavior, no matter how small, must be taken

 

      very seriously.

 

                However, based on the data currently

 

      available, most clinicians believe, and I would

 

      concur, that for children and adolescents who

 

      suffer from depression the potential benefit of

 

      these medications far outweighs the risk.

 

                There is also general clinical consensus

 

      that all of the antidepressants are effective for

 

      some but not all children and adolescents.

 

      Research indicates that between 30-40 percent will

 

      not respond to an initial medication, however, many

 

      of these young people will ultimately respond to a

 

      different medication.

 

                Let me close with the following specific

 

      recommendations.  First, we strongly support the

 

      development of a national registry of all clinical

 

      trials.

 

                Second, we support the continuation of the

 

      current FDA warnings with respect to SSRI

 

                                                               301

 

      antidepressants.  We believe the language is

 

      appropriate and consistent with our current

 

      knowledge, understanding and scientific data.

 

                Finally, we fully support the call for

 

      additional large-scale research studies.  Thank

 

      you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much for your

 

      presentation.  Speaker number 18, please come

 

      forward.

 

                MR. WOODWARD:  My name is Tom Woodward.

 

      My wife, Kathy, and I have four children.  Julie,

 

      the oldest of our four children, took her life on

 

      July 22, 2003.  Julie was a gentle and beautiful

 

      young girl.  She was only 17.  She was deeply loved

 

      and is truly missed by all who knew her.  Julie was

 

      a normal teenager, dealing with normal teenage

 

      issues.  She had no history of self-harm or

 

      suicide.

 

                She was prescribed Zoloft and we were told

 

      that it was safe, very mild, extremely effective

 

      and essential to her getting better.  Seven days

 

                                                               302

 

      after taking her first Zoloft tablet Julie hung

 

      herself in the garage of our home.  We have since

 

      learned that Julie began experiencing akathisia

 

      almost immediately after taking the first pill.

 

                Julie never harmed herself in her 17

 

      years.  The only variable was seven days of Zoloft.

 

      We are certain that Zoloft killed our daughter.

 

      The recent JAMA article stated that the risk of

 

      suicide is 40 times greater during the first nine

 

      days of treatment with an SSRI.  I believe this is

 

      a national crisis.

 

                The drug industry has oversold the

 

      purported benefits of SSRI drugs and aggressively

 

      promoted their use.  As the Spitzer lawsuit

 

      confirmed, drug companies have purposely misled the

 

      public about the safety and efficacy of their

 

      drugs.

 

                The problems associated with these drugs

 

      are particularly frightening in light of the Bush

 

      administration's new Freedom Initiative, a program

 

      designed to subject every school age child in this

 

      country to psychological testing.  The way these

 

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      tests are designed, many children will fail and

 

      inevitably be prescribed an SSRI.  Tragically, some

 

      of these children will then go on to mutilate

 

      themselves, commit acts of violence, or kill

 

      themselves as a direct result of these drugs.  We

 

      are too quick to medicate our children.

 

                Our system of medical treatment is based

 

      on a sacred circle of trust.  This trust has been

 

      broken.  Children look to their parents to protect

 

      and guide them.  Parents seek out the advice and

 

      counsel of physicians and mental health

 

      professionals who, in turn, largely rely on the

 

      drug industry opinion leaders and the FDA to allow

 

      them to fulfill their role as informed

 

      intermediaries.  The drug industry has employed

 

      tactics of deception, distortion, misdirection and

 

      manipulation.

 

                Big PhARMA's money has corrupted the

 

      process and destroyed the sacred trust.  They buy

 

      political influence that secures the placement of

 

      individuals within the FDA to do their bidding,

 

      such as Dan Troy whose mission is clear--damn the

 

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      public and protect his former drug industry clients

 

      at all cost.  Troy is more concerned with tort

 

      reform than with children's lives.

 

                Senior leadership at the FDA drag their

 

      feet and make Orwellian statements such as, just

 

      because these drugs have not been proven to be

 

      effective does not necessarily mean they are

 

      ineffective.  This gibberish is an insult to the

 

      American public and would be laughable if the

 

      consequences weren't so terribly tragic.

 

                Drug industry CEOs at Pfizer and those at

 

      Glaxo and Lilly, senior leadership under FDA--Troy,

 

      Crawford, Temple, Katz and Laughren know the truth

 

      and therefore have blood on their hands.

 

                I deeply appreciate the work of this

 

      committee.  I know there are good people at the FDA

 

      trying to do the right thing in spite of the FDA's

 

      current leadership.  Implement class-wide, strongly

 

      worded black box warnings immediately, inclusive of

 

      Prozac, not some carefully worded drug industry

 

      version designed to protect their interests instead

 

      of the public's.  The FDA needs to be restored to

 

                                                               305

 

      its vitally important mission of protecting the

 

      welfare of the American public.

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker number

 

      19.

 

                MS. MCDONALD:  Good afternoon.  My name is

 

      Sheila McDonald.  I am the vice president of the

 

      Board of the Child and Adolescent Bipolar

 

      Foundation.

 

                The public is alarmed that SSRIs may cause

 

      children to become suicidal.  What alarms us is

 

      that untreated children, prepubertal children and

 

      teens with affective mood disorders are already

 

      suicidal at high rates.  This is the crux of the

 

      problem.

 

                Just two days ago there was a posting on

 

      our website, and I quote a woman about her 10

 

      year-old son where she says, "I thank God for each

 

      and every pill, each and every day that I don't

 

      have to listen to my son, my little boy say that he

 

      wishes he was dead."  She was talking about mood

 

      stabilizers, not SSRIs but we come back to the crux

 

                                                               306

 

      of the problem, which is that untreated children

 

      are already suicidal.

 

                I have prepared remarks.  I think they

 

      have been handed out to you, and this may be a

 

      little disjointed.  I wanted to talk actually about

 

      some testimony that we have heard this morning.  I

 

      have two points on that.  One is that the research

 

      is not where it should be.  It is not advanced

 

      enough for us to be able to distinguish between

 

      children with major depressive disorder and

 

      children with bipolar disorder.

 

                Secondly, as a lay person, which I admit

 

      that I am, many of these events I think can be

 

      explained perhaps by SSRI's triggering

 

      disinhibition for children who perhaps have

 

      presented with a major childhood depression

 

      disorder but, in actuality it is bipolar disorder.

 

                This morning Dr. Laughren asked the

 

      committee what research is needed.  In my prepared

 

      remarks we urge that significant resources be

 

      devoted to both the suicidality component inherent

 

      in certain pediatric brain disorders and on the

 

                                                               307

 

      efficacy and safety of medications used to treat

 

      these disorders in the pediatric population.  We

 

      must realize that children are not short adults.

 

                What I think this morning's testimony has

 

      made clear is that research must be devoted to

 

      diagnosing appropriately the pediatric psychiatric

 

      disorders.  All the presenters have made the

 

      assumption--as I like to say, they have put the

 

      bunny in the hat.  It is easy to pull the bunny out

 

      once you put the bunny in--bunny in the hat.  Dr.

 

      March says that his studies have excluded bipolar

 

      disorder.  Dr. Dubitsky speaks of the, quote,

 

      potential influence of study design on suicidal

 

      risk.  Our children are ill.  Our children need

 

      medical help and they are excluded from these

 

      studies, our children who have bipolar disorder.

 

                At this time we don't have a magic

 

      dip-stick to tell whether you have MDD or BP.

 

      Clinicians must be cognizant that an episode of

 

      childhood depression can signal bipolar disorder

 

      and that in certain cases antidepressant use may

 

      trigger or provoke mania.  We do want amplified

 

                                                               308

 

      warnings and monitoring, but we do oppose any

 

      attempt to ban the use of antidepressants as they

 

      can be an important and potential life-saving tool

 

      in the treatment box when carefully monitored.

 

      Thank you.

 

                DR. GOODMAN:  Thank you.  Speaker number

 

      20?

 

                DR. WALKUP:  I am John Walkup.  I am a

 

      child and adolescent psychiatrist, on the faculty

 

      at Johns Hopkins.  I currently have grant support

 

      from Eli Lilly, Pfizer and Abbott, and within the

 

      past year I have received honoraria from Lilly,

 

      Pfizer and Janson.  No one is paying for me to be

 

      here and I don't represent anyone today other than

 

      myself.

 

                I am a clinician and also a clinical

 

      investigator.  I have conducted federally-funded

 

      trials like TADS.  I was a participant in TADS and

 

      I have also participated in industry-sponsored

 

      trials  As a clinician, there is much at stake

 

      today.  There are many, many children who have

 

      benefited from appropriate assessment and

 

                                                               309

 

      treatment, and I am afraid their stories may get

 

      lost if someone doesn't speak for them.

 

                Prior to this controversy we knew a lot

 

      about depression, and one of the things that we

 

      knew about was the early risk for suicidal ideation

 

      early in the course of treatment.  In addition, we

 

      were also trained that medications, not just SSRIs

 

      but other medications, can cause behavioral side

 

      effects.  So, other antidepressants, the

 

      tricyclics, antihistamines like Benadryl, and

 

      anti-malarials were recently reported in the

 

      newspaper.  Anti-psychotic medications and

 

      stimulants can all cause changes in behavior.  What

 

      is unusual is the link between changes in behavior

 

      and suicidal acts that we do not understand even

 

      though changes in behavior are a part of the

 

      spectrum of drug effects.

 

                With that said about suicidal behavior, I

 

      would like to talk a little bit about the efficacy

 

      trials.  It is very surprising to me as a clinician

 

      that the clinical trials do not document efficacy

 

      of antidepressants in depression.  When I look at

 

                                                               310

 

      the clinical trials, there are two types of

 

      clinical trials.  There are the federally-funded

 

      trials and then there are the industry-sponsored

 

      trials.  If you look closely at the methodologies

 

      for both, there are significant differences in the

 

      methodologies for the federally-funded trials and

 

      the industry-sponsored trials, with the

 

      federally-funded trials having a much higher

 

      standard for ongoing quality assurance and training

 

      of investigators and participation.

 

                My recommendations to the FDA, as humble

 

      as I can be, please don't make policy based on

 

      complex and rare events.  It is a dangerous

 

      precedent and it can do more harm than good.  If

 

      you do go to a stronger warning, please provide a

 

      warning that clarifies but doesn't magnify.

 

      Magnification of the warning may actually do more

 

      harm than good to the kids who actually need to

 

      come to care.

 

                Lastly, I would encourage the FDA, as it

 

      reviews future clinical trials in children, to

 

      think about those kinds of standards that are set

 

                                                               311

 

      through the peer review process for clinical trials

 

      in kids, and to incorporate some of those quality

 

      measures in those clinical trials.  Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker 21,

 

      please come forward.

 

                MR. TAYLOR:  My name is Mark Taylor and I

 

      am one of the victims, one of the many victims of

 

      the SSRI antidepressant era.  I took 6-13 bullets

 

      in the heart area at my high school when Eric

 

      Harris who was, in fact, on Luvox fired at me.

 

      They almost had to amputate my leg and my arm.  My

 

      heart was missed by only one millimeter.  I had

 

      three surgeries.  Five years later I am still

 

      recuperating.

 

                I had to go through all this to realize

 

      that antidepressants are dangerous for those who

 

      take them and for all of those who associate with

 

      those who take them.  I hope that my testimony

 

      today shows you that you need to take action

 

      immediately before more innocent people like me and

 

      you get hurt or die horrible deaths as a result.

 

                                                               312

 

                As Americans, we should have the right to

 

      feel safe, and if you were doing your jobs we would

 

      be safe.  Why are we worrying about terrorists in

 

      other countries when pharmaceutical companies have

 

      proven to be our biggest terrorists by releasing

 

      these drugs on an unsuspecting public?  How are we

 

      supposed to feel safe at school, at home, on the

 

      street, at church or elsewhere if we cannot trust

 

      the FDA to do what we are paying you to do?  Where

 

      were you when I got shot?

 

                You say that these antidepressants are

 

      effective.  So, why did they not help Eric Harris?

 

      According to Eric, they helped him feel suicidal.

 

      He reported to his psychiatrist he was having

 

      psychotic reactions to the drug.  They took him off

 

      it.  He said he was doing great.  They put him back

 

      on it.  He was having suicidal thoughts again.

 

      These drugs help increase the rage in people and

 

      cause them to do things they would not do anyways.

 

      So, why do these so-called antidepressants not make

 

      him better?

 

                I will tell you why.  It is because they

 

                                                               313

 

      don't work.  We should consider antidepressants to

 

      be accomplices to the murder.

 

                MS. TAYLOR:  Hello.  My name is Donna

 

      Taylor and Mark did go through these injuries.

 

      Mark and I both know that had Eric Harris not been

 

      given the antidepressants both Zoloft and Luvox the

 

      nightmare at Columbine would never have happened to

 

      our family and our lives.  But Columbine was only

 

      the beginning of the antidepressant-introduced

 

      nightmare.  I was also given antidepressants and

 

      suffered side effects, including suicidal thoughts

 

      and horrible Paxil withdrawal.

 

                To this day, four years later, I am still

 

      suffering adverse events.  Many other members of my

 

      family have been on antidepressants with disastrous

 

      results.  Where there was never a...

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker number

 

      22, please come forward to the microphone.

 

                MS. WOODSACK:  Hi, my name is Kin Woodsack

 

      and my husband of almost ten years, Woody, died of

 

      Zoloft-induced suicide after being on the drug for

 

                                                               314

 

      five weeks, with the dosage increased just prior to

 

      his death.

 

                He was prescribed Zoloft by his general

 

      physician for the diagnosis of insomnia.  He had

 

      just started his dream job as vice president of

 

      sales for a start-up company two months prior.  He

 

      was having trouble sleeping due to the new stresses

 

      of the job.  Woody wasn't depressed, nor did he

 

      have a history of depression or any other mental

 

      illness.  He was told the drug was safe and was

 

      sent home and a three-week Pfizer-supplied sample

 

      packet automatically doubled the dosage from 25-50

 

      mg.  No cautionary warning was given to him nor me.

 

      In fact, I was out of the country and there was

 

      nobody monitoring him the first two and a half

 

      weeks.

 

                Shortly before he died, I found him curled

 

      up in a fetal position with his hands like a vice

 

      going, "help me; help me.  I don't know what's

 

      happening to me.  It's like my head is outside my

 

      body looking in.  I'm losing my mind."  This is not

 

      just a children's issue.  Adults are also dying

 

                                                               315

 

      from SSRI-induced suicides.

 

                As I was preparing for today one thing

 

      kept coming to mind, and that is the outrageous

 

      marketing of these drugs.  These drugs were

 

      originally designed for major depressive disorder.

 

      Now they are being prescribed for everything from

 

      mild depression, anxiety, shyness, insomnia,

 

      migraines.  Just last week people were on the

 

      "Today Show."  Doctors were telling people they

 

      could take two weeks on, two weeks off because

 

      having depression is so serious with PMS.  One drug

 

      fits all?  Are these marketing based or are they

 

      science based?

 

                You know, my entire career has been in

 

      advertising and I just want to say thanks to the

 

      drug companies that are here because the Harvard

 

      Business School is actually doing a study, one of

 

      the case studies, which is all about the marketing

 

      of antidepressants.  I have to say that children

 

      who have died on these drugs matter.  The adult

 

      victims of this tragedy matter.  Woody, my best

 

      friend, matters.  The time has come to do the right

 

                                                               316

 

      thing.  We should never have been here today if the

 

      right thing had been done 13 years ago and the

 

      follow-up safety studies had been done, and if FDA

 

      followed up with the drug companies.

 

                Let's continue not to waste hours of

 

      precious time and lives.  We have to fix the

 

      problem.  The system is broken.  We have to do it;

 

      people's lives are at stake.  Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker number 23, please come forward to the

 

      microphone.

 

                MS. BARTH MENZIES:  Thank you.  My name is

 

      Karen Barth Menzies, and I am an attorney with Baum

 

      Headland.  We represent over 100 families whose

 

      loved ones have committed suicide or they,

 

      themselves, have attempted suicide.  You heard from

 

      a few of them today.

 

                Approximately half of those cases involve

 

      children.  We have been doing this for over 14

 

      years.  Through the litigation process, our experts

 

      see more evidence concerning the true risks versus

 

                                                               317

 

      the true efficacy of these drugs than anyone

 

      anywhere.  That includes FDA.  Court-imposed

 

      protective orders don't permit us to show this

 

      evidence to FDA or even the congressional

 

      investigators or you.

 

                This evidence shows, I can tell you, that

 

      the companies have known about the serious risk and

 

      the lack of efficacy since the mid 1980s.  But

 

      today I am not going to talk about suicide risk.

 

      Plenty of people are going to be addressing that

 

      today.  What I want to talk about is efficacy.

 

                For purposes of illustration and because

 

      of what I have just heard earlier today, I am going

 

      to focus on Zoloft.  Dr. Paul Lieber, former FDA

 

      veteran of 20 years, who was principally involved

 

      in the investigation, analysis and approval of the

 

      SSRIs, wrote in a memo, from August of 1991, and I

 

      quote, in recommending the approval of Zoloft for

 

      adults, I have considered the fact that the

 

      evidence marshalled to support Zoloft's efficacy is

 

      not as consistent or robust as one might prefer it

 

      to be.  Back in 1991, Dr. Lieber noted that

 

                                                               318

 

      numerous countries around Europe have already

 

      rejected or were about to reject approval of Zoloft

 

      because Pfizer could not demonstrate efficacy.  It

 

      was only until FDA approved Zoloft that the rest of

 

      the countries followed.

 

                In 1991, Dr. Lieber stated, and I quote,

 

      approval of Zoloft may come under attack by

 

      constituencies that do not believe FDA is as

 

      demanding as it ought to have been in regard to its

 

      standards for establishing the efficacy of the

 

      antidepressant drugs.

 

                Just yesterday Dr. Lieber was quoted again

 

      in the "Denver Post" article, stating, second

 

      generation antidepressants were approved by a

 

      regulatory process that requires only limited proof

 

      of efficacy and safety.  Dr. Lieber also quoted,

 

      you are working in a sea of ignorance.  He

 

      concluded, I do have some doubts about these drugs'

 

      values in the big picture.

 

                The drug companies have been so successful

 

      in misleading the medical profession that their

 

      drugs are remarkably effective that it is hard...

 

                                                               319

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker number

 

      24, please come forward to the microphone.

 

                DR. GREENHILL:  Thank you.  My name is

 

      Larry Greenhill. I am a child and adolescent

 

      psychiatrist, from New York.  I am speaking today

 

      on behalf of the American Academy of Child and

 

      Adolescent Psychiatry and the American youth that

 

      they represent.  This organization represents over

 

      7000 child psychiatrists across the country and has

 

      supported my trip here today.  I have also received

 

      support for research from the pharmaceutical

 

      industry in the past but not for this meeting.

 

                In the brief time I have been given I want

 

      to focus on four points.  Both I and the Academy

 

      support education about depression, which is a

 

      serious illness which needs very good treatment

 

      immediately.

 

                Second, the Academy supports better

 

      adverse event elicitation and safety monitoring

 

      procedures.

 

                Third, the Academy supports the formation

 

                                                               320

 

      of a national registry of clinical trials and,

 

      finally, they support more prospective research.

 

                To get to the first point, the Academy

 

      finds untreated depression to be a serious illness

 

      which interrupts youth's normal emotional

 

      development, undermines self-esteem, interferes

 

      with learning in school, and undermines friendship

 

      with peers.  It afflicts many of the 500,000

 

      adolescents who attempt suicide annually in this

 

      country.

