Case Study:  Francis Kelsey & Thalidomide in the US

This case study tells the story of Dr. Frances Kelsey of the Food and Drug Administration (FDA) and the drug thalidomide. The story illustrates the process by which drugs are approved and regulated in the U.S. It also shows the importance of actions of individual scientists.

Background Relating to Pharmaceutical Regulation:

The quality of food and drugs was virtually unregulated until the early 1900’s. The novel, The Jungle, by Upton Sinclair described the alarming practices in the food industry. People were so outraged by his descriptions that Congress passed a law to help regulate the production of food and drugs. In 1927, a separate law enforcement agency, known as the FDA, was formed to enforce food and drug laws. A complex process for safety-testing new drugs has evolved, along with a requirement that new drugs be safe and effective.

bulletThe idea for a drug product is first researched in the laboratory.
bulletIf the drug shows promise, tests are performed in animals to determine how the drug is handled in the body and whether it is safe for human testing. (In 1975, the FDA instituted the Good Laboratory Practice regulations to control studies of drug in animals.)
bulletIf it appears safe in animal studies, investigators prepare a plan to investigate the product on human volunteers. They must submit their plan to the FDA for approval before they move into human testing.
bulletThe drug must go through three phases of human testing.
bulletIf a drug passes all three phases, the company may submit an application, called a New Drug Application (NDA) to the FDA documenting their evidence that the drug is safe and effective.
bulletIf the FDA approves the application, it can now be manufactured for sale.

The Beginning of the Thalidomide Story:

Thalidomide was first synthesized in 1953 and early tests in animals and humans indicated that the drug had little toxicity and that, in humans, it promoted sleep, although it did not have any sedative effect on animals. It was introduced in West Germany in 1957 and it soon became a popular sleeping pill, taken by both adults and children. It appeared to have little ill effects when ingested in large quantities and was thought to be so safe, that it did not require a prescription. Moreover, the drug prevented nausea due to pregnancy and was used for this purpose.

The German manufacturer of this drug began to license the distribution of thalidomide in other countries. In September, 1960, the FDA received an NDA from the American pharmaceutical firm, Merrell, who wanted to distribute thalidomide in this country. The NDA contained glowing claims for the drug and it was considered to be a routine approval. Its investigation was given to the newest medical officer, Dr. Frances Kelsey. Dr. Kelsey held a PhD. Degree in pharmacology and a medical degree. She worked as an editorial associate for the Journal of the American Medical Association. She reported, "I soon learned…that good scientists are almost invariably good writers and the poor writing is often a sign of poor science..when I came to FDA…, I found that many of the studies in support of safety of the new drugs were done by investigators whose work had not been accepted for publication in the Journal."

Questions:

bulletOutline the steps that the Merrell Company needed to go through to have thalidomide approved in the U.S.?
bulletIf you were Dr. Kelsey, what sort of scientific studies would you be looking for in the thalidomide NDA?
bulletIf you were Dr. Kelsey, would you approve the drug for distribution in the US? (consider its use in Europe)

Dr. Kelsey Reviews the Application

Several problems were noted in the NDA:

bulletThe chronic toxicity data were incomplete (no evaluations could be made in regard to its safety when used over prolonged periods of time.)
bulletA chemist found deficiencies relating to details of the manufacturing processes and the methods used to determine the strength and purity of the new drug.
bulletReviewers were concerned that thalidomide did not put animals to sleep because this suggested that there are differences in the way that humans and animals absorb or metabolize the drug. (This made the animal studies suspect.)

