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*, i ‘. ,* Nikch, Hargrave, Devans SCDoyle ,,&torneys and Counselors at Law /j,\ \ t : APU TNERSHlP INCLlJDlNG PROFESSlONAL CORPORATIONS ONE NEW ROCKEFELLER YORK, CABLE: SUITE ROCHESTER, NEW YORK l4.303 1716) 546-8000 CABLE: NIXONHARG ROCHESTER TELEX:978450 1200,1090 VERMONT’ WASHINGTON, (202) D.C. AVENUE, N.W. TELEX: U.S. 1305) September 26, 1983 Dockets Management Branch Food and Drug Administration Department of Health and Human Services Room 4-62 5600 Fishers Lane Rockville, Maryland 20857 PETITION . The undersigned submits this petition on behalf of Thompson Medical Company, Inc. under 21 CFR 10.30 to request the Commissioner of Food and Dugs to open the administrative records in the Over-the-Counter Drug Reviews of W e ight Control Drug Products (Docket No. 81N-0022) and Cold, Cough, Allergy, Bronchodilator, and Antiasthmatic Drug Products (Docket No. 76N-0052N) to accept the enclosed materials relating to the recently-published study conducted at the Intermountain Regional Poison Control Center and Department of Pharmacy Practice, University of Utah, Salt Lake City, Utah. The administrative materials to RevietJ. Action Requested undersigned respectfully requests that the record be opened to permit the enclosed referenced OTC Drug be considered in the B. Statement 10020 NEW YORK 66521 SUITE 510 FiRST NATIONAL BANKOF PALM BEACH B”,LDlNG 842-3600 IO01 A. PLAZA YORK 20005 JUPITER, CITIZEN NEW IZl2) 686-4100 NlXONHARG of Grounds The grounds on which petitioner relies are that phenylpropanolamine hydrochloride (PPA) is one of the ingredients of weight control products and nasal decongestants which are the subjects, respectively, of the above-referenced proposed OTC Drug Products Monographs. The Panel Monographs concluded that PPA and its salts are WlGiiW.4~ FLORIDA 748-1002 ONE 33458 Dockets Management September 26, 1983 Page 2 Branch safe and effective for OTC weight control and oral nasal decongestant use in the specified dosages. The Tentative Final Monograph has not yet been published in either Review. In the preamble to the Advance Notice of Proposed RulemaKing in the Weight Control Drug Products Review (47 Fed. Reg. 8466, et seq., February 25, 1982), the -_-- ---Commissioner requested further studies regarding the safety of PPA for use in weight control products. The enclosed materials summarize a study demonstrating the safety of PPA in weight control products. Since the same ingredient is involved in both types of products, the enclosed materials are highly significant to the agency's OTC Drug Reviews of both weight control and cough/cold drug products. Therefore, these materials should be considered in both Reviews at the earliest possible time c. Certification The undersigned certifies that, to the best knowledge and belief of the undersigned, this petition includes all information and views on which the petition relies, and that it includes representative data and information known to the petitioner which are unfavorable to the petition. & Doyle Suite 1200 1090 Vermont Avenue, N.W. Washington, D. C. 20005 (202) 842-3600 \ SCIENTIFIC . REPORTS l Papers published data anaiysis. and in this section interpretation. arc reviewed . by at least two qualifiel mav Papers accePted result from referees for accuracy, research, critieaf origi,lal s&ntifk experimental des soundness, literature reviews or weI! documented f investigati0nS. API rjc __-_._ESTIPAT!QtI L2m.--'m,,k. Intcrmwrtain (Received June SEV&!K fgp~~&;E$. fK!K-PRESCRil'i'O:! i? 'I-C Ffw -.i--i'jfT A,.*=.L - w.-.