 

                Second, the Academy supports the FDA's

 

      more detailed evaluation of safety data found in

 

      the clinical trials of SSRIs we are discussing

 

      today; supports its Columbia reclassification

 

      project; and supports the public airing of the

 

      resulting data analysis.

 

                We also agree with the FDA's decision to

 

      insert warning language into the package

 

      instructions that accompany all antidepressant

 

      medications, alerting physicians and families about

 

      the need to monitor for signs of new suicidal

 

      thinking or activity during the early days of

 

                                                               321

 

      treatment.

 

                Many child psychiatrists, including me,

 

      have found these antidepressants to be helpful for

 

      treating carefully diagnosed depressed adolescent

 

      patients when these drugs are used in a

 

      well-monitored treatment program.  It is reassuring

 

      that the analyses that we have heard today fail to

 

      find a single completed suicide among the 4400

 

      youth who participated in clinical trials.

 

                Third, the AACP is pleased to join the APA

 

      in support of a national registry of clinical

 

      trials.  We believe that physicians and parents

 

      must have all available knowledge about a

 

      medication's safety and effective to make informed

 

      decisions about treatment choices.

 

                Fourth, the Academy calls for more

 

      research on SSRIs to obtain more precise estimates

 

      of the risk of suicidal behaviors and suicidal

 

      ideation during treatment.  The Academy supports

 

      the funded research efforts now under way, and we

 

      encourage the FDA to support new data in the future

 

      using an incentive program.  Thank you.

 

                                                               322

 

                DR. GOODMAN:  Thank you.  Is speaker

 

      number 25 here?  Okay, we will turn to speaker

 

      number 26, please.

 

                DR. DILLER:  I have prescribed psychiatric

 

      drugs to children for 26 years.  I have written two

 

      books on children and psychiatric drugs.  I have

 

      appeared before Congress and the President's

 

      Council on Bioethics.  But today I come before you

 

      as a physician in private practice with a report

 

      from the front lines, news from the primary care

 

      pediatricians and family doctors, the private

 

      practice child psychiatrists and the families of

 

      the patients themselves.

 

                I am here, representing the views and the

 

      reactions of a silent majority of physicians who

 

      aren't intimately connected financially with the

 

      drug industry.  Here is what they are saying and

 

      thinking:  The battle over the SSRIs in kids'

 

      depression is over.  The ongoing publicity and

 

      negative reactions have already changed the average

 

      doctor's opinions and practices.  No longer are

 

      pediatricians, willy-nilly, prescribing SSRIs for

 

                                                               323

 

      minor mood swings and phobias.  Even child

 

      psychiatrists have become more careful to whom they

 

      prescribe.  All the doctors have become aware of

 

      the problems that may be developed in the early

 

      stages of SSRI treatment.  They are warning the

 

      families and following the children far more

 

      closely.

 

                I think this is a very good development.

 

      However, many of the leaders in organized

 

      psychiatry and academia are publicly wringing their

 

      hands--pediatric depression is untreated they say.

 

      Now even more families will refuse medication.  I

 

      find this cavilling worry the height of psychiatric

 

      sanctimony.  For years we were told to practice

 

      evidence-based medicine and now, when there is no

 

      evidence for SSRI effectiveness and yet higher risk

 

      of suicidality, the leaders say, "wait, not so

 

      fast."  I say, "where's the beef?"

 

                That brings me to my major point.  There

 

      is a growing credibility gap between the front-line

 

      doctors with the leadership and researchers in

 

      psychiatry.  We simply do not know what to believe.

 

                                                               324

 

      We are increasingly bewildered, skeptical and

 

      cynical.  The final blow was learning about the

 

      eight negative SSRI studies in children that were

 

      never released to either the doctors or the public.

 

                This loss of credibility within the

 

      medical profession extends beyond psychiatry into

 

      all of medicine and the general public.  The blame

 

      is clear.  The money, power and influence of the

 

      pharmaceutical industry corrupts all.  The

 

      pervasive control that the drug companies over

 

      medical research, publications, professional

 

      organizations, doctors' practice, Congress and,

 

      yes, even agencies like the FDA is the American

 

      equivalent of a drug cartel.  It is long overdue to

 

      make changes in the way we approve and market

 

      pharmaceutical drugs in this country.

 

                Suppression of negative studies in the

 

      name of protecting stockholder interests at the

 

      cost of children's health highlights the immorality

 

      of an unfettered, unregulated marketplace.

 

      Specifically, we need true transparency in

 

      research.  We also need a more organized system of

 

                                                               325

 

      follow-up by neutral third parties once a drug is

 

      released.  Let us not lose the momentum to reform

 

      this moment gives us lest the tragedies of the

 

      families who appeared before us today go in vain.

 

      Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker number

 

      27?

 

                MR. BUTLER:  My name is Reese Butler, and

 

      I am a survivor.  I lost my wife, my best friend,

 

      my life partner to a suicide on April 7th, 1998.

 

      Her name was Kristin Brooks Roussel.  It is my

 

      belief, and the belief of many experts I have met

 

      since her death that her suicide was preventable.

 

                What began the chain of events that led to

 

      her suicide was a severe bout of postpartum

 

      depression treated with SSRIs, which triggered what

 

      is known as an SSRI syndrome.  Kristin became

 

      pregnant in July of 1997 and was taking SSRIs on a

 

      daily basis.  She had been taking SSRIs for close

 

      to five years.  They worked.  They gave her peace

 

      and very little depression.

 

                                                               326

 

                The pregnancy was unplanned so during the

 

      first trimester she was still on the SSRIs.  As

 

      soon as she found she was pregnant she stopped

 

      taking the drug.  On December 7th we learned that

 

      our baby daughter had many significant birth

 

      defects, one of them life-threatening to our baby.

 

      She immediately decided to terminate the pregnancy.

 

      After losing our baby she started down a path that

 

      led to her death.

 

                A bipolar mom is 31 times more likely to

 

      suffer postpartum depression.  The standard of care

 

      is prescribing SSRIs.  This can trigger an SSRI

 

      syndrome when a bipolar patient is prescribed SSRIs

 

      without a mood stabilizer.  The opinion of many

 

      experts is that bipolar patients should not even be

 

      prescribed SSRIs at all due to the risk of violent

 

      behavior, both inward and outward, that can be

 

      caused by the SSRIs in a bipolar patient without a

 

      mood stabilizer.

 

                The way the syndrome can manifest is by

 

      causing a mania that does not end on its own.  The

 

      depressive side is abated but the drug does not

 

                                                               327

 

      stop the mania, which is a form of euphoria that

 

      can cause the patient to have an extended high like

 

      a runner's high.  As a result, the patient may not

 

      be able to sleep or sleep well.  In the case of my

 

      wife, she had sleep disturbances that lasted

 

      approximately two weeks.  Her doctor switched the

 

      SSRI she was on to another, hoping for a better

 

      effect.

 

                In the end she became suicidal and

 

      homicidal.  We were left with no choice but to

 

      admit her to a psychiatric facility.  There, they

 

      administered trazodone to help her sleep.

 

      Thirty-six hours into the stay she managed to hang

 

      herself on an electrical cord.  Her last words from

 

      her diary are chilling:  "I am experiencing major

 

      drug doubt feeling from the meds.  This is

 

      ridiculous.  My body chemistry has changed so

 

      dramatically from the SSRI and the additional crap

 

      on top of it.  This sucks.  Reese, darling, I will

 

      always love, Buddy too and Hank and Rich, mom and

 

      dad, etc.  This is no way for me to live.  It

 

      doesn't serve the world.  I am becoming a chronic

 

                                                               328

 

      insomniac due to the meds.  I am being tortured.  I

 

      must leave now.  Bye-bye, my love.  I will always

 

      love you, Kristin."

 

                To say the SSRI caused her death would be

 

      unfair and inaccurate.  The SSRI without a mood

 

      stabilizer prescribed by a psychiatrist who had

 

      poor training in risk assessment and not enough

 

      concern about SSRIs in a bipolar patient led to the

 

      sleep deprivation which I believe led to her

 

      suicide.

 

                As a survivor and a founder of the Kristin

 

      Brooks Hope Center, I ask that the FDA require

 

      educational materials about the risk factors in all

 

      prescriptions of SSRIs...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker number 28?

 

                DR. VOGEL-SCIGILIA:  Thank you very much

 

      for allowing myself, Dr. Suzanne Vogel-Scigilia,

 

      and my son, Anthony, to speak to you today.  It may

 

      seem paradoxical that you see many more families

 

      who have concerns about these medications than

 

                                                               329

 

      children who have done well since thousands of

 

      children have had their lives saved by these

 

      medications and the suicide rate in our youth has

 

      dropped.

 

                The view that this community receives is

 

      skewed towards the minority who claim tragic

 

      adverse events because families who are doing well

 

      don't have much motivation to be here.  Some can't

 

      believe that antidepressant medication access can

 

      be restricted directly or indirectly by your

 

      committee's decision.  Others are hesitant to

 

      parade their children whose lives have been saved

 

      in front of this media circus.

 

                Please do not make a decision without

 

      clear, reliable scientific evidence.  The only

 

      issue at hand here, in my opinion, is whether there

 

      is credible evidence to show a danger.  This you

 

      will have to decide, and I ask you not to make a

 

      hasty decision.  In all my years as a physician, I

 

      have never seen a warning removed on a medication,

 

      even later if evidence proves it should be.  If you

 

      inappropriately release a strong warning, either

 

                                                               330

 

      due to true concerns or because of intense pressure

 

      from the other viewpoint, managed care companies or

 

      nervous physicians willingness to pay for or

 

      prescribe these medications may decrease.  This

 

      will gravely harm far more children than any number

 

      who have appeared before the committee thus far.

 

                My father and husband are pediatricians

 

      who have prescribed psychotropic medications for

 

      two generations of children in Beaver County

 

      without adverse events.  I am a practicing clinical

 

      psychiatrist in the same area where there are

 

      woefully few pediatric psychiatrists and most care

 

      is done by other physicians.  Some family

 

      practitioners, pediatricians and psychiatrists in

 

      western Pennsylvania have told me they may have to

 

      stop prescribing if an inappropriate warning, not

 

      backed by reliable research, occurs due to the

 

      threat of malpractice in this litigation-based

 

      society.  Managed care companies also do not want a

 

      suit when their attempts to protect themselves may

 

      lead to prior authorization processes or other

 

      barriers to access that may frustrate families of

 

                                                               331

 

      physicians.

 

                The most chilling thing I have heard to

 

      day is that since the initial hearing on your

 

      committee occurred antidepressant prescriptions for

 

      children and adolescents have declined ten percent.

 

      One consequence of the prior warning is that more

 

      children are not receiving treatment that they

 

      need.  I hope that you think about these absent

 

      children and their families when you look at Tony

 

      and I.

 

                MR. SCIGILIA:  Hello.  Ladies and

 

      gentlemen of the FDA, my name is Tony Scigilia and

 

      I am diagnosed with bipolar disorder.  I currently

 

      take Wellbutrin.  My mother told me what was going

 

      on today and I want to tell you that I have been

 

      taking several--I took several antidepressant

 

      medications.  And, they consist of Zoloft, Prozac

 

      and Effexor, and they have caused me no side

 

      effects, none however.

 

                Please, help me preserve my future.  Don't

 

      take away my medication.  Thank you.

 

                DR. GOODMAN:  Thank you very much. 

 

                                                               332

 

      Speaker number 29?

 

                MS. WINTER:  Hello.  My name is Mary Ellen

 

      Winter.  This is my husband Jeffrey.  Exactly 342

 

      days ago we lost our daughter, Beth.  Beth was only

 

      22 years old and had recently graduated from the

 

      University of Rhode Island, in May, 2003.  Beth was

 

      looking forward to a career in communication and

 

      was experiencing some anxiety and having trouble

 

      sleeping when she consulted our family physician.

 

                He prescribed Paxil and said she would

 

      start feeling better in two weeks.  Seven days

 

      later Beth took her own life.  Since October 7th,

 

      2003 our family's life has been indelibly altered

 

      We, like most of you in this room, grew up with

 

      confidence in the strides made in medicine and

 

      accepted with faith antibiotics and vaccinations

 

      prescribed.  We believed the FDA would always act

 

      to protect our family's well being.

 

                When my daughter went to our family GP

 

      last year, we trusted that our doctor was well

 

      educated and informed.  We were wrong.  We now know

 

      that pharmaceutical sales is a high stake business,

 

                                                               333

 

      driven to increase shareholder wealth.  The

 

      consolidation of pharmaceutical companies like

 

      GlaxoSmithKline has resulted in increased

 

      sophistication in the quest to market and

 

      distribute pharmaceutical products.  Priority has

 

      moved from health to profit.  Not all doctors are

 

      equipped to understand the marketing targets they

 

      have become.  The FDA has allowed our daughter to

 

      be the victim of a highly commercial enterprise

 

      that selectively releases clinical data to maximize

 

      sales efforts and seek only to gain corporate

 

      profits.

 

                We quickly learned, after Beth's death,

 

      that Paxil and SSRIs in general are highly

 

      controversial and cases of suicidal behavior are

 

      well documented, yet the prescription Beth received

 

      contained no such warning.  Beth was not told about

 

      the hidden data or the clinical studies or the

 

      untold lawsuits that GlaxoSmithKline had been

 

      quietly settling.   The bottle of Paxil that Beth

 

      received only contained pills and had no warning as

 

      to the risk of suicide.

 

                                                               334

 

                As residents of the State of New York, we

 

      thank our Attorney General, Elliot Spitzer, for

 

      addressing issues that the FDA has been unwilling

 

      to address.

 

                [Applause]

 

                In a few summer months, Mr. Spitzer has

 

      forced GlaxoSmithKline to release secret clinical

 

      data, and in the future GlaxoSmithKline will be

 

      required to perform under the terms of the consent

 

      agreement.  We believe every state's attorney

 

      general in this country should seek similar action

 

      against GlaxoSmithKline.

 

                The FDA needs to regain their leadership

 

      position and restore lost respect and integrity.

 

      This will clearly require complete and full

 

      disclosure of the risk associated with prescription

 

      drugs regardless of the impact on potential sales

 

      and profit margins of the major pharmaceutical

 

      companies.  This will also mean full and complete

 

      disclosure of what the FDA knows to Congress and

 

      the American people about SSRIs.

 

                If we, or Beth, knew the information we

 

                                                               335

 

      now know, Beth would have recognized the side

 

      effects when they were taking effect.  We know for

 

      certain that Beth would have never hung herself in

 

      the home of her family whom she so loved...

 

                [Applause]

 

                DR. GOODMAN:  Speaker number 30, please.

 

                MS. HATCHER:  My name is Beverly Hatcher

 

      and I want to tell you how Paxil destroyed my

 

      mother's life.  She was a normal, healthy person

 

      who loved life to the utmost.  She loved to eat,

 

      cook, travel and talk on the phone.  She had a

 

      smile for everyone that she met.  She had no

 

      history of mental illness.

 

                In 1997, after my dad died, she moved from

 

      North Carolina to live with me, in Virginia.  She

 

      soon found work but later chose to retire.  She

 

      soon ran across another one of her childhood

 

      sweethearts.  They began to travel everywhere.

 

      This was life before Paxil.  On August 18, 2003,

 

      she was prescribed Paxil because of a small bout of

 

      depression that was due because of a heart attack

 

      of her closest cousin.  She quickly transformed

 

                                                               336

 

      into someone that began to complain of having

 

      constant bad dreams, having no appetite, being

 

      nervous, hearing voices.  She stopped taking baths

 

      at night and bit her nails down to nubs.  She said

 

      she thought things were crawling all over her and

 

      that she was losing her mind.  Nothing mattered

 

      anymore.  These were not normal signs of normal

 

      grief.

 

                On September 2nd, 2003, the day before her

 

      daughter's birthday, she hung herself in that

 

      daughter's basement.  This was 16 days after

 

      starting Paxil.  She was only 60.  How did Paxil

 

      get the FDA stamp of approval and make it to

 

      market?  How or why would any healthcare provider

 

      prescribe such a medicine capable of causing this?

 

      As a nurse and healthcare provider myself, we take

 

      an oath to save life, not destroy it.

 

                Are drug companies providing the FDA and

 

      healthcare providers all the facts about Paxil?

 

      No.  Drug companies are not telling the truth to

 

      the FDA, healthcare providers and certainly not to

 

      consumers because they have figured our a way

 

                                                               337

 

      around all the loopholes.  In this case, the FDA's

 

      guidelines are meaningless and they contain even

 

      bigger loopholes.

 

                To the FDA, we will never understand why

 

      this had to happen to us.  There is no excuse.  It

 

      was your job to protect my mother and not the drug

 

      company's profits.  Because of this, we will be

 

      motherless for the rest of our lives.  Nothing can

 

      change that.  When will enough be enough?  Stop

 

      taking innocent lives.

 

                To the drug companies, and especially to

 

      the FDA, this T-shirt sums up how we, the family of

 

      Barbara Jean Darton, feel about Paxil.  The back

 

      reads "cocaine is an illegal drug that kills."  On

 

      the front it reads, "Paxil is a legal drug that

 

      kills."  Don't put another family through this.

 

      Remove Paxil from society.  Until then, remember

 

      the faith and the message of this T-shirt and do

 

      the right thing.  Sincerely, in memory of my

 

      mother, Ms. Barbara Jean Darton.  Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  We are now going

 

                                                               338

 

      to take a brief break.  We will reconvene in ten

 

      minutes.

 

                [Brief recess]

 

                DR. GOODMAN:  Please start gravitating

 

      towards your seats.  As soon as we receive a few

 

      more committee members back from their break, we

 

      will recommence.

 

                First let me reiterate my apology that I

 

      issued before.  That is, we have a system that

 

      basically, once we start up, is automated and

 

      sometimes the microphone is turned off on people at

 

      a very key moment in their presentation.  We have

 

      to balance that with the desire to make sure that

 

      we are treating everybody uniformly.  I think that

 

      or the most part I am very pleased with the way

 

      this has been going, the respect that everyone has

 

      shown each other in the process.  I need to remind

 

      you that everyone has a chance to speak who had

 

      signed up.  Really we should not have any outbursts

 

      from the audience.  If there is somebody who has

 

      something to say, they should have had an

 

      opportunity to be up at the podium.  With that,

 

                                                               339

 

      speaker number 31.

 

                DR. SCHAEFER:  My name is David Schafer.

 

      I am a child psychiatrist and pediatric at Columbia

 

      University, and I have engaged in research on

 

      adolescent suicide since 1970.  I have never

 

      received any financial support from the

 

      pharmaceutical industry, and my travel expenses are

 

      going to be reimbursed by an endowment from the

 

      University.

 

                I am please to be able to make this brief

 

      statement because my main interest professionally

 

      has been in suicide prevention, and I believe that

 

      the decisions that will be arrived at by your

 

      committee will probably have an important effect on

 

      suicide prevention.

 

                I would like to make three points,

 

      starting with the point that was referred to this

 

      morning, by Dr. Wysowski about the coincidence

 

      perhaps, or perhaps not, of the very striking

 

      decline in the youth suicide rate that coincides

 

      with the very striking increase in the rate of

 

      prescription of SSRI antidepressants to

 

                                                               340

 

      adolescents.

 

                Starting in 1964, the youth suicide rate

 

      started to increase, and increased in an

 

      unstoppable fashion until about 1990.  At that

 

      point it stabilized and started to decline in 1994.

 

      This pattern was not confined to the United States.