At the same time, the Merrell Company was anxious to get the drug approved and was pressuring the FDA to do so. Dr. Kelsey resisted. Five months into the process, Dr. Kelsey learned of the following problems:

bulletPatients who had used the drug for prolong periods were experiencing deterioration of the nerves in the hands and feet. Merrell responded by saying that this occurred rarely and was reversible. They were willing to put this side effect on the label.
bulletThalidomide was being used by pregnant women and the FDA wanted to consider the possibility that the fetus could be harmed by the drug. Merrell responded by showing studies in mice that showed it to be safe in the third trimester of pregnancy, but the FDA wanted studies showing the it was safe throughout gestation. Merrell wanted to release the drug with a warning saying the studies had not yet established its safety during pregnancy. Dr. Kelsey did not accept this suggestion.

Questions:

bulletIf you were an FDA reviewer, what would you have done at this point?
bulletDr. Kelsey was under tremendous pressure to approve thalidomide. Why do you think she resisted this pressure?

The Story Continues:

In November 1961, more than a year after the application was submitted to FDA, thalidomide was withdrawn from the German market because of congenital abnormalities in children born to mothers who had used it. By 1962 the evidence was overwhelming that it caused crippling malformations of the arms and legs. Many of these victims were born with hands and feet protruding directly from their torsos and others had limbless trunks with toes extending from their hips; others were born with just a head and a torso; still others had cardiac problems. It is estimated that 8,000 to 80,000 thalidomide-deformed babies were born in Europe. Thanks to the skepticism of Dr. Kelsey and others at the FDA, this tragedy was largely averted in the US.

(There were 10 well-documented cases of women who had received thalidomide during pregnancy and delivered seriously deformed babies in the US. Apparently this was the result of Merrell’s distribution of thalidomide to more than 1000 physicians during the time that the NDA was reviewing the drug. At the time, this was not illegal.)

Questions:

bulletHow can you explain the wide disparity in the estimate of victims in Europe?
bulletWhat is your reaction to Dr. Kelsey and her team?

Political Implications:

Dr. Helen Taussig, a physician, wrote articles and gave speeches on the effects of thalidomide in Europe and tried to bring this story to the attention of the American people. Senator Estes Kefauver of Tennessee had been involved in investigating the drug industry and, reading about Dr. Taussig’s crusade, decided to promote the story to help the passage of his bill to strengthen the regulation of drug testing in humans so that physicians could not casually distribute investigational drugs. The bill, known as the Kefauver-Harris Drug Amendments to the FDCA was passed in 1962.

What Ever Happened to Thalidomide?

The drug is now known to have complex, multiple effects on the body. It inhibits new blood vessel growth (angiogenesis). This growth provides a "road map" for the growth of limbs and organs during development. Interestingly, despite its devastating effects on the fetus, it may be useful in treating some diseases like cancer because it inhibits angiogenesis. Israeli physicians discovered that leprosy patients given the drug to help them sleep also experienced healing of the painful lesions that accompany leprosy. In 1998 the FDA approved thalidomide for the treatment of leprosy.

Questions to Ponder:

bulletAIDS patients complain abut the slow rate at which drugs are developed to treat their illness. The drug companies attribute the slowness to stringent drug testing. The FDA has provided avenues by which these patients can obtain drugs that have not been fully tested. What do you think about this "fast tracking" of AIDS drugs?
bulletCurrently, herbal preparations are not required to meet the requirements enforced by the FDA. Many argue that if they must undergo the same stringent testing procedure, they will become quite expensive. What do you think?
bulletYou have been hired to represent the pharmaceutical industry. What are your responsibilities to the public? What is your opinion about government regulation?
bulletRecently baseball pitcher Steve Bechler died unexpectedly and the weight loss supplement, ephedra, was implicated in his death. Read the article, FDA To Put New Rules on Dietary Supplements, and discuss how the 1994 Dietary Supplement Health and Education Act impacted drugs like ephedra.  Do you think the new rules on dietary supplements go far enough in light of the ephedra controversy?
bulletRead the article, Beyond Botox: An Industry's Quest for Smooth Skin.  Imagine that you are the scientist investigating these new procedures.   How would you design your study?
bulletRead FDA Requires Barcodes on Drugs and explain the FDA's role in assuring patient safety in hospitals.

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