-,t-...L , Pharm D and David C Spocrke. Jr, P?S, RPha Brent R Ekins. ;nd Dtpartncnt of P)?arnracy Practice, Regional Poison Control Center 84132 Salt LGkt. City, Utah University of Utah, 18, -V'F TC:"!T.!TY 1381; (!F l!evision Received September The American compulsion to be slim; combined with the conclusions of a non-government advisory panel's recommendations in Narch of 1979 indicating benzocaine and phenylpropanolamine (PPA) in over-thecounter (OTC) weight control products to be safe and effective, have increased the use and the availability of these drugs in American homes. Weight control products obtained without a prescription fall into two classes: spmpathomimetic-containing products and those without. Those without mq- contain vitamins, methylcellulose, benzocaine, fructose, lethicin, and grapefruit extract, The sympathomimetic-containing weight control products may contain any of the above with PPA alone or combined with caffeine. Table 1 lists some of the common commercially available products. thile PPA is reported safe in doses for weight control (11, there are limited data about the toxic effects of PPA when taken in overdose (2-5). There is mounting evidence of serious toxicity when taken in‘ combinat%on with other drugs (6-6) and in hypersensitive persons using normal Caffeine is not an innocuous doses (g-20). drug (12,221. Although serious toxicity from caffeine is rare, its danger is well documented (23-28). Caffeine in combination . _ : With PPA will contribute to the toxicity in possibly both overdosage and in regular " lrIETfIODS i .\ . 1 The patients for this prospective study were either children or adults who had ingested a non-proprietary sympathomimeticcontaining weight control product. The study period was for 5 months. Patients who met the following criteria were included: History of ingestion of a srmpathomimet ictPresent 3400 address: South, Valley west.Valley West City,. 4160 West Hospital, Utah 84120 Vet Hum Toxic01 1362; November Accepted Comonly Available Table 1. lant-containing $98:) 12, Over-The-Counter Appetite Suppressant Stimu- Products P roduc t Hanufacturer PFA (4 Other Sub- Caffeine bg) stances Anorexin Pick Your tlenu Weight Loss Program Anorex in SRA Qharm 2s 100 -- Anorexin SDA Pharm 50 200 -- Appedr ine Kaax Strength Thompson )ledical 2s 100 + Appress Tablets North American 2s 100 -- Ayds Appetite Suppressant Oroptets (0.6 ml”12 drops), Purex 2s 0 -- Extra Strength Putex ‘15 200 -- :“s 200 0 -w- 75 200 -- 75 37-s 200 - Cne-Span Aydr (Red Capsule) Purex Ayds AU/PM Appet i te Sup- pressan t Capsules Yellow Cap. Blue Cap. 1. ; doses. g.y . The purpose of this report is to describe the range of presenting signs and symptoms following ingestion of OTC sympathomimeticcontalng weight control products and to estimate the toxic dose and sequelae from . such overdose. i2, t Cenadex sules Central Cap- Codex in Arco Coffee Break Cubes We i ght Reduction Plan Coffee-Off Coffee. and Pharm O’Conner Drug Westport Qhacm Sates Tea, 25 Hedicat Cant rol rules Cap- Thompson Hedical 75 Con t rot Drops/ Thompson Hedicat 25 0.2 ml-4 drops g* 2 Apr I983 we 2s Thompson a New We 0 I.1 0 -- CD ,#* . : + !” Tib&e i raduc 1 (cant : t* Manufacturer l”Yli PPA hg) Caffeine W Other Sub- Westpoint Pharm Sales 25 0 Day Trim Westpoint Pharm Sales 75 0 75 -- Dexada r PIUS Republ ic Drug 75 Dex-A-Diet Capsule5 (formerly DexA-Diet II) O’Conner \ Drug 75 Dex-A-Diet Drops (formerly Dex-ADiet il)/O.6 O’Conner Drug 25 Dex-A-Diet Lite CapSul es O’Conner Drug 75 0 Dexatrim Capsules Thompson Medical 50 200 Thompson Medical 75 Dexatrim Caffeine-Free Ex Strength Capsules Thompson Medical 75 Diadbx Capsules Tablets O’Conner Drug Dictac Pre*Weal Die& Aid Drops/O.2 ml5 drops SO 200 0 + 1x 0 0 + + Other SUiP stances O’Conner Drug 25 0 + 0 Grapefruit O’tonner Diet Plan Drug Vi th Diadax Ex Strength ViFort if ied tamin Continuous Action Capsules -- Al leghany Hungrex 75 0 + 25 0 wm . Pharmacal -- 200 Hungrex 0 Plus 50 25 ii Uenley James Labs 25 0 ey Labs 25 0 - See Dietcap L Perrigo SO Dietcap withOut Caffeine L Perrigo 75 0 Dietguard Day Diet Whi tehal Lab 2s 0 -- 0 + Pharmex Weight LOSS Group Super 75 0 -we Odrinex Phenopro-75 Ex Strength H K Lab PPA - Max Strength Al leghany Pharmaca 1 Pro-Dax D’Conner Drug 21 66 Prolamine Capsules Thompson kkdical PVH Appetite ‘Control Cap- JB WI 11 iams 140 -- 200 -- 0 w- soles . 75 37.5 I 200 33.33 Alleghany Pharnacal VW ---- 50 Ai leghany Pharmacai Lemmon Odrinex Henley James Labs UL 60 Grapefruit Diet Plan Mi th Diadax Chewable Tablets Ex Strength -- Dibtac Max Strength Capsules Once-A-Day Twice-A-Day Dyna-Slim Sharpe Nationals Capsules Henley James tabs Trim + Caffeine (ms) D’Conner Drug Permathene-12 14 Plan 0 Diet Obestat Uenl 25 Tablets ml James O’Conncr Drug Grapefruit Diet Plan With Diadax Dietac 12 Hr Diet Aid Capsules Diet Grapefruit Chewable 0 0 Republ ic Drug Dietat PreHeal Diet Aid Tablets ?PA (-3) Tablets 25 Ex hanufacturer Plus fluidex Delco Dcxa-Da r Capsules Dexatrim Strength Capsules Product . Cool Down 5 Tablets DelcoPro Tablets Capsules ‘ Present Amoun t ? 