 

      It was also found in most other developed countries

 

      where SSRIs are also available.  The general

 

      consensus is that SSRIs must be considered as one

 

      of the possible causes of this abrupt change in a

 

      pattern of mortality.

 

                I think Dr. Wysowski said quite clearly

 

      that this is an ecological situation.  The fallacy

 

      is there.  But I think it also was somewhat unfair

 

      in not giving cognizance to the large number of

 

      analyses that have been done to try and look at

 

      alternative explanations for the decline.  Most

 

      importantly, there has really been no decline in

 

      exposure to substance and alcohol abuse, which is

 

      recognized as one of the major risk factors.  There

 

      has been a decline in other forms of psychotherapy

 

      during this period, rather than an increase.  And,

 

                                                               341

 

      the rates have declined in many, many countries.

 

      Firearm suicide is almost unknown.  And, the CDC

 

      have recently produced data showing that there has

 

      been a significant switch from firearms to hanging

 

      in the United States during this period.  So, I

 

      think that we do have to give serious consideration

 

      to the possibility that there is a causal

 

      relationship.

 

                The second point is that there is another

 

      whole area of research which has not been

 

      discussed, which is toxicology analyses in suicide

 

      victims which have failed to show high rates of...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker number 32, please.

 

                MR. MILLER:  My name is Mark Miller.  The

 

      first thing I would just like to say in a response

 

      to a comment made earlier here this morning is that

 

      I would rather be scared to death by a label on a

 

      medication than be changed forever by the death in

 

      our family seven years ago.

 

                Seven months ago my wife Cheryl and I

 

                                                               342

 

      stood here and shared our story.  Our 13 year-old

 

      son, Matthew, had committed suicide after taking

 

      Zoloft.  We shared how he had become akathistic on

 

      the drug and, despite what Pfizer would like to

 

      have you believe about our son as they attempt to

 

      portray him in a letter posted on your website, the

 

      one indisputable fact that matters most is that

 

      Matt, our son, never attempted suicide or self-harm

 

      prior to taking Zoloft.  In fact, in testimony that

 

      Pfizer did not share with you, Matt revealed to his

 

      doctor before he ever took a pill that suicide was

 

      something that he could never bring himself to do.

 

      His doctor did not see suicide as a threat.  His

 

      mother did not see suicide as a threat, nor did I.

 

      Yet, within a week, one week on the pill, Matt

 

      violently and with great difficulty took his own

 

      life.

 

                Pfizer's strongly worded 50-page document

 

      continues to show a pattern of how drug companies

 

      disparage victims and anyone else who dares speak

 

      out against them.  Pfizer was so afraid of our case

 

      going to trial where the facts could best be

 

                                                               343

 

      weighed by a jury that they tried to discredit the

 

      science of an internationally respected expert.  If

 

      that is the case, the conclusions from this science

 

      are now being validated by regulatory bodies around

 

      the world.  Months ago, in fact, they were

 

      validated by your agency's own internal review.

 

                Health Canada, in the meantime, has

 

      demanded that Pfizer level with its citizens.  In a

 

      warning on their own letterhead, Pfizer Canada

 

      admitted last May that Zoloft, quote, may be

 

      associated with increased risk of suicidal ideation

 

      in children under 18, unquote.  Where is your

 

      demand for a similar clear and unambiguous warning

 

      in the U.S.?

 

                You have to go to page 13 of Pfizer's new

 

      38-page prescribing information for Zoloft until

 

      you read anything about the possibility of suicide,

 

      and even then there is no mention that the drug may

 

      be associated with it, as they admit to in Canada.

 

      That is a warning?

 

                Are we to believe that children in the

 

      U.S. react differently to Zoloft than Canadian

 

                                                               344

 

      children?  Last year in Great Britain, as you know,

 

      these drugs were banned for children under 18.  It

 

      is very possible they could ban their use for

 

      anyone under age 30.  Why, I ask, has the FDA,

 

      contrary to your own mandate, allowed negative

 

      trial data to be so easily kept from doctors and

 

      the American public?  Why haven't parents, like

 

      Cheryl and myself and countless others, been told

 

      the truth about these medications?  That is your

 

      job, to make sure that we get the information we

 

      need to make careful, wise and informed decisions.

 

      We learned the hard way that these drugs can kill.

 

      Many of the people are testimony to that.

 

                Ban these drugs...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 33, please come forward.

 

                MR. FARBER:  I am Donald Farber.  I am an

 

      attorney from Wren County, California.  I represent

 

      antidepressant victims and there are a lot of them,

 

      believe me.

 

                Dr. Hammad said this morning that there

 

                                                               345

 

      are no consistent patterns of trial design.  He

 

      cited 12 variables.  He is wrong.  There is a

 

      consistent pattern of trial design, and that is to

 

      conduct them so that they don't detect suicide at

 

      the crucial times.

 

                The Columbia project, though interesting

 

      and I am sure professionally stimulating, does not

 

      advance the knowledge necessary to know whether

 

      antidepressants are safe.  The only real question

 

      the world wants to know is do antidepressants cause

 

      suicide?  Congress asked Dr. Woodcock the question

 

      last Thursday, and she said the jury is still out.

 

      Well, the jury has been out on that question for 15

 

      years.

 

                We have heard the same rhetoric the last

 

      six months as we heard in 1991 with the original

 

      Prozac hearing.  If you go back and read the

 

      transcripts, it is the same thing.  Everybody knows

 

      why no progress has been made to answer that

 

      question.  The drug companies will not do the

 

      clinical trials to specifically test the suicide

 

      hypothesis under any condition.  If ethical

 

                                                               346

 

      barriers are involved, as Dr. Temple claimed in

 

      "The Wall Street Journal" and PBS, the FDA should

 

      give as much attention to ensuring clinical trials

 

      are properly designed to test that hypothesis as it

 

      has to this Columbia project to bail out the

 

      industry.

 

                While I have my opinion, the public cannot

 

      tolerate another 15 years of professional ignorance

 

      on whether antidepressants cause suicide or not.

 

      Test them right and find out the answers.  Thank

 

      you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker number

 

      34.

 

                MR. ROUTHIER:  I testified once already in

 

      February and I am not happy about having to do it

 

      again.  My beloved wife of 18 years went to her

 

      doctor sick with abdominal pains and was coerced

 

      into trying an unmarked sample of Wellbutrin.

 

      After a week of serious adverse reactions and

 

      insomnia, she shot herself.  She was never

 

      depressed, was a perfect wife and mother, and

 

                                                               347

 

      worked 25 years in the Department of Public

 

      Welfare.

 

                The product information guide, which she

 

      was not given, states patients treated with

 

      bupropion have experienced psychosis, but it is

 

      impossible to determine the extent of the risk.

 

      How can any benefit be worth the risk if risk is

 

      impossible to determine?  The list of side

 

      effects--psychosis, mania, hallucinations,

 

      insomnia, agitation, suicidal ideation, etc., etc.

 

                GlaxoSmithKline's answer is we told you

 

      so, and everyone knows the inherent dangers.

 

      Hundreds of cases were settled on Prozac alone a

 

      decade ago.  Two main ingredients are fluoride and

 

      hydrochloric acid, the most caustic, corrosive

 

      substances known.  These neurotoxins poison the

 

      brain, triggering adrenaline, masking symptoms.

 

      Nobody can know what it is to lose the most

 

      beautiful, intelligent, strong, loving, caring wife

 

      of 18 years, incredible mother of two boys that she

 

      adored, my soul-mate.  There was nothing ever wrong

 

      with her until these damned pills.  Which they want

 

                                                               348

 

      to question and deny?

 

                She left a legacy of love that was

 

      witnessed by hundreds as the most unselfish wife

 

      and mother, sister, daughter, friend, co-worker.

 

      She left me and two sons with a need for justice.

 

      We all know this stuff is dangerous.  Anyone

 

      denying this, especially anyone in a position to

 

      make a difference, in the face of such horrific

 

      testimonies is an enemy of humanity.

 

                After 18 amazing, wonderful years, at 40

 

      years old she became deathly ill for a week and

 

      then ended her pain.  One week after the first

 

      pill.  Then the autopsy found the gallstones.

 

      Guess what, don't take poison, toxic chemicals

 

      while having a gallbladder attack.  I absolutely

 

      worshiped her and everyone told us we had a rare

 

      love.  Even our middles names are Mary and Joseph.

 

      We were a match made in heaven.  We were ripped

 

      apart by a nightmare conspiracy no one could

 

      imagine.  My wife was murdered.

 

                How many settlements have silenced

 

      victims?  I don't care about any perceived benefit

 

                                                               349

 

      when this stuff kills people.  My wife was worth

 

      the risk?  Other victims here were?  Which ones?

 

      The FDA has to get off their ass and move on this,

 

      and make it clear it is children and adults.  Don't

 

      try to minimize the numbers by dividing groups.

 

      There is plenty of proof.  I call on everyone to

 

      carefully investigate every episode where a person

 

      on these drugs had uncharacteristic, uncontrolled

 

      violence or suicide.  I am aware of many.  Don't

 

      let them blame psychotic episodes on depression.

 

      Many are given these drugs for reasons other than

 

      depression, including my wife.

 

                Look at the studies, the NDAs, the

 

      MedWatch reports, the settlements, witnesses, read

 

      the side effects.  The body count is climbing and

 

      we are sick of the coverups.  The risks are too

 

      great to be...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker number 35?

 

                MS. MCBRIDE:  My name is Sharon McBride

 

      and I am a dental hygienist.  I am here as a mother

 

                                                               350

 

      and a friend--

 

                DR. GOODMAN:  Could you bring the

 

      microphone closer to you?

 

                MS. MCBRIDE:  Sorry.  I am here at my own

 

      expense as a mother and a friend.  I am here today

 

      to remind the committee of the serious suicide

 

      attempt of my then teenage daughter shortly after

 

      being prescribed the SSRI medication Zoloft.  After

 

      seven years on Paxil, she is still attempting to

 

      recover from the problems incurred from abruptly

 

      stopping that medication.

 

                I have only in the last three weeks

 

      learned of the higher suicide ideations of the

 

      other SSRI type medications that she has been

 

      prescribed.  Two days after beginning Seroquel, my

 

      daughter overdosed on that medication.  She denied

 

      suicide attempt but had no explanation for her

 

      action.  She continues to have difficulties more,

 

      in part, to the side effects of the medications and

 

      the devastation they have caused in her life.

 

                Liz Torklingson was a beautiful

 

      high-spirited young lady who was a purist and very

 

                                                               351

 

      careful about what she put into her body, only

 

      eating organic foods and no red meat.  She did

 

      suffer from a nagging depression and became, over

 

      time, convinced to try medication.  She took

 

      Serzone for a year but discontinued after hearing

 

      on the radio that it can cause long-term health

 

      problems.  Celexa was recommended as a healthier

 

      replacement.  Because of a bad cold, the dosages of

 

      Celexa were forgotten and Sudafed was taken.  Upon

 

      resuming the Celexa, she quietly walked into the

 

      subway, entered into the dark tunnel, sat down on

 

      the track and let the train run over her.  One week

 

      later came the FDA warnings about antidepressant

 

      medications but too late for Liz.

 

                This morning I received an email from my

 

      neighbor in Arizona about her 13 year-old daughter.

 

      Erica was never suicidal while on Paxil, although

 

      we had some of the worst incidents with her rages

 

      and meltdowns during the time that she was on

 

      Paxil.  She was literally uncontrolled about home

 

      school and church.  Teachers in school and church

 

      were not able to handle here.  At one point in

 

                                                               352

 

      school she had such a serious meltdown that the

 

      entire classroom had to be removed and the school

 

      officer was brought in to control the situation.

 

      Another time her behavior reached a point of

 

      kicking the teacher and aids resulting in her

 

      getting arrested.  These incidents led to her

 

      admittance into a behavior health center.  She was

 

      admitted twice within two months.

 

                This report is also similar to the report

 

      you heard from Todd Shivick about his 11 year-old

 

      son Michael.  Michael not only had these same type

 

      of rage behaviors but made four suicide attempts

 

      while on Paxil.  Now, one and a half years after

 

      discontinuing Paxil, Michael, now 14, has returned

 

      to a normal teenage life, participating in high

 

      school activities.

 

                I respectfully request that not only

 

      suicide ideation be investigated but also these

 

      personality and behavior changes in our children

 

      prescribed these SSRI medications.  This affects

 

      our homes, our society, our nation and our future.

 

      Thank you.

 

                                                               353

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 36, please.

 

                DR. BREGGIN:  I am Peter Breggin.  I am a

 

      psychiatrist without financial ties to the drug

 

      industry or anyone else.

 

                It is gratifying to see the FDA finally

 

      considering, after ten years, data that I produced

 

      in talking back to Prozac and since then in

 

      numerous books, medical articles, peer reviewed

 

      articles, including the one I have given the

 

      committee.  Some of my data comes from suits

 

      against the manufacturer in which I have been an

 

      expert.  I have been involved now in dozens of

 

      cases against the manufacturers and they have, for

 

      good reason, settled every single one.  In

 

      addition, a number of criminal cases have come out

 

      well for the defendants.

 

                Dr. Laughren knows that he is wrong about

 

      the absence of any suicide signal in adult cases.

 

      By a 6:1 ratio there were more suicide attempts on

 

      Prozac compared to imipramine and compared to

 

                                                               354

 

      placebo in all of the clinical trials used for the

 

      approval of Prozac.  Beasley, at Lilly, kept this

 

      data initially from the FDA but I disclosed it ten

 

      years ago, in 1994, in the Westecker case and it

 

      has since then been published numerous times.

 

                The Prozac data would have been much

 

      worse, as Dr. Laughren knows, if Lilly had not been

 

      illegally medicating its patients by actual memo

 

      from Ray Fuller to all of his principal

 

      investigators, empowering them to give

 

      tranquilizers against the protocol for these

 

      patients, also, if Lilly had not been hiding its

 

      adult suicide events in the coding items, innocuous

 

      items such as "no drug effect" in a suicide case.

 

      This kind of thing makes the collection of data, as

 

      done in the present cases today, just fraught with

 

      risks of fraud about coding because Lilly, we know

 

      for sure, has coded with absolute ability to hide

 

      their data and I found it by going through the

 

      files, which the FDA doesn't do.

 

                Again, in adults I have reanalyzed suicide

 

      data from other high profile SSRIs and found adult

 

                                                               355

 

      signals, but the data is sealed because the cases

 

      have been settled but the FDA hasn't empowered me

 

      to release that data or, in fact, ask for it.

 

                SSRIs cause suicide and violence in the

 

      early stages of treatment or during drug changes

 

      because of stimulation, euphemistically called

 

      activation.  It is an amphetamine- or cocaine-like

 

      effect, which the FDA has now recognized by putting

 

      out a list of agitation, hostility, anxiety,

 

      irritability, and so on, on its own website,

 

      symptoms wholly indistinguishable from

 

      methamphetamine or cocaine...

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker 37,

 

      kindly come forward.

 

                MR. ORR:  I cannot see my notes with the

 

      lights off.

 

                DR. GOODMAN:  Somebody may be leaning

 

      against the dimmer somewhere.  That was probably

 

      inadvertent.  We won't start you until we get the

 

      lights right.

 

                MR. ORR:  Thank you.  My name is Bruce

 

                                                               356

 

      Orr.  I have no financial ties to anyone.  I am

 

      from Charleston, South Carolina.  I am a former law

 

      enforcement officer, with approximately 20 years

 

      experience.  I am also a former director of a

 

      children's ministry.  I currently have a child in

 

      my life whose meds. were switched three times, in

 

      four months, with three suicide attempts.

 

                As a law enforcement officer, I spent a

 

      career combating illegal drugs and the influence

 

      that they had on our children.  As supervisor of

 

      the violent crimes and homicide division of my

 

      agency, I dealt with the aftermath of the

 

      unnecessary violence associated with these drugs.

 

      Times have changed.  There are still, and always

 

      will be, crimes related to street drugs, but more

 

      and more I am seeing a pattern of violence

 

      associated with the excessive use, sudden

 

      withdrawal from, or switching of antidepressants

 

      and, frankly, it is quite disturbing.

 

                While we sit in this air conditioned room,

 

      looking at pretty charts, cops like I was are

 

      dealing with the blood and gore accompanying these

 

                                                               357

 

      suicides.  Have you seen the aftermath of a

 

      suicide?  I have and I still do every night when I

 

      go to sleep.

 

                Our children are our hope and our

 

      investment in the future, and we sit here today

 

      hearing the cries of parents whose hope and future

 

      were destroyed by the very drugs they thought would

 

      help preserve it.

 

                As I stated earlier, I was a law

 

      enforcement officer and a children's church

 

      director.  I was a pretty easy-going person but in

 

      2002 I was placed on the antidepressant Paxil for

 

      post-traumatic stress disorder and major recurring

 

      depression.  Prior to that time I was awarded

 

      "Supervisor of the Month," in line for promotion,

 

      and had just received a medal for saving a life.

 

      After four months of horrible side effects, my

 

      doctor attempted to switch me from Paxil to Remeron

 

      and stopped abruptly in four days.  During severe

 

      withdrawal, I attempted suicide by overdosing and

 

      driving my truck into a parked car and shoving it

 

      through my home.  I was subsequently charged and

 

                                                               358

 

      eventually pled guilty to lesser charges, and now I

 

      am a convicted felon.  I guess you could say Paxil

 

      brought my career full circle, from cop to

 

      criminal.

 

                Two years ago, as a 38 year-old man, I

 

      wanted to die in withdrawal.  I recall laying on a

 

      friend's bathroom floor and begging him to kill me.

 

      When he didn't do it I tried to do it myself.  I

 

      cannot fathom what that must be like at 18, 15, 12

 

      or even 10 years of age.  The pain and mental

 

      anguish is unbearable.

 

                Something must be done about these drugs

 

      and the effects that they have on both children and

 

      adults.  If the drug companies withhold potentially

 

      life-threatening information just to turn a profit

 

      something must be done.  My family and my career

 

      were forever destroyed but at least I still have my

 

      life.  I never would have thought that a little

 

      pill, that ironically comes in little-girl pink for

 

      lower doses and baby-boy blue for larger doses,

 

      could alter my personality so drastically, but it

 

      did.  It is not worth another parent losing a child

 

                                                               359

 

      over or, in my case, children losing a parent over.

 

      This medication cost me a year of my children's

 

      lives but I have them back now.  I just wish that

 

      some of these parents could say the same thing.

 

      Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 38, come forward, please.

 

                MR. REED:  Good afternoon.  My name is

 

      Jerry Reed and I am the executive director of the

 

      Suicide Prevention Action Network, SPAN, U.S.A.

 

      Suicide claims the lives of over 4000 young people

 

      each year, making it the third leading cause of

 

      death for those between the ages of 10-24.  In 2003

 

      16.9 percent of high school students seriously

 

      considered attempting suicide, while 8.5 percent

 

      made an actual suicide attempt.

 

                Research shows that over 90 percent of

 

      children and adolescents who die by suicide have a

 

      mental disorder.  Among adults, psychotherapy and

 

      antidepressants are regarded as the most effective

 

      treatments for depression, but only limited

 

                                                               360

 

      research has been conducted on the efficacy of

 

      antidepressants in children and adolescents and the

 

      studies that have been conducted thus far have

 

      three major problems:  One, they have been too

 

      short in duration.  Two, they have excluded those

 

      at highest risk for suicide and, three, not all of

 

      them have been published.

