叙述性回顾:FDA对膳食补充剂法规的敷衍态度导致了大量不良事件的报告。

Innovations in Pharmacy Pub Date : 2023-10-10 eCollection Date: 2023-01-01 DOI:10.24926/iip.v14i1.4989
WeiQi Li, Albert Wertheimer
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Products which showed highest prevalence in adverse event reports through the Food and Drug Administration CFSAN Adverse Event Reporting System (CAERS) included but not limited to; Vitamin E (vitamin derivative), Beta-sitosterol (plant sterol) Yohimbine, Kava Kava Kratom, Garcinia Cambogia, (herbal products) and OxyElite Pro (marketed weight loss product). The primary endpoint was evaluating the FDA's regulations on dietary supplement safety protocols. The secondary endpoint was assessing the actions of the FDA in response to these case events. <b>Results</b>: Overall, between 2004 to 2021, a total of 79,071 adverse events related to the use of dietary supplements were reported to the Center for Food Safety and Applied Nutrition. Vitamin E products for example, marketed for decades for their antioxidant benefits in turn have shown significant evidence of toxicity and an increased risk of bleeding outweighing its potential benefit. 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引用次数: 0

摘要

背景:美国食品和药物管理局(FDA)起源于1906年通过的《纯净食品和药品法案》,旨在遏制消费品市场中长期存在的滥用行为。该法案的通过是为了禁止州际间的商标错误和掺假的食品、饮料和药品的贸易。因此,促进FDA的使命,通过监管人类和兽药,生物制品,医疗器械,食品供应,化妆品和烟草来保护公众健康,以确保安全性,有效性和安全性。1994年,膳食补充剂健康和教育法(DSHEA)进一步制定,规定了具体的标签要求,提供了监管框架,并授权FDA颁布膳食补充剂的良好生产规范。该法案将“膳食补充剂”和“膳食成分”定义和分类为食品,要求所有非处方产品(OTC)都包含易于理解的标签,并符合FDA的质量,有效性和安全标准。然而,在OTC产品的保护伞下,FDA在对庞大的膳食补充剂市场的监管方面做得不够。这项研究的目的是辨别FDA对OTC膳食补充剂的规定缺乏功效是如何不可避免地激发了弊大于利的。方法:本综述包括案例研究,包括年轻的青少年和成年消费者,他们经历了使用膳食补充剂的不良事件。在美国食品药品监督管理局(CFSAN)不良事件报告系统(CAERS)中,不良事件报告发生率最高的产品包括但不限于;维生素E(维生素衍生物),β -谷甾醇(植物甾醇)育喜宾,卡瓦Kava Kratom,藤黄果(草药产品)和OxyElite Pro(上市减肥产品)。主要目的是评估FDA对膳食补充剂安全协议的规定。次要终点是评估FDA对这些病例事件的反应。结果:总体而言,2004年至2021年间,食品安全和应用营养中心共报告了79071起与膳食补充剂使用相关的不良事件。以维生素E产品为例,数十年来一直标榜其抗氧化功效,但事实证明其毒性和出血风险的增加超过了其潜在益处。FDA的回应只是简单地实施了标签指南的更新,然而随着病例数量的逐渐增加,这一更新的效果微乎其微。同样,草药产品,如卡瓦卡瓦、育喜宾、克拉托姆和藤黄果,以及体重调节产品,如OxyElite Pro和HydroxyCut,分别与器官衰竭、肝脏、肾脏、心脏毒性和死亡有关。美国食品和药物管理局的回应仅仅是对公众消费者发布警告,警告他们的消费影响,并对某些产品进行有限的召回。结论:由于这些产品的易用性,一般公众更倾向于在没有医疗团队适当指导和监督的情况下使用,这是可能出现的相互作用、禁忌症和不良后果的主要担忧。在更多关于疗效和安全性的研究发现后,如果适当实施严格的法规,不良事件的病例可能会大大减少或完全避免。FDA的极简主义努力只包括上市后监测和标签修改的回顾性行动,这在越来越多的报告中一次又一次地显示出缺陷。通过修改非处方补充剂的审查过程来反映处方药的审查过程,可以减少不良事件的严重程度。除临床研究外,该过程还应包括临床前研究,FDA在批准前对数据进行彻底检查和上市后监督。
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Narrative Review: The FDA's Perfunctory Approach of Dietary Supplement Regulations Giving Rise to Copious Reports of Adverse Events.

Background: The Food and Drug Administration (FDA) originated from the passage of the 1906 Pure Food and Drugs act aimed to rein in the long-standing abuse in the consumer product marketplace. The act was passed to prohibit interstate commerce of misbranded and adulterated foods, drinks, drugs. Thus, promoting the FDA's mission to protect the public health by regulating human and veterinary drugs, biological products, medical devices, food supply, cosmetics, and tobacco to ensure safety, efficacy, and security. Progressing further in 1994, the Dietary Supplement Health and Education Act (DSHEA) was established designating specific label requirements, providing regulatory framework, and authorizing the FDA to promulgate good manufacturing practices for dietary supplements. This act defined and classified "dietary supplements" and "dietary ingredients" as food requiring all over the counter products (OTC) products to consist of labeling that is easy to understand and meets the FDA quality, effectiveness, and safety standards. However, under the umbrella of OTC products, the FDA fell short in its regulation of the expansive dietary supplement market. The objective of this study is to discern how the lack of efficacy in the FDA's regulations of OTC dietary supplements inevitably inspired more harm than benefit. Methods: This review comprised of case studies including young adolescents and adult consumers who experienced adverse events from the use of dietary supplements. Products which showed highest prevalence in adverse event reports through the Food and Drug Administration CFSAN Adverse Event Reporting System (CAERS) included but not limited to; Vitamin E (vitamin derivative), Beta-sitosterol (plant sterol) Yohimbine, Kava Kava Kratom, Garcinia Cambogia, (herbal products) and OxyElite Pro (marketed weight loss product). The primary endpoint was evaluating the FDA's regulations on dietary supplement safety protocols. The secondary endpoint was assessing the actions of the FDA in response to these case events. Results: Overall, between 2004 to 2021, a total of 79,071 adverse events related to the use of dietary supplements were reported to the Center for Food Safety and Applied Nutrition. Vitamin E products for example, marketed for decades for their antioxidant benefits in turn have shown significant evidence of toxicity and an increased risk of bleeding outweighing its potential benefit. The FDA's response was simply implementing a label guideline update, yet this update had evidence of minimal effect as the number of cases gradually continued to increase. Likewise, herbal products such as Kava Kava, Yohimbine, Kratom, and Garcinia Cambogia, in addition to weight regulating products, such as OxyElite Pro and HydroxyCut, have been linked to organ failure, hepatic, renal, cardiac toxicity, and death respectively. The FDA merely responded through instating public consumer warnings of their effects with consumption and limited recalls of certain products. Conclusion: With the easy accessibility of these products, the general public is more inclined to its use without proper guidance and monitoring from their healthcare team, posing as a major concern for possible interactions, contraindications and unfavorable outcomes. With proper implementation of stringent regulations post findings from increased studies on efficacy and safety, cases of adverse events could have been reduced significantly or averted completely. The FDA's minimalistic efforts consisting of only post-marketing monitoring and retrospective actions of label modifying have time and time again shown flaws as seen in the growing series of reports. By emending the over-the-counter supplement review process to reflect that of prescription medication, the magnitude of adverse events can be diminished. The process should include preclinical research in addition to clinical research, FDA thorough examination of data prior approval and post marketing surveillance.

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