 

                The limited evidence available and the

 

      shortcomings of the research conducted thus far

 

      underscore the need for continued and improved

 

      research.  Most suicide prevention is based on the

 

      principle that suicide is generally preceded by the

 

      signs and symptoms of a mental illness or other

 

      behavioral or emotional problem which can be

 

      treated.  If we are to continue screening young

 

      people, it is imperative that we have safe and

 

      effective treatments to provide to those identified

 

      at risk.

 

                Since most young people with a mental

 

      disorder to not receive mental health services,

 

      prematurely prohibiting the use of antidepressants

 

      for young people with depression, one of the most

 

                                                               361

 

      widespread treatment methods, may discourage a

 

      significant number of people from seeking out help

 

      and ultimately do more harm than good.

 

                As an organization comprised mostly of

 

      suicide survivors, we have heard the stories of

 

      mothers and fathers who sought out treatment for

 

      their children but were never educated about the

 

      risks associated with their loved one's condition

 

      or treatment.  In survivor suicide support groups

 

      nearly all parents who lost a child report if they

 

      had only known 30 days before the suicide what they

 

      knew 30 days after, their child's life might have

 

      been saved.

 

                The fact is that most young people

 

      receiving treatment for depression or other mental

 

      illnesses do not get services from the specialty

 

      mental health sector but, rather, from schools,

 

      primary care providers, child welfare services or

 

      juvenile justice facilities.  It is, therefore,

 

      essential that everyone prescribing antidepressants

 

      to youth know about the need for increased

 

      monitoring and vigilance, particularly during the

 

                                                               362

 

      first weeks of treatment.  All those involved with

 

      the treatment of children and adolescents with

 

      depression should be forewarned about the potential

 

      risks and may be informed as to what signs and

 

      symptoms are indicative of potentially serious

 

      problems.  Patient education is a proactive action

 

      that should be taken now.  It is the least we can

 

      do while the requisite research is pursued.

 

                Suicide has been a leading cause of death

 

      among young people for far too long.  Any concerns

 

      about the efficacy of antidepressants for treating

 

      young people with depression must be addressed

 

      immediately.  SPAN, U.S.A. represents people who

 

      know all too well the terrible tragedy of suicide.

 

      We must act now.  There are too many lives at

 

      risk...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 39, please come forward.

 

                MR. COFFIN:  Good afternoon.  My name is

 

      Chris Coffin.  I am with Pinley law firm in

 

      Plackman, Louisiana.  I am standing before you

 

                                                               363

 

      today in two separate roles, number one, I am an

 

      attorney who represents thousands of individuals

 

      whose lives have been negatively affected by the

 

      use of SSRIs.  Some of them are parents who have

 

      been misled about the safety and efficacy of these

 

      drugs.  Some of them are adults who have ingested

 

      the drugs and experienced suicidality or

 

      experienced severe debilitating withdrawal symptoms

 

      when they tried to reduce their dose or terminate

 

      the use of the drugs.

 

                The second role I am in here today as a

 

      healthcare professional.  I am also a practicing

 

      registered nurse.  I understand the risk/benefit

 

      analysis that goes along with treatment decisions.

 

      I understand what it means to be a provider who is

 

      passionate about the care, in this case, of his

 

      patients.

 

                For the sake of my clients, my patients

 

      and for the sake of our colleagues as healthcare

 

      providers, I come to you with three requests today.

 

                Number one, take further action.

 

      Contraindicate the use of SSRI drugs in children. 

 

                                                               364

 

      I understand that you want to be thoughtful and

 

      careful in your analyses.  I understand that you

 

      want to consider all angles.  At this point,

 

      however, we now have the benefit of the analysis

 

      done by British regulators, by Dr. Mosholder and by

 

      the Columbia University group.  Although the data

 

      is not absolutely perfect because it was not always

 

      looking at suicidality, we do know that the risk

 

      outweighs the benefit.  That seems very clear.

 

                The second request I have to you is to dig

 

      deeper.  By dig deeper, I mean to look deeper into

 

      the data.  Look further, beyond just the pediatric

 

      issues.  Realize that there is far more data in the

 

      halls of the pharmaceutical companies than has been

 

      presented to you.  Because of litigation, my legal

 

      colleagues and I have been able to look at that

 

      information and I think if you look you will find

 

      an abundance of information that will further

 

      educate you about the debilitating risks of these

 

      drugs.  Do not trust and do not be misled by the

 

      pharmaceutical companies.  Whether you take my

 

      position or anybody's position in this room, you

 

                                                               365

 

      owe it to the American people to look further into

 

      the information that the drug companies have within

 

      their houses.

 

                The third request I have of you today has

 

      been made by many others, and that is to educate.

 

      From a healthcare provider's standpoint, I ask that

 

      you go beyond the regular minimal requirements that

 

      FDA imposes on drug companies.  Force the drug

 

      companies to provide better education on SSRI drugs

 

      for children and adults.  You will prevent serious

 

      injury in the future if you do so.  Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 40, please come forward.

 

                MS. ERBER:  Hi.  I am Alice Erber and this

 

      is my family, Robert, Talia and Rachel Steinberg.

 

      We live in Palo Alto, California.  My son, Jacob

 

      Steinberg, died last year, on Wednesday, July 23,

 

      after being on Paxil for about a month.  He was 20

 

      years old.  Jake was going to be a senior at

 

      college.  He played the piano, sang in the glee

 

      club, was the entertainment editor of the school

 

                                                               366

 

      newspaper.  He was involved with student

 

      government.  He was a great kid, so full of life.

 

      He loved music, films and had many friends.

 

                In mid-June, Jake went to see an

 

      internist, whom he had never seen before, to get a

 

      referral for a hand specialist because his hands

 

      were sore from playing the piano.  The internist

 

      who saw him for 30 minutes prescribed Paxil because

 

      he bit his fingernails and the doctor thought it

 

      might help with that.  Jake had been taking

 

      Wellbutrin for anxiety and mild depression for

 

      about six months.  He was doing fine on Wellbutrin.

 

      The internist told him that it was okay to take the

 

      Paxil with the Wellbutrin.

 

                Jake had begun a six-week internship in

 

      New York City in June and he was not going to be

 

      supervised by a doctor.  He went on a trip with my

 

      husband to Israel for two weeks in July, and felt

 

      sick and had diarrhea.  My husband was concerned.

 

      I talked to Jake on Saturday before he died.  He

 

      told me he was staying up late; he wasn't sleeping.

 

      He left me a great phone message on the day that he

 

                                                               367

 

      died.  In the morning he sounded fine.  He talked

 

      to his sister at lunchtime and they had a good

 

      talk, but before he hung up he complained to her

 

      that his stomach hurt.  Then, on that afternoon, on

 

      Wednesday, July 23, we found out that he killed

 

      himself.

 

                They said at work he started acting

 

      bizarre.  He started having erratic behavior and he

 

      ran through the building, throwing his clothes off

 

      and fighting the office security guard, and ending

 

      up throwing a chair through a window and jumping to

 

      his death from the 24th floor of a Manhattan office

 

      building.  What a horrible way to die.

 

                We went to get his body the next day and

 

      the detective said he found two empty bottles of

 

      Paxil and Wellbutrin.  When the autopsy report came

 

      back it showed that there was Paxil and Wellbutrin

 

      in Jake's body but not in overdose, just a regular

 

      amount.  We are sure that the Paxil caused his

 

      death.  He had the symptoms of akathisia.  We also

 

      think Paxil and Wellbutrin may have created a manic

 

      psychotic episode.

 

                                                               368

 

                We want to tell our story to make sure

 

      that if he had not taken Paxil he would be alive

 

      today.  The public and the doctors need to know

 

      these suicides in young people.  Tomorrow is Jake's

 

      birthday.  He would be 22 years old.  We are here

 

      in his memory, making sure this does not happen

 

      again.  He was impulsive and out of character.  We

 

      know he did not want...

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Sorry for your

 

      loss.  Speaker 41, please.

 

                MS. WEBB:  I am here because three years

 

      ago my daughter was suffering some symptoms that

 

      the doctor felt represented depression and started

 

      her on samples of Paxil.  I trusted this decision

 

      as a mother and based on my medical background as a

 

      registered nurse.

 

                Unfortunately, she did have an obvious

 

      worsening of symptoms.  Were we aware that the

 

      antidepressant could be the cause of this?  No, we

 

      were not.  I am here because I agree that the FDA

 

      needs to require further studies to be done to see

 

                                                               369

 

      if it is true that certain antidepressants increase

 

      the risk of suicidality.

 

                When I learned that I would have the

 

      opportunity to speak before this committee I wasn't

 

      sure what I would say.  So, I replayed an audiotape

 

      of a confrontation with my then 17 year-old

 

      daughter during the time she was taking these

 

      antidepressants.  We could not believe the changes

 

      we saw in our daughter in the very short time she

 

      had started on the antidepressants.  It was

 

      unbelievable--the rage, anger, the hostility she

 

      exhibited that night.  She ended the night by

 

      cutting her wrist.  Now I am learning that the

 

      changes we saw in our daughter, more likely than

 

      not, were the side effects of the antidepressant

 

      she was taking at the time.

 

                Yes, we did report a worsening of symptoms

 

      shortly after she started the Paxil.  The doctors

 

      only changed her to another antidepressant, Zoloft.

 

      She then continued to worsen and they continued to

 

      increase the dosage until she began to further harm

 

      herself with self-mutilation, cutting, overdose,

 

                                                               370

 

      numerous things.  We were fortunate to get her help

 

      in the right environment with counselors who spent

 

      many hours with the children.  She was taken off of

 

      the strong antidepressants and, within a short time

 

      none of the staff could believe she had done while

 

      she had been on Paxil and Zoloft.  She continued

 

      there, getting counseling, and returned as the

 

      child we knew before she took these

 

      antidepressants.

 

                Why did we not know about these adverse

 

      side effects that are now being reported in

 

      children?  Was it possible the drug companies may

 

      have been aware of these adverse side effect?  If

 

      we had known, I believe it is possible that maybe

 

      my daughter and our family would not have had to go

 

      through the agony and heartache we went through.

 

                My daughter is hearing impaired and has a

 

      cochlear implant, and has worked hard all her life

 

      to overcome the stigma of being hearing impaired

 

      and deaf.  It has been hard but she has always had

 

      a positive attitude.  Now we are sad but also find

 

      relief in telling her that what she went through

 

                                                               371

 

      could have been prevented if the drug companies had

 

      made public these adverse side effects.  Yes,

 

      relief but, unfortunately, too late.  She now has

 

      to endure the stigma that mental illness brings to

 

      those who suffer it.  Luckily, she has shown her

 

      determination to overcome this, as she did her

 

      hearing loss.  She is now a junior in college and

 

      doing great.  Her determination has brought her

 

      through many obstacles but this was one she should

 

      not have had to battle.

 

                Guidelines for the use of antidepressants

 

      in children should be reevaluated and studies done

 

      to determine which, if any, are safe for use in

 

      children.  Thank God, we were able to get my

 

      daughter help before it was too late.  I am sure

 

      there are many more children who did not get that

 

      help and may have succeeded in their suicide

 

      attempts.  Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker 42,

 

      please.

 

                MR. WITZCAK:  My name is Chester Witzcak. 

 

                                                               372

 

      I am a resident of York, Pennsylvania, and I have

 

      no financial relationship with the FDA, drug

 

      companies or any advocacy group.  I am attending

 

      this hearing at my own expense.

 

                On August 6th, 3002 my oldest son,

 

      Timothy, died of a Zoloft-induced suicide at age

 

      37.  He died after taking the drug a total of five

 

      weeks.  It was prescribed for insomnia.

 

                How did this happen?  Zoloft was

 

      prescribed off-label and there was no information

 

      regarding Zoloft's serious side effects with the

 

      Zoloft samples given to him by his physician.  Why

 

      did this happen?  Soon after SSRIs were introduced

 

      the drug companies began a campaign to establish

 

      that they were effective treatment for other

 

      diseases although there was no clinical basis for

 

      this, and none of the serious side effects were

 

      discussed or highlighted in the literature or on

 

      the labels.

 

                Today these drugs are prescribed for a

 

      long list of ills.  Physicians and patients are

 

      using it for just about anything except hangnails

 

                                                               373

 

      despite the fact that SSRIs are only approved to

 

      treat a few conditions.  In 1997 FDA added a major

 

      weapon to the drug company arsenal,

 

      direct-to-consumer advertising.  FDA issued

 

      guidelines that allowed drug companies to air

 

      broadcasts and print advertisements that contained

 

      minimal information about a drug's possible side

 

      effects.  The United States is the only

 

      industrialized nation that allows

 

      direct-to-consumer advertising to the public.

 

      Other countries consider the practice to be

 

      unethical.

 

                How effective are these SSRI drugs really?

 

      At present, drug companies not only plan and pay

 

      for the trials of their own drugs, but also analyze

 

      and publish the results.  This conflict of interest

 

      has introduced a bias into the testing since drug

 

      companies suppress test results they don't like

 

      when drug companies show that the drug isn't more

 

      effective than a placebo, a sugar pill or, said

 

      another way, better than nothing.  That is a very

 

      low hurdle.

 

                                                               374

 

                What is needed?  We need warnings for all

 

      patients, not just juveniles being prescribed SSRI

 

      drugs, informing them of the serious side effects.

 

      Families and spouses must be warned as well to

 

      allow them to be aware and to watch for the signs

 

      for these serious adverse reactions.  We need this

 

      now, not more studies or hearings.  We need to

 

      eliminate the direct-to-consumer advertising.  You

 

      authorized it.  Stop it now.  Eliminate the

 

      off-label use of drugs.

 

                If a drug is to be used for a particular

 

      treatment, require that it is more effective than

 

      existing treatments, with real clinical tests not

 

      based on a journal article hyped by the drug

 

      companies.  Establish a truly independent drug

 

      testing agency.  We can't go on with the fox in the

 

      henhouse situation we currently employ.  Without

 

      the positive actions I have indicated the FDA will

 

      continue to be a co-conspirator in the assault of

 

      the public, with the SSRI drug-induced violence and

 

      suicide.  Thank you.

 

                [Applause]

 

                                                               375

 

                DR. GOODMAN:  Thank you.  Is speaker 43

 

      present?  If speaker 43 is not present, then

 

      speaker 44.

 

                MS. PARKER:  My name is Nancy Parker, and

 

      I am a mother of a 12 year-old African-American

 

      girl, Rebecca, whom I adopted at the age of three

 

      weeks.  I am also a member of NAMI, NYC Metro.

 

                First of all, I want to say my heart goes

 

      out to everyone here who has lost a loved one, but

 

      I am here to tell a very different story.  My

 

      daughter has suffered from severe mental illness

 

      for the past seven years.  Her present diagnosis is

 

      depression with psychosis NOS.  She is presently on

 

      a regimen of 800 mg of Seroquel, a milligram of

 

      Haldol and 225 mg of Wellbutrin.

 

                At the age of five and a half, Rebecca had

 

      her first episode.  I was cleaning up a glass that

 

      had suddenly broken when she ran in, appearing to

 

      be in something of a trance, picked up what I

 

      assumed was a small piece of glass and swallowed

 

      it--her first attempt at trying to hurt herself.

 

      She was then in therapy and had her first

 

                                                               376

 

      hospitalization where she was given a diagnosis of

 

      bipolar disorder.

 

                So, a little girl comes home on depakote

 

      and after a week she has another episode, and when

 

      I think she may be gaining control she comes up

 

      behind me and clocks me over the head with a big

 

      toy hair dryer.  We both wound up in the ER and

 

      when the doctor asked her, "why did you hit your

 

      mom over the head?" she replied flatly, "because I

 

      had to."  At this point her doctors concurred it is

 

      very likely that Rebecca is not bipolar.  Now there

 

      is no diagnosis so the doctors tell me if she acts

 

      up just give her Benadryl.

 

                She left the hospital and was seeing a

 

      therapist regularly, and in September of 1999 she

 

      began hearing voices.  At this point, her therapist

 

      and psychiatrist put her on the first of many

 

      antipsychotics, Risperdal.  While this was going on

 

      her behavior became very self-injurious.  One

 

      impulse was she would walk out in front of cars.

 

      When I told her she could get killed, she answered,

 

      "maybe I wanted to."  She would bang her head on

 

                                                               377

 

      the wall and tell me how she wanted to die and be

 

      with her grandma in heaven.

 

                For Rebecca, the time between ages 5-12

 

      meant five hospitalizations and one year in

 

      residence.  She has been on everything from

 

      Risperdal, olonzapine and BuSpar.  While in the

 

      hospital, they put her on lithium and then took her

 

      off for three days because she became violently

 

      ill.  When she was in residence they started

 

      Rebecca on a low dose of Risperdal and Wellbutrin.

 

      While that helped somewhat, it was not the perfect

 

      mix.  Finally they tried Serecol [?] with

 

      Wellbutrin.  There were some difficult times there

 

      but they had upped the Serecol and Wellbutrin to

 

      her present dose.

 

                Presently, she has been on Wellbutrin and

 

      does not hear any voices.  She has not had any

 

      hospitalization and is relatively happier now and

 

      there is no impulse to hurt herself.

 

                I just want to say that we have to have

 

      clinical trials for these children.  They must be

 

      started at a low dose and if there is any problem

 

                                                               378

 

      the doctors have to be told that these kids, if

 

      they are not working out on these particular drugs,

 

      have to be taken off the drugs.  Or, if it is a

 

      cocktail, as in my daughter's case, maybe the

 

      cocktail has to be stopped.  Finally...

 

                DR. GOODMAN:  Thank you.  Speaker 45,

 

      please.

 

                MR. SCHNEEBERG:  Yes, my name is Richard

 

      Schneeberg and I have a masters in counseling.

 

      Between 1997 and 2000 a person is given 14

 

      different types of antidepressants on eight

 

      hospital stays.  During one of the stays he tries

 

      to jump out of a hospital window.  After another

 

      hospital stay he is found walking on the railroad

 

      tracks, and when he is brought to the hospital he

 

      is a catatonic zombie.  He can't speak and he is in

 

      a fetal position, rubbing his knees together.

 

      After another hospital stay the person has a

 

      delusion of murder.  After yet another hospital

 

      stay this very same person makes a threat to burn

 

      down a hotel.  He is brought to a hospital and

 

      starts having hallucinations after being medicated

 

                                                               379

 

      again.

 

                The common thread in all of these bizarre

 

      actions, including suicide, is that none of them

 

      ever occurred before this person was given

 

      antidepressants.  The focus of this conference is

 

      on children, however, the person who I refer to is

 

      not a child.  It was me, a man, then in his late

 

      40s.

 

                England has banned all antidepressants for

 

      kids except Prozac.  Let's have an American

 

      revolution and ban antidepressants for everyone and

 

      prevent many suicides.

 

                All of the above is documented in my

 

      autobiography, "Legally Drugged," being produced

 

      and published soon, and will be produced as a

 

      motion picture.

 

      Excerpts from the hospital reports will be in the

 

      book, where the psychiatrists themselves state they

 

      were worsening my condition.  Counseling only, no

 

      drugs.  Antidepressants, weapons of mass

 

      destruction.

 

                [Applause]

 

                                                               380

 

                DR. GOODMAN:  Thank you.  Speaker 46,

 

      please.

 

                DR. RISINGER:  I am David Risinger and

 

      this is my wife, Sarah.  I have no financial ties.

 

                Next slide.  This is my 15 year-old son,

 

      Josh.

 

                Next five slides.  All these pictures were

 

      taken about a year ago before Josh started

 

      antidepressants.

 

                Next slide.  See that smile?  Suicidal?

 

      No way!

 

                Next slide.  Not that he didn't have

 

      problems.  He had been seeing a psychologist who

 

      thought an antidepressant might help.

 

                Next slide.  This is Josh before Zoloft.

 

      He was popular, athletic, had a girl friend, was

 

      making plans.  He had hope and enjoyed life.

 

                Next slide.  Twelve tablets later he was

 

      gone.

 

                Next slide.  Three times in those 12 days

 

      I talked to his doctors to tell them that he wasn't

 

      doing well; to tell them that he couldn't sleep at

 

                                                               381

 

      all; that he seemed agitated.  He cried out to us

 

      that this medicine was making him worse.  I was

 

      told, "give it time; these take a couple of weeks

 

      to work."  Twelve days.  None of us recognized the

 

      danger he was in because none of us had adequately

 

      been warned.

 

                Next slide.  The first I ever heard of

 

      this controversy was this article that ran shortly

 

      after Josh's funeral.

 

                Next slide.  There is certainly no mention

 

      of it in any of the product literature.

 

                Next slide.  The reason I come to you

 

      today is to caution don't rely only on the clinical

 

      trials data to base your recommendations.

 

                Next slide.  I would like to give an

 

      example from my practice, and that is x-ray

 

      contrast media.

 

                Next slide.  Doctors and patients are

 

      warned of the risks of these drugs.

 

                Next slide.  Specialized training and

 

      preparation are required to use these drugs.

 

                Next slide.  And many lives have been

 

                                                               382

 

      saved to reactions that never happened in any of

 

      the clinical trials, reactions that most of my

 

      younger colleagues have never seen and would never

 

      believe until they saw their first case, and by

 

      then it would be too late.

 

                Next slide.  But I know this happens.  I

 

      have seen it.

 

                Next slide.  I know this happens too.  I

 

      have seen it, and I am here to tell you.

 

                Next slide.  Don't rely only on the

 

      clinical trial data.  I think what you are looking

 

      for maybe too rare to find there.

 

                Next slide.  But just because it is rare

 

      doesn't mean it isn't important.  There are

 

      millions of people on these drugs.  Thousands of

 

      lives literally are at risk.  What do we do?  I

 

      would like to give an example from my practice.  To

 

      interpret mammograms, every three years I have to

 

      get 15 hours of CME.  Why can't we do something

 

      like this with these drugs?  Every prescriber

 

      should be required to periodically pass a mandatory

 

      certification in psychopharmacology.  Surely this

 

                                                               383

 

      committee would find this tool useful for keeping

 

      clinicians up to date, and the time is long overdue

 

      for effective warnings on the drug label, in the

 

      package insert, and in all advertisements.  This

 

      can't wait any longer or it will be too late.

 

                Next three slides.  For Josh and many

 

      others it is already too late.  Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 47, please.

 

                DR. HEALY:  Ladies and gentlemen, I am

 

      here and have paid all my own costs to be here.

 

      This meeting you are having is more than about a

 

      crisis about one drug-induced side effect; this is

 

      a crisis for evidence-based medicine that has

 

      enabled the FDA and the companies to state openly

 

      and repeatedly that there is no credible evidence

 

      that there is a link between SSRIs and suicide when

 

      this is scientifically quite wrong.

 

                There have been 677 trials involving

 

      SSRIs, and having helped review all of these, I can

 

      let you know that roughly only 1/4 suicidal acts

 

                                                               384

 

      that have happened in these trials have been

 

      reported in the scientific articles that have come

 

      out of those trials.  Nevertheless, when you

 

      combine all of the trials year on year, as of 1988,

 

      the odds ratio that SSRIs are associated with

 

      suicide over placebo over double the rate is there

 

      from '88 onwards, and for each year onwards.  The

 

      odds ratio without risk of getting well in these

 

      drugs is actually much less.  It is only half of

 

      the odds ratio of picking up a suicide.

 

                The original Paxil suicide figures that

 

      SmithKline submitted to the FDA, in '89, showed an

 

      eight times greater risk of suicide on Paxil for

 

      adults than for the same suicidal acts on placebo.

 

      Telling SmithKline that FDA believed concerns about

 

      suicidality were a public relations first, Martin

 

      Brecker, of FDA, invited them to resubmit their

 

      figures.  SmithKline did so and in the process

 

      re-coded as placebo suicides and suicidal acts acts

 

      that had not happened on placebo.  They were only

 

      doing what Lilly and Pfizer had also done.

 

                In contrast, FDA, when faced with

 

                                                               385

 

      debatable evidence that the SSRIs worked, had a

 

      completely different approach.  Such as the volume

 

      of negative studies that people within the FDA

 

      suggested to Bob Temple that the label for these

 

      drugs should include some indication of how many

 

      negative studies there were.  Martin Brecker, in

 

      the case of Zoloft, where two of the tree trials

 

      back then when the drug came to FDA first were

 

      actually negative, and still are negative, said he

 

      would be embarrassed to be associated with this

 

      portfolio.  FDA, Dr. Temple, chose not to write

 

      into the labeling the number of negative studies

 

      there had been. In the light of what has happened

 

      with Elliott Spitzer, who characterized such

 

      behavior as close to fraud, it may be time to

 

      revisit this choice.

 

                Having said this, I think FDA made the

 

      right choice to approve Zoloft and other SSRIs.

 

      But there is a sauce for the goose and a sauce for

 

      the gander issue here.  The best estimate we have

 

      of suicide on these drugs is 2.4 times greater.  In

 

      the Paxil OCD trials the best estimate we have...

 

                                                               386

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.  Is

 

      speaker 48 here?  You are speaker 49?

 

                MS. WAINSCOTT:  Yes.  I am chair of the

 

      National Mental Health Association.  I am an unpaid

 

      volunteer and I am family member.

 

                Depression itself creates a significant

 

      risk for suicide and we have known for a long time

 

      that as a person emerges from the black hole that

 

      is severe depression, there is a risk that they

 

      will marshall the strength to act on the suicidal

 

      thoughts that often accompany this illness.  I saw

 

      this happen two times to my mother as she bravely

 

      struggled with depression for almost half a century

 

      without the benefit of today's treatment advances.

 

                Today, because the topic of suicide is

 

      uncomfortable for many, because insurance plans

 

      limit visits and often flatly deny psychotherapy,

 

      because practitioners are very time pressed and

 

      sometimes they are wrong, kids are often not

 

      adequately monitored after they receive medication,

 

      and parents often are not told what to look for to

 

                                                               387

 

      protect their children.  There are heart-breaking

 

      stories of the consequences.

 

                But I came to tell you a success story.

 

      As a young child Jessica was sunny and cheerful,

 

      loving, affectionate.  Then, as she turned 11 it

 

      was clear that something was very wrong.  She was

 

      suddenly crabby, difficult to get along with.  She

 

      became moody and withdrawn.  Jessica's father

 

      approached her directly, "you have to tell us

 

      what's the matter."  She replied, "I have been

 

      telling you."  "No," he said, "you have just been

 

      going away."  After a long silence Jessica said, "I

 

      don't know, Dad.  It just seems like I'm mad all

 

      the time."  As the words tumbled out and she

 

      described her pain he realized she needed

 

      professional help.

 

                She was diagnosed with depression and

 

      together she, her family, their pediatrician and a

 

      consulting psychiatrist developed a comprehensive

 

      treatment plan that included SSRI medication with

 

      close monitoring.

 

                I am happy to tell you, and I want to show

 

                                                               388

 

      you a picture, that my granddaughter is doing

 

      extremely well.  She is the tall one.  She is an

 

      outgoing, happy 15 year-old, engaged in her family,

 

      successful at school.  She has a lively group of

 

      friends and is displaying a real talent for art.

 

      She sticks to her treatment regime and she still

 

      takes medication.

 

                As I prepared this testimony I talked with

 

      Jessie about it.  She told me, "Babi, tell them not

 

      to do anything that will make people afraid to go

 

      for help.  Life is so much better with treatment."

 

      I asked her how it is better and she said, "I'm

 

      just able to be myself.  There are no invisible

 

      strings pulling me down."

 

                So, I ask you for Jessica and for the

 

      millions of kids like her who do and will struggle

 

      with depression balance the risk of medication with

 

      the risks of untreated depression.  Help tear down

 

      the barriers to treatment.  Don't erect new ones.

 

      Address the issues in the broadest possible

 

      context.  Be mindful of the many children like

 

      Jessie who benefit from these medications and the

 

                                                               389

 

      hundreds of thousands who need treatment and get

 

      nothing.

 

                The written testimony of the National

 

      Mental Health Association, which you have, makes

 

      specific recommendations.  We support the call for

 

      closer monitoring of...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 51, please come to the podium.

 

                MS. GRUDER:  My name is Deborah Gruder.

 

      My husband, Scott, was never diagnosed, ever, with

 

      depression but on March 30th, the morning of March

 

      30th, after being on Paxil for 13 days--13 days

 

      only--he went to Walmart at 7:16 a.m. and bought a

 

      shotgun and returned to his office and locked the

 

      door and shot himself.

 

                Neither he nor I had any idea that there

 

      was any need to beware.  We were never told we

 

      should beware.  We knew people who had been on

 

      Paxil or other SSRIs and we had seen many of them

 

      benefit, and we had seen the numerous television

 

      commercials that showed people that were in very

 

                                                               390

 

      desperate psychological trouble, after taking

 

      SSRIs, all of a sudden they were dancing through

 

      fields of flowers; they were laughing; they were

 

      happy.  This is what we knew.  We didn't know there

 

      was anything to be concerned about.  Not once--not

 

      once did we ever see in any of these

 

      commercials--we never-ever saw a follow-up of

 

      anyone stepping off of a bridge into the icy waters

 

      of a river to their death.  We never saw a woman

 

      lock herself behind her bathroom doors and slice

 

      herself up with scissors.  We never saw anyone take

 

      a gun and go behind closed doors and shoot

 

      themself.

 

                My husband and I did not once hear about

 

      the subpopulation of people, which evidently he

 

      belonged to, that had a very adverse reaction to

 

      Paxil and other SSRIs.  Early this year I

 

      understand, and for the past 10-15 years you have

 

      been aware that there is a problem with SSRIs.

 

      Shame on you!  Shame on you for being aware when

 

      you should be protecting us, the people, all these

 

      people sitting behind me!  My story is not unlike

 

                                                               391

 

      theirs.  You should be protecting us.  Where were

 

      you?  Where have you been?  Why haven't you done

 

      anything about this?  This is just a small

 

      percentage of people that have had a loved one die

 

      violently because you have not done your job...

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker 52,

 

      please.

 

                MS. GUARDINO:  My name is Mary Guardino

 

      and I am the founder and executive director of

 

      Freedom from Fear, a national mental illness

 

      advocacy organization, and someone who suffers from

 

      anxiety and depression.

 

                I want to thank the committee and all

 

      those who have participated in the process of

 

      gathering and sharing information related to this

 

      very important issue.  As a mother and mental

 

      health advocate for the past 20 years, nothing has

 

      been more important to me than the health and

 

      safety of our children.

 

                My own depression and anxiety began when I

 

      was very young.  Most tragically, it was not until

 

                                                               392

 

      I was 40 years old that I received a proper

 

      diagnosis and successful treatment.  I was one of

 

      the lucky folks back in 1982 because my treatment

 

      combined medication and cognitive behavior therapy.

 

      That treatment brought me from the darkness of

 

      despair into the sunshine of hope.  I have never

 

      forgotten those dark, long, painful days.  They

 

      continue to motivate me in my work as an advocate

 

      for those struggling with mental illnesses and the

 

      family and friends who love and care for them.

 

                When my own children showed signs of

 

      anxiety and depression, fortunately, I was better

 

      prepared to find the treatment they needed.  I

 

      truly believe that my daughter would not have been

 

      able to complete law school nor my son complete a

 

      masters in psychological counseling if it were not

 

      for the early intervention and successful

 

      treatments of their illnesses.

 

                What also is important is that their

 

      positive experience with treatment has taught them

 

      to trust the mental health network and to utilize

 

      it with confidence when it is needed.  Their proper

 

                                                               393

 

      treatment has increased their resilience and

 

      empowered them to help others.

 

                In closing, I want to remind the committee

 

      to never lose sight of the goal all of us here so

 

      passionately strive for, that is, to improve the

 

      mental health status of all our citizens.  To

 

      achieve that, we must encourage people in need of

 

      help to seek treatment and provide consumers and

 

      providers with access to the latest scientifically

 

      valid data and information on the best treatment

 

      options.  If we fail in either of these endeavors,

 

      we will not be achieving the goal we all aspire to.

 

      Thank you.

 

                DR. GOODMAN:  Thank you.  Speaker 53,

 

      please.

 

                MS. WILLIAMS:  I am here representing

 

      Jacob Williams who died of Prozac-induced suicide,

 

      December 5th of 2000.  I was here last February.

 

      Therefore, I will give a brief synopsis of my

 

      previous statement and add a few additional

 

      comments that I feel are pertinent.

 

                My son, Jacob Williams, was born on

 

                                                               394

 

      October 15th, 1986.  On October 11th of 2000,

 

      Jacob's pediatrician prescribed him Prozac.  It was

 

      to be increased to 20 mg if there were no side

 

      effects.  The doctor did not describe to us what

 

      side effects we were to look for.  I assumed the

 

      prescription insert would indicate all side effects

 

      related to this drug.  I was wrong.  My husband

 

      asked the doctor if Jacob's problem could be

 

      hormonal, and did Jacob have to be put on

 

      medication.  The doctor replied that this

 

      medication would help him because it is the most

 

      commonly prescribed drug for teenagers to help them

 

      with their needs.

 

                On November 6th, 2000 Jacob was back in

 

      the doctor's office for a follow-up visit.  At this

 

      time his dose was increased to 20 mg.  This was

 

      Jacob's last visit to the doctor.  Shortly after

 

      this visit I began to notice an aggressive behavior

 

      in Jacob which had not been there before.  He also

 

      showed a verbal aggression and short temper that

 

      had not been present before.  When questioned about

 

      this behavior he stated, "I don't know what's

 

                                                               395

 

      making me do this."  On December 5th of 2000 I

 

      found Jacob hanging from the rafter in our attic.

 

                During the time Jacob was on Prozac, he

 

      went to a psychologist on several occasions.  The

 

      psychologist asked Jacob on these occasions whether

 

      he thought about suicide.  He responded that he

 

      would never do such a think because it was against

 

      his religion.  My sole purpose in being here today

 

      is to, hopefully, prevent other parents from having

 

      to go through the pain and anguish our family has

 

      gone through.  Had I known suicide was a possible

 

      side effect to this medication I never would have

 

      allowed my son to take it.

 

                I appreciate the action that has been

 

      taken since the last hearing.  However, I am

 

      concerned that many are still saying Prozac is a

 

      safe SSRI.  It is not safe.  Since my last

 

      appearance before you I have heard statements from

 

      others who survived their encounters with SSRIs,

 

      specifically Prozac.  My son cannot speak for

 

      himself since he did not survive, and it is my

 

      responsibility as his mother to speak for him.  It

 

                                                               396

 

      is my firm belief that his death was a

 

      Prozac-induced suicide.

 

                In conclusion, Jacob trusted me.  I

 

      trusted the doctor and the doctor trusted the FDA

 

      to make sure the drugs that are approved are safe

 

      and have proper warning labels.  I plead with you

 

      to live up to the trust our society has placed in

 

      you.  Thank you.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.  Is

 

      speaker 54 here?  If not, speaker 55, please come

 

      forward.

 

                MS. YORKE:  Good afternoon.  My name is

 

      Laurie Yorke and I am here on my own accord.

 

                Seven months ago I stood in my living room

 

      and watched my 16 year-old son slash his wrists in

 

      a full-blown Paxil-induced rage, screaming, "I was

 

      born to die."  I am one of the lucky ones.  My son

 

      is alive.

 

                The process of weaning and withdrawal

 

      began without the help of my son's prescribing

 

      psychiatrist.  He had refused to take my son back

 

                                                               397

 

      as a patient after the suicide attempt.  It was an

 

      Internet message for the Paxil survivors that

 

      walked me through the withdrawal process.  With

 

      each lowered dose, my son experienced the anger,

 

      aggression, brain zaps, visual disturbances and

 

      insomnia.  His withdrawal symptoms followed

 

      stunningly similar patterns that others have

 

      experienced.  He took his last dose of Paxil at the

 

      end of April.

 

                Prior to my son being prescribed Paxil for

 

      a single panic attack I did the research on this

 

      drug.  As a nurse of 20 years, I am probably in the

 

      minority because I do read drug inserts.  I do read

 

      the PDR.  I do ask questions.  When I questioned

 

      his psychiatrist about the use of an SSRI in a

 

      child his age, I was reassured by this adolescent

 

      psychiatrist that he has never had a problem with

 

      it before.

 

                Paxil turned my child, in a period of 13

 

      months, from an A/B student, social, outgoing

 

      personality like you would not believe into an

 

      angry, death-obsessed, anti-social recluse.  My

 

                                                               398

 

      son, now off Paxil, is once again happy, outgoing,

 

      socially active.  What he must now deal with is the

 

      lack of concentration still existing after the

 

      Paxil withdrawal.  I shudder to think of what the

 

      long-term ramifications of Paxil use will be in his

 

      case.

 

                The FDA's lack of action on the evidence

 

      presented years ago caused my son to become a

 

      victim of Paxil.  The FDA chose not to act on

 

      information you received that documented these

 

      reactions in clinical trials.  GlaxoSmithKline

 

      chose to hide clinical trial data to protect

 

      profits instead or protecting our children.

 

      GlaxoSmithKline said on "World News Tonight" that

 

      they gave the information to those who needed to

 

      know.  I am responsible for my child.  I spend 24

 

      hours a day with him.  I needed to know.  I was not

 

      told.

 

                Delaying banning of SSRIs for children

 

      means more children will die and the violent

 

      behavior will continue.  You have failed to protect

 

      our children from a bad drug.  I was under the

 

                                                               399

 

      impression that FDA approval meant that drugs

 

      actually went through a rigorous investigation

 

      prior to their being approved for safety.  I know

 

      that the FDA approval now means nothing.  Drug

 

      companies are allowed to pick and choose the

 

      clinical trials that they like.  You rubber-stamp

 

      the approval and allow the children of the United

 

      States to become the guinea pigs.  I believe the

 

      FDA has forgotten the Hippocratic oath, the basic

 

      that we all must adhere to, first do no harm.

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 56, please.

 

                MR. FRITZ:  I told the story of my 15

 

      year-old daughter, Stephanie, last February 2nd.

 

      She was on Zoloft and hung herself on November

 

      11th.

 

                DR. GOODMAN:  Can you start over and bring

 

      the microphone closer?

 

                MR. FRITZ:  Sure.  I told the story of my

 

      15 year-old daughter, Stephanie, on February 2nd

 

      here.  She was on Zoloft and hung herself on

 

                                                               400

 

      November 11th.  I attended the congressional

 

      hearing last Thursday at which Dr. Woodcock

 

      testified that the FDA had clinical information

 

      that showed that these antidepressants were not

 

      effective in treating children; that they caused an

 

      increase in suicidal thoughts.  Some of these

 

      trials are years old so the FDA has had knowledge

 

      and decided not to share this information with

 

      parents so that they could make informed decisions

 

      on how to care for their children.

 

                Dr. Woodcock said there is something in

 

      the law that kept the FDA from putting the

 

      information out.  She couldn't cite the law.  I

 

      guess it never occurred to her to ask Congress to

 

      change the law so that this information could get

 

      out.  Maybe the FDA was too stupid to ask them to

 

      change the law but I don't think so.  The FDA made

 

      a conscious decision to hide this information from

 

      the public because they say there is no other

 

      treatment available, even though they knew the

 

      drugs weren't effective and kids would be put at

 

      higher risk for suicide.

 

                                                               401

 

                Doctors are charged with first doing no

 

      harm, just like Laurie said.  But you, Drs. Temple,

 

      Laughren, Katz and Woodcock, have abused the public

 

      trust.  You have greatly misused the power of your

 

      positions by keeping the information from the

 

      public while protecting the drug companies'

 

      profits.

 

                I am asking that four of you resign as

 

      soon as the congressional investigation is over so

 

      that we can get people to work at the FDA that will

 

      work to protect our children and not the drug

 

      companies and their profits.  You say that

 

      depression is the cause of suicides that occur with

 

      children on these drugs.  Well, you have known all

 

      along, because of off-labeling, that kids have been

 

      prescribed these drugs for illnesses other than

 

      depression and still have completed suicide or they

 

      have attempted suicide, and you can't explain away

 

      these events on depression.

 

                Those that have survived these drugs talk

 

      of violent thoughts and actions that went away and

 

      haven't come back since being off the drugs.  You

 

                                                               402

 

      say the jury is still out on these drugs.  But it

 

      isn't out on you people.  You need to go.  We need

 

      to get people who will fulfill their duty and

 

      protect the people, not the drug companies.  And,

 

      these drugs need to go.  Until the drug companies

 

      can show that they work they shouldn't be

 

      prescribed to children.

 

                The FDA should demand that the drug

 

      companies open up their files, not just the

 

      clinical data, on these drugs so we can see what

 

      they thought and what they are saying about these

 

      drugs--if they haven't shredded them, that is.  If

 

      they have nothing to hide, they should do it right

 

      away but I don't think they will.  They have known

 

      all along that these drugs don't work and were

 

      potentially dangerous to children who took them.

 

                Dr. Cleary, from Pfizer, testified at the

 

      congressional hearing on Thursday as well.  She

 

      testified in front of Congress that she wanted to

 

      be open and let people know what was going on.

 

      Well, I call on them to open up their files now so

 

      we know what is going on.

 

                                                               403

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker 57,

 

      please.

 

                DR. VARON:  I am a full-time child and

 

      adolescent psychiatrist.  I would like to thank the

 

      North Baltimore Center, which is a community-based

 

      health center treating the children of Baltimore

 

      City.  I would like to thank them for allowing me

 

      to come down today.  Although they didn't provide

 

      financial support, they forfeited a day of billable

 

      services to allow me to speak to you today.

 

                Each day I realize that some of my

 

      patients may one day die from the depression I seek

 

      to treat.  Antidepressants in children and

 

      adolescents do work.  In many cases I have seen

 

      depression improved with the use of antidepressant

 

      medication.  In cases where medication has been

 

      helpful, the child has been involved in a

 

      multi-disciplinary approach where individual

 

      therapy, family therapy, including parent

 

      management training, has been utilized; the patient

 

      had access to partial and/or inpatient

 

                                                               404

 

      hospitalization when needed; and educational

 

      intervention was available when appropriate.  As

 

      well, medications were helpful only if the right

 

      diagnosis was made.  For instance, if we were

 

      really treating bipolar disorder as opposed to a

 

      depression the antidepressants, in fact, were not

 

      helpful.  Also, they were helpful if comorbidities

 

      were also treated.

 

                Second, discrimination in obtaining mental

 

      health care can compromise the patient's ability to

 

      be monitored appropriately for the dangerous side

 

      effects that we are talking about.  And, shortages

 

      of child and adolescent psychiatrists can also

 

      exacerbate this issue as these are the physicians

 

      most fully trained in prescribing these

 

      medications.

 

                Would a potential life-saving cancer drug

 

      with the risk of, say, aplastic anemia be taken off

 

      the market because of poor access to proper

 

      physician monitoring, or due to denial of an

 

      important hospital admission due to insurance

 

      purposes?

 

                                                               405

 

                Third, I believe that there is a

 

      subpopulation of children that require lower

 

      starting doses, almost homeopathic doses as it

 

      were, and a longer titration periods of SSRI

 

      dosages.  As such, these individuals may actually

 

      be more sensitive to the activation or

 

      disinhibition that we are talking about on the

 

      SSRIs.  Thus, if they are started on the higher

 

      doses, they may be more subject to the events that

 

      we are talking about today.  Thus, I would like to

 

      suggest that any future research take this

 

      subpopulation in mind.

 

                Fourth, in my practice over the last ten

 

      years I have seen one case of an antidepressant

 

      causing suicidal ideation, as reported by the mom,

 

      prior to the child actually coming to me.  In that

 

      case, no act, fortunately, was involved but the

 

      child still needed to be put on an antidepressant

 

      medication and subsequently did well.

 

                I would like to talk about a female who

 

      was successfully treated.  She had recurrent

 

      depression for many years on many medications.  She

 

                                                               406

 

      subsequently, over the last six months, has

 

      resolved on a combination of high-dose Zoloft,

 

      Risperdal and Wellbutrin and she is currently

 

      living without depression...

 

                DR. GOODMAN:  Thank you.  Speaker 58,

 

      please.

 

                MS. ZITO:  My name is Julie Zito.  I am

 

      Associate Professor of Pharmacy and Psychiatry at

 

      the University of Maryland, in Baltimore.  I am a

 

      pharmacoepidemiologist and I have been studying the

 

      use of psychotropics in children for the past 12

 

      years.

 

                I am here, despite the late hour and our

 

      exhaustion, to really ask the panel to consider

 

      seriously a specific scientific model in addressing

 

      the need for additional research on the benefits

 

      and risks of SSRIs in treating youth.  Namely, I

 

      ask you to recommend conducting a very large cohort

 

      study on a systematic sample of youths in

 

      treatment, and to follow them for a period of at

 

      least a year.  This non-clinical trial longitudinal

 

      approach can address many of the currently

 

                                                               407

 

      unanswered questions that you are here to consider.

 

                The sample should include youths from both

 

      primary care and psychiatry.  Data suggest there

 

      are about two million children a year getting an

 

      SSRI prescription so there shouldn't be too much

 

      trouble in identifying 100,000 7-17 year-olds who

 

      can be systematically assessed on outcomes at

 

      periodic times across a year.

 

                A cohort study would allow us to document

 

      outcomes in four treatment groups, those who get

 

      better and stop meds., those who get better and

 

      continue meds., those that stop treatment because

 

      of a lack of improvement, and those that stop

 

      because of adverse events.  Of course, in the case

 

      of the last example, those rare serious events can

 

      be fully described.

 

                The rationale is simple.  A signal of 1.78

 

      from retrospective trial data is really too weak to

 

      be definitive.  Randomized trials are typically too

 

      small to address rare events.  And, finally,

 

      depression is, indeed, too serious a condition to

 

      unwittingly deprive those use who would benefit

 

                                                               408

 

      from treatment simply because of lack of data that

 

      can distinguish between the SSRI at risk youth from

 

      the SSRI improvers.

 

                Federal sponsorship is necessary to assure

 

      that the design and assessment of such a study

 

      would be adequate to address the clinical public

 

      health questions that we are really after at this

 

      point.  We do need collaboration among the numerous

 

      disciplines that are involved around this question.

 

      We need the participation and support of youths and

 

      their families, and we need support from the

 

      treatment settings in which they receive care,

 

      particularly large HMOs and large mental health

 

      clinic settings.

 

                There is no existing data source now that

 

      is adequate to address the SSRI safety and even the

 

      community effectiveness questions that you are here

 

      to discuss.  Sadly, it is the suffering of young

 

      people...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.  Is

 

      speaker 59 here?  If not, will speaker 60 step

 

                                                               409

 

      forward?

 

                DR. ROBB:  I am Dr. Adelaide Robb and,

 

      while I am the psychiatric liaison to the American

 

      Academy of Pediatrics Committee on Drugs, I am here

 

      speaking today as a child psychiatrist, practicing

 

      at Children's National Medical Center in

 

      Washington, D.C.

 

                I wanted to give you a bit of a different

 

      perspective, that of somebody who takes care of

 

      kids who are sick every day with depression and

 

      their suffering.  I first became aware of

 

      adolescent depression and suicide when I was 16 and

 

      a classmate called me at two o'clock in the

 

      morning, saying he wanted to kill himself.  I spent

 

      the next two hours talking on the phone, trying to

 

      think of good reasons to stay alive, and the next

 

      two weeks combing the obituaries in the "Buffalo

 

      Evening News" seeing if anybody under the age of 20

 

      had died.  I never found out who that classmate was

 

      but it made me think a lot more about what I was

 

      going to do when I went to medical school, and I

 

      went off and did training in psychiatry.

 

                                                               410

 

                I then went on to a fellowship at the

 

      National Institute of Mental Health where I took

 

      care of a lot of families with bipolar and major

 

      depression.  Many of them were bringing in their

 

      kids who were five and six years old and suffering

 

      from depression, and none of the doctors in

 

      Washington, D.C. wanted to treat depression in a

 

      five year-old because it was dangerous, and scary,

 

      and what kind of five year-old gets depressed?

 

                So, I ended up going back to do additional

 

      training in child psychiatry and for the last ten

 

      years as a  Board certified child psychiatrist I

 

      have admitted 3000 patients to our inpatient unit

 

      at Children's, and 2000 of those kids were

 

      suffering from a mood disorder, and from those

 

      2000, about 70 percent had major depression and

 

      went on antidepressants.  While we have lost

 

      several patients from our unit to things like

 

      cancer and AIDS and other illnesses that can cause

 

      death in the under 18 year-olds, we have not had a

 

      single suicide out of those 3000 kids admitted.  I

 

      want you to remember that.

 

                                                               411

 

                I have also treated outpatients with major

 

      depression and have had about 500 kids that I have

 

      taken care of in the last ten years who have gone

 

      on antidepressants.  Again, none of them has died.

 

      A hundred have tone to college; two have gone to

 

      law school and two to medical school.  I don't

 

      think any of that would have been possible for them

 

      if they hadn't gotten treatment which consisted of

 

      careful monitoring, medicine when necessary, and

 

      therapy and education about side effects.  I tell

 

      parents I want them to call me if they have any

 

      questions.  I tell them these medicines, especially

 

      in the beginning, may lead to suicide and if they

 

      have any questions--none is too silly--I will

 

      answer email; I will answer a phone call.  I am

 

      there to help the kids.

 

                But I am a child psychiatrist and we spend

 

      more time with our patients and we want to help

 

      them.  In addition, I have actually been a PI in

 

      ten of the trials that you guys are talking about.

 

      We have had 63 patients randomized in those trials.

 

      We have not had a single suicide in those trials

 

                                                               412

 

      either, nor have we had increase in suicidal

 

      ideation...

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 61, please.

 

                DR. REBARBER:  Hello.  My name is Dr.

 

      Steve Rebarber and I am an outpatient child and

 

      adolescent psychiatrist.  I have been working in

 

      Bethesda, Maryland since I completed my child

 

      psychiatry training in D.C. Children's Hospital in

 

      1991.

 

                I appreciate the opportunity to come

 

      before the committee to briefly share my experience

 

      concerning the safety and efficacy of SSRI usage in

 

      children with depression, and urge the committee to

 

      allow sufficient time for reliable research to be

 

      done on this crucial matter before taking any

 

      dramatic steps, such as prohibiting their usage.

 

                In my practice I have had broad experience

 

      in working with families whose children have tried

 

      SSRIs.  SSRIs are neither the panacea, as some

 

      proponents suggest, nor are they the scourge that

 

      some opponents claim.  I have seen some children

 

                                                               413

 

      who have become agitated with SSRIs, some rare

 

      instances where perhaps they have become suicidal,

 

      but I have also seen many children with beneficial

 

      and sometimes life-saving reactions in responses to

 

      SSRIs.

 

                I have no doubt that if SSRI usage is

 

      prohibited before reliable scientific evidence

 

      demonstrates that they are dangerous that many,

 

      many children will suffer devastating untreated

 

      depression, and many of them are likely to go on to

 

      substance abuse or suicide.

 

                I realize that the committee has heard

 

      dramatic examples by caring and sometimes

 

      devastated families; that SSRIs have had terrible

 

      effects on their children.  In some cases the

 

      families may be correct in blaming the medication.

 

      In some cases, it seems to me, given the complexity

 

      of children's lives, the families may be wrong.

 

      You may be hearing from far fewer of the far

 

      greater number of families for whom SSRI treatment

 

      has been beneficial.  I can imagine the pressure

 

      that the committee may be feeling hearing these

 

                                                               414

 

      stories because at times I also find myself hearing

 

      the plea of parents, urging me to do something,

 

      anything, and sometimes the most difficult part of

 

      my work is to tell parents that I don't yet have

 

      enough information on which to act and that the

 

      best thing to do is to gather more information

 

      before acting.

 

                I urge the committee to act, not in the

 

      heat of the moment, but only after you have the

 

      sound scientific information necessary for making

 

      good decisions.  Thank you.

 

                DR. GOODMAN:  Thank you very much.

 

      Speaker 62, please.

 

                DR. KRATOCHVIL:  Good afternoon.  My name

 

      is Chris Kratochvil and I am a child and adolescent

 

      psychiatrist, from the University of Nebraska

 

      Medical Center, in Omaha, Nebraska.  I receive

 

      support from pharmaceutical companies but no

 

      support for this testimony.

 

                Thank you for providing me with this

 

      opportunity to talk to the committee today.  I come

 

      to you today as a clinician that treats children

 

                                                               415

 

      and adolescents with major depression and a

 

      clinical researcher who studies the treatment of

 

      pediatric depression.  I am the principal

 

      investigator of the Nebraska side of the TADS

 

      study, which you heard Dr. March talk about earlier

 

      today.

 

                In my role as a clinician I work closely

 

      with the children and adolescents suffering from

 

      depression, as well as their families.  These

 

      youngsters experience significant distress and

 

      impairment as a result of the depression that

 

      impacts their daily life at home, school and with

 

      their friends.  Sadly, as you have also heard,

 

      depression can all too often lead to suicide.

 

                In the context of a careful clinical

 

      evaluation and close monitoring, I have seen many

 

      youths make significant gains in their battle with

 

      depression when antidepressants are included as a

 

      part of a comprehensive treatment plan.  As a

 

      clinician, I see antidepressants playing a critical

 

      role in helping many of these young people.

 

                That being said, I do agree with the

 

                                                               416

 

      current warnings in place on the use of

 

      antidepressants.  Close monitoring is good medicine

 

      and includes educating and including the families

 

      in the monitoring.  In my role as a clinical

 

      researcher in the TADS study, I have had the

 

      opportunity to systematically study the safety and

 

      effectiveness of two specific treatments for

 

      adolescent depression.  The results of the study,

 

      as you heard, have shown a significant importance

 

      in depression in adolescents treated with

 

      fluoxetine combined with cognitive behavioral

 

      therapy.  But these findings are just the

 

      beginning.

 

                What about other pharmacotherapies, other

 

      psychotherapies and other age groups?  How do we

 

      select the best treatment for a specific child who

 

      comes to us with a unique story and a unique set of

 

      problems?  Significant research remains to be done

 

      to help guide us in our efforts to help these young

 

      persons and their families.

 

                My recommendations to the committee at

 

      this time:  Warnings for careful and systematic

 

                                                               417

 

      follow-up when antidepressants are used,

 

      particularly during the initiation, titration and

 

      discontinuation.  Additionally, further studies on

 

      the safety, effectiveness and role of all

 

      antidepressants that are used in the pediatric

 

      population need to occur.  Thank you for your time.

 

                DR. GOODMAN:  Thank you.  Is speaker 63

 

      here?  Speaker 64?

 

                MR. SWAN:  My name is Eric Swan and I lost

 

      my brother-in-law, Tim Witsack, to SSRI suicide.

 

      His story is told on the website we have created

 

      for him at woodymatters.com.  I urge each and every

 

      one of you to go there and study his story.

 

                Albert Einstein said it best when he

 

      defined insanity, it is doing the same thing over

 

      and over and expecting a different result.  I am

 

      here to simply ask that you include adults in

 

      safety action you recommend or take.  I believe

 

      that if the patterns taken in the past are repeated

 

      we will be having a similar hearing sooner than

 

      later on adults on these same issues.  I believe

 

      that no one here truly knows that the side effects

 

                                                               418

 

      of SSRIs are any less dangerous to a 19 year-old

 

      than an adolescent.  Adults matter too.

 

                Every person sitting in this room can do

 

      something to help fix this tragedy.  Members of the

 

      develop committee, please hear the stories of adult

 

      victims of SSRI-induced suicide and include adults

 

      in your recommendations to FDA.  Please also focus

 

      on patients given antidepressants off-label who are

 

      not depressed who went on to commit suicide out of

 

      character.

 

                Employees of the FDA--Dr. Temple, Katz,

 

      Laughren, I assume that since FDA included adults

 

      in the March warnings that you are also looking at

 

      the original safety and efficacy studies for adults

 

      from the late '80s and early '90s.  If you truly

 

      are part of the jury that is still out, please

 

      decide sooner than later.  Lives are in the

 

      balance.  And, please investigate from other angles

 

      as well.  We have some ideas on this and will

 

      follow-up with you.

 

                To the pharmaceutical industry here, your

 

      industry is important.  With that, however, comes

 

                                                               419

 

      an awesome responsibility to your fellow Americans

 

      who take these drugs.  The very minute a safety

 

      issue is discovered it should be disclosed and

 

      openly worked out.  There is no excuse to ever put

 

      one penny of profit over the life of a child,

 

      husband, wife, mother, father, brother, sister or

 

      friend.  Please disclose all you know on this

 

      matter so a solution can be found.

 

                To the media here, thank you for bringing

 

      the stories into the spotlight.  Please continue to

 

      write and tell the stories that need to be told.

 

                On August 6th, 2003 I walked into a

 

      nightmare when we found my brother-in-law hanging,

 

      at age 37.  Tim Witsack lived his life by the gauge

 

      of doing the right thing.  If we all apply that

 

      same standard to the work before us today we have a

 

      chance to end the patterns of the past and save

 

      lives.

 

                As an aside, Dr. Laughren, I heard you

 

      mention earlier that you have not seen the same

 

      indications in adults.  Please use Woody's story

 

      and the adult stories behind me as your indication.

 

                                                               420

 

      Thank you all for your time.

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker 65,

 

      please.

 

                MS. WEATHERS:  My name is Patricia

 

      Weathers.  I am a New York mother and president and

 

      co-founder of ablechild.org, a national grassroots

 

      parent organization representing over 900 members,

 

      such as Mrs. Vicky Dunkle whose 10 year-old

 

      daughter died in her mother's arms as a direct

 

      result of the antidepressant prescribed her.

 

                I am one of the lucky ones.  My child is

 

      still alive.  My own story has been featured on

 

      "Good Morning, America," "The Today Show," A&E

 

      investigative reports and "The New York Times,"

 

      just to name a few.  I have testified before state

 

      legislatures and twice before Congress.  My

 

      activism began after my son's school coerced me to

 

      place him on Ritalin, a drug that caused him to

 

      become extremely withdrawn.  The school

 

      psychologist and psychiatrist then diagnosed him

 

      with social anxiety disorder and recommended Paxil

 

                                                               421

 

      as a, quote, wonder drug for kids.

 

                On Paxil, he began hearing voices in his

 

      head, drew violent pictures and even attacked me.

 

      I could no longer recognize my own son.  He pleaded

 

      with me at one point, "Mom, make it stop."  I

 

      finally realized that it was the Paxil that put him

 

      in a drug-induced psychosis so, naturally, I

 

      removed him from the drug.  I was then charged with

 

      medical neglect when there was no proof that

 

      anything was medically wrong with him.  I soon

 

      discovered social anxiety disorder, like bipolar

 

      disorder and attention deficit disorder, are not

 

      medical conditions.  Parents are told that their

 

      child has a chemical imbalance or a neurobiological

 

      illness.  We risked our child's life based on this

 

      fundamental lie.

 

                I now know this is not true but, more

 

      importantly, so do you.  The FDA is well aware that

 

      there are no x-rays, biopsies, blood tests or brain

 

      scans that verify these mental disorders as a

 

      disease or illness.  My point is simple.  The FDA

 

      should not be condoning or approving these drugs

 

                                                               422

 

      without evidence of disease, illness or physical

 

      abnormality that would justify risking our

 

      children's lives with a harmful and potentially

 

      lethal drug.

 

                We are gathered here today, discussing

 

      warning labels on antidepressant drugs.  Why?  The

 

      FDA had enough evidence 14 years ago to issue these

 

      warning labels on these drugs and you know this.

 

      Now the FDA must do more.  The FDA's own mission

 

      statement says that it is responsible for helping

 

      the public get accurate science-based information.

 

      It is failing.  The FDA is risking our children's

 

      lives based on nothing more than junk science.  The

 

      FDA is responsible for protecting the public

 

      health, not vested interests.  I remind you that

 

      children's lives are in your hands and I call...

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker 66,

 

      please.

 

                MS. STEUBING:  We are Celeste and Dan

 

      Steubing.  This is our daughter, Ann.  On June 8th,

 

      2003, our 18 year-old son, Matthew, graduated from

 

                                                               423

 

      high school with his whole life ahead of him.  Six

 

      weeks later Matthew jumped to his death from the

 

      Cooper River Bridge in Charleston, South Carolina.

 

      He had been taking the antidepressant Lexapro for

 

      less than ten weeks.  Matthew was the youngest of

 

      our six children.  He was a happy and healthy child

 

      with no prior history of depression.  Matt was a

 

      normal teenage boy.  He loved sports, loud music,

 

      pretty girls, cool cars and Seinfeld.  He loved his

 

      family.

 

                Matthew had plans for college.  He had

 

      plans to join the Air Force ROTC program.  He did

 

      not plan to die.  Matthew was experiencing some

 

      difficult life lessons.  He began to withdraw from

 

      his friends and his normal activities.  He lost

 

      interest in school, work, his plans for college,

 

      even basketball, the thing he loved most.  We

 

      sought the help of a counselor who recommended a

 

      combination of therapy and medication as the best

 

      way to help Matthew's chemical imbalance.  A family

 

      practice doctor prescribed Lexapro.  Prior to

 

      taking the medication, Matthew was depressed; he

 

                                                               424

 

      was not suicidal.  After beginning the Lexapro

 

      things changed.  In Matt's words, "it just got

 

      worse."

 

                He became more withdrawn.  He had trouble

 

      sleeping.  He was anxious and restless as though he

 

      couldn't stand to be in his own skin.  He had

 

      tremors in his hands and complained several times

 

      that he felt like his heart was beating too fast.

 

      He said things like, "I feel like I'm here but I'm

 

      not here," and "it feels like my head is

 

      disconnected from my body."  As for side effects,

 

      we were told there could be things like dizziness,

 

      nausea and insomnia.  Never did the doctor discuss

 

      the possibility that this drug could worsen my

 

      son's depression or cause a condition called

 

      akathisia, a condition we now recognize as being

 

      present in Matthew.

 

                As parents, we have a right to make an

 

      informed decision regarding our child's care.  That

 

      right was taken from us when you elected to turn a

 

      blind eye to the evidence that had been mounting

 

      against these drugs for years.  Had we known the

 

                                                               425

 

      truth about the potential dangers of this

 

      medication we would have been better armed to

 

      protect our son.  Matthew would be alive today.

 

                I said before that we lost our son.  What

 

      I truly believe is that our son was murdered by

 

      Forest Laboratories and the FDA has his blood on

 

      its hands.  How many more children have to die?

 

      How many more families have to be torn apart before

 

      you do the job you were charged to do?  When you

 

      err on the side of caution, it must be in favor of

 

      the innocent victims who put their faith, their

 

      trust and their lives in your hands.  We demand

 

      full disclosure.  You owe us...

 

                [Applause]

 

                DR. GOODMAN:  Thank you very much.  Is

 

      speaker 67 here?  If not, speaker 68, Dr. Mann?

 

                DR. MANN:  My name is John Mann.  I am

 

      president of the American Foundation of Suicide

 

      Prevention, which represents families who are

 

      survivors of suicide, and supports research into

 

      the prevention and causes of suicide.  I am also a

 

      psychiatrist at Columbia University.

 

                                                               426

 

                First slide, please.  I would like to make

 

      several points.  I know that some people have

 

      blamed the treatment and other people have blamed

 

      the condition for a series of tragic suicides that

 

      we have heard about today.  The point I would like

 

      to make is that depression is a real lethal

 

      condition.  You may not be able to take an x-ray

 

      but it is definitely killing a lot of people.

 

      Principally, it is untreated depression that is the

 

      major cause of suicide in the United States in both

 

      adults and children.

 

                Next slide.  When you do psychological

 

      autopsies and talk to the families who have lost

 

      their loved ones, it is clear that the principal

 

      problem in these suicides is not that they have

 

      been taking antidepressants that have killed them.

 

      The principal problem is that they have been taking

 

      nothing.  Most of them have taken no

 

      antidepressants and a small minority have taken low

 

      doses of antidepressants, and very few have had

 

      adequate treatment.

 

                Next slide, please.  Do antidepressants

 

                                                               427

 

      work in children?  What is of interest is that

 

      fluoxetine, where three studies have shown

 

      efficacy, those three studies were not conducted by

 

      the pharmaceutical industry; they were conducted by

 

      academics.  That probably suggests something about

 

      design and who should be doing the studies.

 

                Next slide, please.  Non-SSRIs, however,

 

      pretty unanimously do not seem to be effective.

 

                Next slide.  Now, what is remarkable is

 

      that those individuals in the United States that

 

      live in particular areas where the highest

 

      prescription rates exist for SSRIs, in those

 

      demographic groups that have received the highest

 

      prescription rates of antidepressants, in

 

      particular SSRIs, have had the biggest fall in

 

      suicide in the United States.  This applies to both

 

      adults and children and it is true around the

 

      world.

 

                Next slide.  The suicide rate rose 31

 

      percent in the United States up to 1986 or prior to

 

      SSRIs.  Since 1987 there has been a steady fall in

 

      the suicide rate.  Why?

 

                                                               428

 

                Next slide.  The women, for example, who

 

      have received roughly twice the prescription rate

 

      of men, have had about double the drop in suicide

 

      rates.

 

                Next slide.  Those areas of the United

 

      States that have the highest prescription rates of

 

      SSRIs, both in adults and children, have had the

 

      biggest falls in suicide rates.

 

                Next slide.  In fact, if you calculate,

 

      for every 10 percent increase in prescription

 

      rates, there are approximately almost a 1000

 

      decreases in suicide...

 

                DR. GOODMAN:  Thank you.  Speaker 69,

 

      please.

 

                DR. BRAIN:  I am Lawrence Brain, child

 

      psychiatrist practicing in Bethesda, Maryland and

 

      president of the Child and Adolescent Psychiatric

 

      Society of Greater Washington.

 

                Until two years ago and for over 20 years

 

      I treated seriously ill children in psychiatric

 

      hospitals, and for most of that time was medical

 

      director of these large programs.  Therefore, I

 

                                                               429

 

      have been involved in the treatment of thousands of

 

      significantly ill child patients and have had an

 

      opportunity to observe the effectiveness of the

 

      SSRI antidepressant group.

 

                I wish the committee to focus on another

 

      clinical element.  Until approximately ten years

 

      ago seriously depressed children were admitted to

 

      psychiatric hospitals for assessment and treatment.

 

      Initially this required a comprehensive evaluation

 

      and the development of an extensive treatment plan.

 

      I believe it is essential that in evaluating the

 

      effectiveness and safety of the SSRI group it is

 

      imperative that this be placed within the context

 

      of an adequate and comprehensive treatment plan.

 

                In the past, after evaluation, depressed

 

      children were prescribed antidepressant

 

      medications, frequently of the SSRI group.

 

      However, they remained hospitalized in a safe

 

      therapeutic environment where, in addition to

 

      medication, they received numerous

 

      psychotherapeutic services during which we had an

 

      opportunity to observe the impact of the medication

 

                                                               430

 

      so that if activation and escalation of suicidal

 

      ideation or impulsive and potentially dangerous

 

      behavior occurred, this was able to be contained.

 

                As it is known that this activation

 

      typically occurs within the first three weeks of

 

      treatment, the patients remained in the facility

 

      until we observed a therapeutic response and a

 

      pattern of safe behavior.  Patients were then

 

      discharged to day treatment where intensive daily

 

      treatment was provided until safe discharge to

 

      outpatient care was achieved.

 

                This process changed with the intrusion of

 

      managed care, such that now significantly depressed

 

      children are not hospitalized unless there is an

 

      absolute assessment of being a danger to themselves

 

      or others.  Currently, it is typical for

 

      hospitalization to be brief; assessment to be

 

      superficial and if medication prescribed, the

 

      patient is discharged within 3-5 days.  Managed

 

      care reviewers have focused on the utterance of

 

      suicidal thoughts as the only determinant of

 

      potential dangerousness.

 

                                                               431

 

                As a clinician, I have argued vociferously

 

      on many occasions that, if not present, this does

 

      not represent real change and that potential danger

 

      exists.  Given the known duration before clinical

 

      effectiveness can occur, it is evident the current

 

      policies are exposing children unnecessarily to the

 

      vicissitudes of their illness.  It is my experience

 

      that these medications are safe and effective

 

      provided they are used within the context of a

 

      comprehensive treatment plan, and I urge this

 

      committee to look beyond the limitations of brief

 

      studies, to provide guidance and direction as to

 

      the totality of care as outlined in the practice

 

      parameters developed by the American Academy of

 

      Child and Adolescent Psychiatry.

 

                While it is the responsibility of the

 

      treating psychiatrist to ensure as much as

 

      possible...

 

                DR. GOODMAN:  Thank you.  Speaker 70,

 

      please.

 

                MR. SHAPIRO:  My name is Mark Shapiro.  I

 

      am here from Duke University.  I have no financial

 

                                                               432

 

      association with any drug makers.

 

                First of all, I know you are tired so I

 

      would like to thank you for listening to me and

 

      thank you for your thoughtful deliberations on this

 

      difficult topic.  I am speaking here as a member of

 

      the public.  However, I am the manager of child and

 

      adolescent psychopharmacology trials.  I am also a

 

      past sufferer from major depression.

 

                In my early 20s I sought treatment for

 

      depression and, like many sufferers, it was not

 

      until I was suicidal that I even recognized the

 

      need for treatment.  In my case, paroxetine and

 

      frequent session with a psychiatrist saved my life.

 

      Although I was skeptical of psychiatry before that

 

      experience, therapy helped me to understand and

 

      overcome my illness.  However, without

 

      antidepressant medication I could not have made it

 

      to this session and might not be standing before

 

      you today.

 

                I would like to comment on the DNDP and

 

      ODS analyses and to commend those involved for

 

      their efforts to address the current issue in a

 

                                                               433

 

      fair and scientific manner.  However, it should be

 

      noted that the potential pitfalls of meta-analysis

 

      are well documented and grow as the heterogeneity

 

      of the included studies grows.  As Dr. Dubitsky

 

      noted, these analyses include nine drugs plus an

 

      extended release formulation, five distinct

 

      psychiatric disorders, varied treatment durations

 

      and both in- and outpatient settings.  In other

 

      words, meta-analysis in this case may be better for

 

      generating a hypothesis for a randomized,

 

      controlled trial than actually making a policy

 

      decision.  Although there may be a weak signal, the

 

      results are not conclusive either for the

 

      individual drugs or in aggregate.

 

                Why might this be?  I believe that the

 

      regulatory climate in which they were conducted

 

      creates a situation that may have affected the

 

      trial teams and sites.  This stems from the fact

 

      that many of the trials were aimed at gaining

 

      six-month exclusivity.  From a financial

 

      perspective, the six-month marketing exclusivity is

 

      frequently worth a great deal more than a pediatric

 

                                                               434

 

      label change, particularly in cases where a drug is

 

      already being used off-label.  When planning a

 

      trial companies may, therefore, view labeling

 

      changes of secondary importance.

 

                In my own experience, study sponsors have

 

      often set unrealistically aggressive time lines for

 

      these projects.  Such pressures can lead to

 

      questionable or at least expeditious choices

 

      regarding trial design and implementation and

 

      subject recruitment.  This may result in an

 

      elevated placebo response, reduced trial power and

 

      distorted safety profile.

 

                In contrast, the publicly funded TADS

 

      study offers meaningful and clinically useful

 

      information about how best to treat adolescent

 

      depression.  However, to address the risk/benefit

 

      ratio of antidepressants and detect rare but,

 

      nonetheless, significant adverse effects such as

 

      increased suicidality, a large randomized and well

 

      designed study is required.  Faced with similar

 

      challenges, other areas of medicine have

 

      successfully adopted practical clinical trials. 

 

                                                               435

 

      The Child and Adolescent Psychiatry Trials Network

 

      is an NIMH-funded initiative that has recruited

 

      more than 200 child psychiatrists who are willing

 

      to conduct this research in a real-world setting in

 

      an attempt...

 

                DR. GOODMAN:  Thank you.  Speaker 71, and

 

      then our last speaker will be number 73, so three

 

      more speakers.

 

                MS. MILLING-DOWNING:  On January 10th,

 

      2004 our beautiful little girl, Candice, died by

 

      hanging four days after ingesting 100 mg of Zoloft.

 

      She was 12 years old.  The autopsy report indicated

 

      that Zoloft was present in her system.  We had no

 

      warning that this would happen.  This was not a

 

      child who had ever been depressed or had suicidal

 

      ideation.  She was a happy little girl and a friend

 

      to everyone.

 

                She had been prescribed Zoloft for

 

      generalized anxiety disorder, by a qualified child

 

      psychiatrist, which manifested in school anxiety.

 

      We were monitoring her diet, encouraging her

 

      physical activates and had testing accommodations

 

                                                               436

 

      put in place at school.  She had the full support

 

      of a loving, caring, functional family and a

 

      nurturing school environment.  Her death not only

 

      affected us but rocked our community.

 

                How could this have happened to such a

 

      happy and loving child?  When Candice died her

 

      school was closed for the day of her memorial

 

      service, a service that had to be held in the

 

      school gym in order to seat the thousand or so

 

      people who attended.  How ironic, Dr. Laughren,

 

      that your family attended Candice's memorial

 

      service.  Our daughters had been in class together

 

      since kindergarten.  How devastating to us that

 

      your daughter will graduate from the school that

 

      they both attended for the past eight years and

 

      that Candice will never have the opportunity to do

 

      so.

 

                Bishop Chain wrote to me following

 

      Candice's service which he helped officiate.  He

 

      referred to Candice as a spiritually gifted child.

 

      How fitting that he officiated at President

 

      Reagan's memorial service on June 11th, what would

 

                                                               437

 

      have been Candice's 13th birthday.

 

                Candice's death was entirely avoidable,

 

      had we been given appropriate warnings and

 

      implications of the possible effects of Zoloft.  It

 

      should have been our choice to make and not yours.

 

      We are not comforted by the insensitive comments of

 

      a corrupt and uncaring FDA or pharmaceutical

 

      benefactors such as Pfizer who sit in their ivory

 

      towers, passing judgments on the lives and deaths

 

      of so many innocent children.  The blood of these

 

      children is on your hands.  To continue to blame

 

      the victim rather than the drug is wrong.  To make

 

      such blatant statements that depressed children run

 

      the risk of becoming suicidal does not fit the

 

      profile of our little girl.

 

                We attended the public hearings held in

 

      February three weeks after Candice died.  We had a

 

      very hard time learning about the specifics of this

 

      meeting as none of our calls to the FDA were ever

 

      returned.  Imagine our shock as we sat and listened

 

      to person after person describing their personal

 

      pain and suffering at losing a child like us.  How

 

                                                               438

 

      could we not have known?  These warnings were not

 

      an isolated case.  We were never told of any danger

 

      associated.  I voiced concern and was told that

 

      there was no problem.

 

                After the hearings I again tried to

 

      contact the FDA and again no one returned my phone

 

      calls.  I wrote a formal letter complaining about

 

      Pfizer and was told it would be forwarded for a

 

      reply.  It is six months later and I am still

 

      waiting for my reply.

 

                I want to know why.  Why you have done

 

      these things to us, and why...

 

                [Applause]

 

                DR. GOODMAN:  Thank you.  Speaker 72.

 

                DR. KAHN:  My name is Dr. Peter Kahn.  I

 

      am a Board certified child and adolescent

 

      psychiatrist, in practice for 25 years.  I am one

 

      of the medical directors of the Shepherd Pratt

 

      Health System.

 

                DR. GOODMAN:  Please bring the microphone

 

      closer.

 

                DR. KAHN:  Okay.  Do you want me to start

 

                                                               439

 

      again?  I am one of the medical directors of the

 

      Shepherd Pratt Health System.  I am also on the

 

      clinical staff at the University of Maryland School

 

      of Medicine.  Our experience at Shepherd Pratt in

 

      prescribing antidepressants to treat children and

 

      adolescents with major depressive disorders has

 

      been overall positive, particularly when combined

 

      with psychotherapy.  Too often our young patients

 

      keep suicidal ideation and harmful behavior secret

 

      from their parents and, thus, parents may be

 

      unaware of how negatively severe depression

 

      influences their child's thinking and behavior.

 

                When prescribing medication, it is good

 

      practice to carefully evaluate patients for

 

      comorbid conditions that might negatively influence

 

      their response to antidepressants, and to probe for

 

      history of suicidal and homicidal ideation and

 

      history of harm.

 

                Informed consent includes both

 

      risk/benefits of antidepressant use and the

 

      risk/benefits of not prescribing antidepressants.

 

      As one college age patient said to me last week in

 

                                                               440

 

      thinking back about her adolescence, "without my

 

      antidepressants I would have been dead."

 

      Psychiatrists have known for years that during the

 

      initial phase of treatment the risk of suicide may

 

      increase.  Thus, it is good practice to carefully

 

      educate patients and their parents, provide 24/7

 

      emergency phone coverage and assess outpatients at

 

      least weekly during the first weeks of

 

      antidepressant treatment, following dose changes

 

      and during discontinuation.

 

                As all patients do not respond to a single

 

      antidepressant, it may be necessary to switch an

 

      antidepressant ineffective in one individual to

 

      another, hopefully, more effectiveness medication.

 

      To make these decisions we need unbiased data.

 

                I am aware that my experiences in

 

      prescribing these medications, while positive, are

 

      retrospective and anecdotal.  Clearly, we need more

 

      unbiased clinical research not just on

 

      antidepressants but on all medications for

 

      children.  Towards that end, I support the

 

      establishment of a mandatory clinical registry for

 

                                                               441

 

      all clinical trials.  In the meantime, this process

 

      has finally gotten the appropriate attention of

 

      physicians patients and their families.

 

                The FDA's warning must be clear.

 

      Judicious monitoring is necessary.  I believe that

 

      it is imperative that physicians be properly

 

      educated and then have the option to prescribe

 

      antidepressants for the child and adolescent

 

      patients.  Thank you.

 

                DR. GOODMAN:  Our final speaker for this

 

      evening?

 

                MS. MCGINN:  Good afternoon.  My name is

 

      Eileen McGinn.  I have a master of public health

 

      degree and I have several members of my family who

 

      have schizophrenia, bipolar disorder, alcoholism.

 

                The current process for the approval of

 

      drugs for the American market is scientifically

 

      flawed.  Science requires reliability and validity.

 

      The trials for many psychotropic drugs are not

 

      reliable nor are they valid.  Reliability in

 

      science requires that research be independently

 

      replicated in different labs by different

 

                                                               442

 

      researchers.  In the case of drug trials, the same

 

      firm producing the drugs conducts all the trials.

 

      This is an inevitable source of bias and a breach

 

      of the scientific method.

 

                In terms of validity, there are several

 

      problems.  First and most important, the samples

 

      are not representative.  People in a research study

 

      are supposed to represent the general population

 

      with the illness.  Most trials systematically

 

      exclude many people, especially those with severe

 

      illness.  The group study does not represent the

 

      population with the illness so we cannot generalize

 

      the results.

 

                Second, often the outcome measures are not

 

      clinical measures.  There is no blood test or brain

 

      scan to mark the presence of psychiatric illness so

 

      researchers use rating scales, similar to

 

      questionnaires, to measure the severity of

 

      symptoms.  On a scale of 1-20 clinicians may agree

 

      that a score under 7 demonstrates wellness, while a

 

      score over 7 shows that the person is ill.  It

 

      would seem logical to use the cut score of 7 to

 

                                                               443

 

      sort out the responders from the non-responders.

 

      This simple, direct method is not used.  Instead,

 

      researchers use a mathematical formula based on a

 

      percent decrease in scores.  A person may decrease

 

      from 20 to 10 but at 10 he is still quite ill.  In

 

      children the percent decrease is often 20-30

 

      percent, not 50 percent.

 

                The dropout rates for some trials approach

 

      50 percent, a dropout rate that biases the results

 

      and calls into question any conclusions of the

 

      trial.  The information from the dropouts, like

 

      adverse events or non-response, is rarely analyzed

 

      or reported.  Scientific methods exist to deal with

 

      the dropout data but they are rarely reported in

 

      the trial results.

 

                Trials are short and small.  Small size

 

      means that less common adverse events are not

 

      captured.  Short duration means that delayed

 

      harmful events are not known by the end of the

 

      trial.

 

                Fifth, trials are not valid because the

 

      double-blind...

 

                                                               444

 

                     Summary by the Committee Chair

 

                DR. GOODMAN:  Thanks to you and to

 

      everybody else who has taken out the time and

 

      poured our their hearts today.  It has been a long

 

      day.  I appreciate your attentiveness and your

 

      patience.  I, for one, feel exhausted not only

 

      because of the late hour but because of some of the

 

      heart-rending stories that I have heard today.

 

                On your agenda, the next item is for me to

 

      take a stab at a summary of what we heard today.

 

      We could take a break before that.  I will leave it

 

      up tot he committee.  My preference would be just

 

      to go into it so that we can leave, hopefully, by

 

      6:15 as originally planned.

 

                What I would like to do then, as I see no

 

      objection, is to summarize some of what we heard

 

      today, touching on some of the salient points.  I

 

      don't mean this to be a comprehensive summary by

 

      any means.

 

                First let me begin with where we stood

 

      going into this meeting.  We learned at our last

 

      meeting that there was a suicidality signal in

 

                                                               445

 

      several of the studies that were submitted in

 

      pediatric depression, meaning that there was more

 

      suicidal behavior or ideation reported in the drug

 

      versus the placebo group--not the expected finding.

 

      It is opposite, in fact, to what you would expect

 

      since suicidality is one of the symptoms of the

 

      underlying condition.  In fact, the only drug for

 

      which there was no suicidality signal at all were

 

      the trials submitted for fluoxetine.

 

                Coupled with this, we learned that three

 

      out of the 15 studies in pediatric major depression

 

      were positive so that the majority of the studies

 

      were either failed or negative.  So, in addition to

 

      adverse effects that were of concern, we had

 

      question about the overall benefit of this class of

 

      agents, raising then naturally questions about

 

      benefit/risk ratio.

 

                Finally, we heard public testimonies last

 

      time as well, and many of those, like the ones we

 

      heard today, were passionate and plausible.  When I

 

      listened to them last time, as I did today, I was

 

      looking for a pattern.  Certainly they don't

 

                                                               446

 

      necessarily fit into a pattern but several of the

 

      cases--I didn't exactly count but quite a few of

 

      the cases seemed to suggest that suicides or the

 

      suicidal behavior that was reported by the public

 

      testimony occurred relatively early after the

 

      initiation of medication.

 

                That observation I think resonated, at

 

      least with my own clinical experience and that of

 

      many other clinicians, as something that we have

 

      known for a long time, both in children and adults,

 

      that there are some patients who are susceptible to

 

      a behavioral toxicity.  We know for sure that

 

      patients with bipolar diathesis seem to be

 

      particularly prone to developing a syndrome that

 

      may represent induction of mania after the exposure

 

      to antidepressants.  We also know from child

 

      psychiatrists that they are particularly alert,

 

      even before the warnings were issued--they have

 

      been alert all along as part of their training that

 

      there are some patients, some kids who are

 

      exquisitely sensitive to these medications and then

 

      they adjust the dose, the titration and the

 

                                                               447

 

      observation accordingly.

 

                There is also an impression, despite the

 

      lack of efficacy in most of these trials that were

 

      submitted--a strong conventional wisdom among

 

      clinicians that there are many children out there

 

      who have benefited from the use of antidepressant

 

      medications.  However, the data supporting that

 

      observation is rather elusive.

 

                We also heard from John Mann today during

 

      the public testimony that untreated depression is

 

      the major cause of suicide in youth.

 

                Now, based upon what we heard last time,

 

      we did not conclude that there was sufficient

 

      evidence to articulate a direct link between

 

      administration of the antidepressants and the

 

      suicidal behavior.  However, I think we heard

 

      enough to suggest that there was a potential risk;

 

      that we needed to do something quickly to mitigate

 

      that risk.  I think what we gravitated to was a

 

      hypothesis that many of these cases, from what we

 

      heard both in the public testimony as well as what

 

      we saw in the clinical trials, can be attributed to

 

                                                               448

 

      behavioral toxicity, particularly something that

 

      occurs early in treatment and perhaps--and this is

 

      only perhaps, it is a hypothesis--if one is more

 

      vigilant, if the prescriber, and the family members

 

      and the patients are more vigilant about monitoring

 

      for side effects such as activation, things that

 

      have been referred to as akathisia and insomnia,

 

      that those symptoms or signs may represent a

 

      precursor to the symptom we most fear, that of

 

      suicide intent.

 

                We reconvened this time with the intention

 

      of going back to the data after a reclassification

 

      of the events and also the opportunity to look at

 

      any additional data that emerged in the interim.

 

      So, reviewing what we heard today, first we heard

 

      from Dr. Laughren who brought us up to speed and

 

      reviewed some of the history of the clinical

 

      trials, the FDA steps that have been taken, and he

 

      also reminded us of something that I wish to

 

      revisit tomorrow.

 

                So, in part I am giving the summary as

 

      kind of a demarcation between today and tomorrow,

 

                                                               449

 

      and also to try to set the stage for some of our

 

      discussions.  I reminded us that a number of these

 

      studies were conducted under the conditions in

 

      which the sponsor could be granted six months

 

      exclusivity if they submitted a trial in pediatric

 

      depression.  I think this was certainly

 

      well-meaning.

 

                There had been an outcry previously that

 

      these drugs were being looked at off-label but

 

      there weren't sufficient studies.  But the question

 

      that I think is on all our minds is whether this

 

      well-meaning action could have led to some

 

      unintended consequences.  Although we haven't

 

      exactly articulated what those might be, that is

 

      certainly what comes to my mind--could the sponsors

 

      have used marginal estimates of power?  If their

 

      goal was to have a positive study, not just a trial

 

      submitted but a positive outcome, would they have

 

      set the sample size higher?  Would we have had a

 

      different outcome?  I will turn to the

 

      statisticians tomorrow perhaps to say whether there

 

      is any evidence of that.  There is though, from

 

                                                               450

 

      what I can tell, a powerful effect size so I am not

 

      sure that that is the case.  Nevertheless, I think

 

      we should talk about that more tomorrow.

 

                One of the other speakers also mentioned

 

      the possibility that there might have been some

 

      incentives or encouragement towards rapid

 

      enrollment, and could some of that process to speed

 

      it up since the companies were going to receive

 

      six-month exclusivity--could that have led to some

 

      contamination in the data set?  That is all

 

      speculation but I think we should turn to a

 

      discussion of those possibilities tomorrow.

 

                Dr. Wysowski then turned to other sources

 

      of data that might have bearing on our discussions,

 

      including ecological studies, and mentioned work,

 

      published by Dr. Schaefer at Columbia, showing an

 

      inverse relationship between the use of

 

      antidepressants and the decrease of suicide in our

 

      youth, and pointed out that correlation does not

 

      equal causality and that there were other factors,

 

      intervening variables that could explain that

 

      pattern over time.  Dr. Schaefer did have an

 

                                                               451

 

      opportunity to rebut during the open presentations

 

      later.

 

                What was also presented were some

 

      patient-level controlled observational studies,

 

      including a study by Jick that was published in

 

      JAMA.  This was a study that compared several

 

      different antidepressants to each other with

 

      respect to suicide risk.  It was pointed out that

 

      our ability to infer the suicide risk contributed

 

      by the drugs is limited since there was no

 

      unexposed group as one of the controls.

 

                Interestingly, however, what was found

 

      significant was a relationship between time of

 

      onset of medication and reports of suicidal

 

      behavior, such that the patients who had started

 

      antidepressant medication in the past nine days

 

      showed a significantly higher rate of suicidal

 

      behavior than those who had been on antidepressants

 

      for six months or more.  That finding certainly did

 

      fit with one of the hypotheses that I think has

 

      been on our minds and that led to some of the

 

      warnings in the interim, that the adverse effects

 

                                                               452

 

      could be something that will occur early in the

 

      course of treatment.

 

                Dr. March then presented results from the

 

      TADS study.  This is in contrast to the other

 

      studies we have looked at, sponsored by NIMH.  It

 

      was a trial that had four arms that included

 

      cognitive behavioral therapy.  Our focus on this

 

      study though was not on the cognitive behavioral

 

      therapy so the most germane component of that study

 

      is the comparison between fluoxetine and placebo.

 

      Furthermore, those are the two studies that were

 

      conducted in a double-blind fashion.

 

                What we learned is that on several but not

 

      all measures fluoxetine was superior to placebo.

 

      As I understand it from the presentation and

 

      reading the article, talking about benefit,

 

      fluoxetine was not significantly superior to

 

      placebo on changes in mean scores on the Children's

 

      Depression Rating Scale, although it nearly met

 

      statistical significance.  With regard to

 

      suicidality, reported rates of suicidal ideation

 

      decreased in all the treatment groups.

 

                                                               453

 

                Dr. Dubitsky gave us a summary of the data

 

      and a handout that I think will be extremely useful

 

      tomorrow as a reference, and reminded us that only

 

      three of the 15 studies in major depression were

 

      positive.

 

                Dr. Posner, from Columbia, then reviewed

 

      the methodology and how it was implemented to

 

      reclassify the data from the clinical trials.  The

 

      presentation struck me as being very rigorous and

 

      comprehensive, and it was validated by Dr. Iyasu,

 

      from the FDA who looked at a sample using the same

 

      strategy that was used by Columbia and came out

 

      with very good agreement between their results and

 

      the reclassification as ascertained by the Columbia

 

      group.

 

                Then we moved into what I would see as the

 

      cornerstone of the data that was presented today,

 

      the new data that we had been anticipating and that

 

      I think we will continue to examine tomorrow.  Dr.

 

      Hammad presented the reanalysis that was conducted

 

      by the FDA based upon the reclassification of

 

      suicidality.  I will not, in the interest of time,

 

                                                               454

 

      attempt to review all the findings, but suffice it

 

      to say it is my impression at this juncture that

 

      that reanalysis reinforced the existence of

 

      association between drug and suicidality.

 

                He also introduced another metric to us,

 

      that of risk difference, something that I think

 

      helps translate the risk into something we can

 

      understand more at the patient level, and said that

 

      overall the risk difference was computed to be 2.3

 

      percent, meaning that two to three out of 100

 

      patients might incur an increase in suicidality

 

      during exposure to one of these antidepressants.

 

                There was also a time-to-event analysis

 

      that I would like to revisit tomorrow.  My

 

      understanding was that Dr. Hammad did not find any

 

      evidence for relationship between time of exposure

 

      to drug and suicidality.  This is certainly

 

      disappointing to me.  It certainly deviates from my

 

      working hypothesis but I think I would like to

 

      understand it a little better.  I know there was a

 

      statistical discussion around the table but I had a

 

      little trouble following it so I hope that tomorrow

 

                                                               455

 

      maybe we can revisit it so I can at least convince

 

      myself that there was no evidence base for earlier,

 

      rather than later, suicidality.

 

                The reason that is important, of course,

 

      in my mind, in addition to a failing hypothesis

 

      that matches your own clinical experience, is that

 

      it does give you hope that by merely--not merely

 

      but by introducing increased vigilance about the

 

      early phases of treatment one can abort of prevent

 

      suicidality if, in fact, the risk is evenly spread

 

      over the course of treatment, or the strategy that

 

      we have adopted is going to be less effective.

 

                Dr. Mosholder then compared the analysis

 

      he conducted with the subsequent analysis based on

 

      the reclassification of the data.  Although there

 

      were some individual differences, for the most part

 

      the findings were in the same range.

 

                Also, a metric that he came up with that I

 

      thought was helpful is in giving some sense of the

 

      magnitude of the suicidality signal.  As he said,

 

      there would be one suicide event every 12

 

      patient-years of drug exposure.

 

                                                               456

 

                During the presentations by industry, one

 

      of the presenters argued not to consider the

 

      medications as a class.  That is one of the

 

      questions before us tomorrow.  He pointed out that

 

      we need to attend to the differences in their

 

      pharmacodynamic as well as their pharmacokinetic

 

      properties.

 

                Another presenter pointed out the

 

      limitations of the data based upon the clinical

 

      trials with regard to understanding the risk of

 

      suicidality, indicating that these studies were not

 

      designed to test the suicidality.  So, this is a

 

      post hoc analysis, and I think we did our best with

 

      the existing data set but there are certainly

 

      limitations based upon how those studies were

 

      designed and the instruments that were used.  There

 

      is also no direct drug-drug comparison.

 

                In the public hearing we once again heard

 

      passionate and moving testimony, and many cases

 

      that, again, seem quite plausible to me that in

 

      some way implicated a role of antidepressants in

 

      suicide.  It was pointed out by other speakers, as

 

                                                               457

 

      well as myself earlier today, that in the process

 

      we cannot forget about all the other individuals

 

      that we think are out there with depression who

 

      have been protected against suicide because of

 

      their treatment.

 

                What didn't we learn today?  We didn't

 

      learn much about the long-term efficacy of the

 

      antidepressant medications.  I think most of the

 

      conventional wisdom and clinical lore about their

 

      effectiveness is not so much based upon the results

 

      of an acute trial but the impression of what

 

      happens over a longer period of time.  The

 

      available data presented here or that I have looked

 

      through do not give us an answer to this very

 

      important question.  There is an overall dearth of

 

      prospective data on the question of efficacy of

 

      antidepressants in the pediatric population.

 

                We also don't have enough information to

 

      know whether some of the events that we might

 

      classify as a result of behavioral toxicity

 

      represent an interaction with an underlying

 

      vulnerability of that individual.  What comes to

 

                                                               458

 

      mind in particular is an individual that might be

 

      bipolar or have a bipolar diathesis.  Or, maybe

 

      there are other factors that are patient specific,

 

      even the way they metabolize the drug, that may

 

      make them more vulnerable to that behavioral

 

      toxicity.

 

                So, I think the work is cut out for us

 

      tomorrow.  What I would ask you to do this evening

 

      in preparation for tomorrow is review the questions

 

      that the FDA has asked us to address.  Some of

 

      those will come to a vote.  I don't think we have

 

      decided which ones yet but I think some of them

 

      will come to a vote, and certainly most will

 

      involve considerable discussion.

 

                One of the decisions I think we are going

 

      to make is in answering the over-arching question,

 

      have we done enough yet.  Has it been enough to

 

      issue warnings to make everyone more vigilant about

 

      possible adverse effects that could lead to suicide

 

      or suicidality?

 

                Is there anything anybody from the

 

      committee would like to add at this point?

 

                                                               459

 

                DR. FOST:  Just one comment that I would

 

      like to have on the record for today's meeting.

 

      Many of the families who spoke in their grief and

 

      anger, understandably, felt a need to find blame or

 

      cause of the tragedies that have befallen them, and

 

      Bob Temple, Tom Laughren and others were sometimes

 

      identified by name and, by implication, others in

 

      the FDA.

 

                I think it needs to be said that these are

 

      all people who work very hard, with great

 

      integrity, to try to find out what the right thing

 

      to do is.  I have no ties, by the way, to any

 

      companies involved in any of these issues.  Bob

 

      Temple, in particular, is I think one of the most

 

      important public servants we have had in this

 

      country in the last 25 years.  I would guess

 

      conservatively that he has saved tens of thousands

 

      of lives, probably hundreds of thousands, by

 

      setting very high standards for the agency to

 

      ensure that drugs that are dangerous do not get

 

      into the marketplace.  So, the notion that he would

 

      be soft on dangerous drugs is just not plausible. 

 

                                                               460

 

      So, I understand the grief and the anger and the

 

      need to place blame, but I think these are not the

 

      people to assign it to.

 

                DR. GOODMAN:  Thank you.  Anyone else that

 

      would like to comment before I give you a few

 

      ground rules?

 

                [No response]

 

                So, before adjourning, I will ask the

 

      members of the committee to take the materials with

 

      them, including the statements received from the

 

      public.  Wear your name tags tomorrow.  I guess

 

      that has been added because some of you haven't

 

      been doing that.  We ask all the FDA presenters to

 

      be prepared with their backup slides--I am sure

 

      they will be--for tomorrow's discussion.  Once

 

      again, I wish to remind the committee to refrain

 

      from speaking to each other about the meeting.  If

 

      I see you together, I assume you are talking about

 

      sports or the weather.

 

                I wish to inform the public that they can

 

      submit their written statements to the FDA through

 

      Dockets Management.  The fliers on the information

 

                                                               461

 

      desk outside the ballroom will explain the

 

      procedure.

 

                Finally, to remind the committee and the

 

      public that the meeting is scheduled to begin

 

      promptly at 8:00 a.m. tomorrow.  We plan to end at

 

      5:00 p.m. but may or may not end early.  Thank you

 

      very much for your attention.

 

                [Whereupon, at 6:10 p.m. the proceedings

 

      were adjourned, to be resumed at 8:00 a.m., on

 

      Tuesday, September 14, 2004.]

 

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