75 0 0 200 PVH Appet Suppressant Sip Vet Hum ToxicOt and Slender S1 implan Strength Spant 2.2 Ex Plus rot Spantrol Strength Plus Super 0 i tc EX Odrinex AprT&f JB Williams 25 0 Al leghany Pharmaca I 25 0 Whi teworth 75 200 -- North American 45 50 + North American 75 150 + 25 100 *- Fox Pharmaca I ‘-a vm . - I Table Symptoms. Treatment 3. Total Me Symptomatic Number (2) 19 3 (15.8) 3-5 14 2 (14) 6-12 2 1 (SO) D-2 19 If-2t only 6 (85.7) 7 ,22 l-2 dosage of Phenylpropanolamine/Caffeine Onset of .Symptoms (hr) Ouration 133 10.5 460 40 9 10 150 9.8 500 34 3 11 -4 12 300 8.2 800 22 0 2 575 8.8 1400 26 5 10 680 1s 1 4 1 12t9.48 15 2Ok14.5 5 235 stration (20). Common side effects from overdose associated with PPA include hypertension (2,4,12-X4,19,20), severe headache: (2,4,11-13,191, blurred vision (13). confu. sion (4,5,13,16,18,19), vomiting (2.12.191, and seizures (2,5,13,20).. Caffeine is'8 natur8lly OCCUrring alkaloj is rarely associated with SeriOUS adverse reactions or fatalities (22). A possible explanation for the low frequencv of serious reactions is the high incidence and prominent central nervous of gastritis system side effects with relatively small Pharmacologic effects on the centra doses. nervous and digestive systems can be seen with as littIe a dose as 50 mg. A therapeu tic dose is near 100-200 mg (27). Caffeine stimulates the cerebral cortex, the thalamu the vasomotor and respiratory centers (21, 22,24-27). Cardiac stimulation resulting in a variety of arrhythmias have been repor ed (21,23,25). The combination of caffeine with PPA produces a pharmacologic synergism accentuating some action of each drug. which Physician evaluation was required only Seventy-seven percent 16 times (22.85$). of the time the problem was managed at home with only demulcents to delay absorption or the induction of enesis using syrup managed in Of the patients of ipecac. only two required hospitalizathe hospital, tion, 64% were discharged from the emergency department in ICSS than 4 h, and the remaining discharged in an average of S .25 h . The duration of treatment in the health care facility and the therapy performed are noted in Table 5. The dose at which symptoms developed PPA alone was 17.5 mg/kg. This is not suggestive of a minimum toxic dose, rather a dose that predictably produced symptoms in the study patients. ghen PPA/ caffeine combinations were involved in children (age Q-51, a toxic dose for PPA was close to 10 mg/kg (average total dose was 140 mg). The caffeine doses averaged 37 mg/kg with an average total dose of 480 mg producing symptoms. All adults studied were symptomatic, suggestin* that early demonstrable clinical finding: are expected and that symptoms are not a good early descriminator between the low versus the high end of toxicity. for DISCUSSION Phenylpropanolamine is a sympathomimetic amine structurally similar to amphetamine, ephedrine and metaraminol. The pharmacologic as a direct actions of PPA are described alpha 8drenergiC effect and an indirect acting amine producing release of norepinephrine from storage site at nerve endings Its structural formula protects (8,111. it from rapid degradation allowing for extended duration of action from oral adminiSymptom (Hay be Marc symptom per case) Nausea or Nervousness Headache one Table d : 20 12 10 vomiting 5. Treatment Performed in the Health Care Duration Health of Cafe * Dirz iness Drowsiness Ueakness Disorientation Shortness of breath Hot flashes lncfcased urination Flushed . 6 Numbness 1 : 2 2 1 1 t hands Tine in Facility Treat=ent Performed Ipecac Activated Cathartic Charcoal Intravenous Phenobarbi (hr) 49 I 2 9 5 la hydration tal .I Vet Hum Toxic01 3, 2 Apr 1983 and Duration of Time Facility (Number) the it-‘, 8-14 .I4 8 Tachycardia of I and Frequency No than No Treatment 3 units. Symptom Complaint Ipecac Given <l The type of symptoms and frequency noted the study patients are listed in Table nausea or vomiting, nervousness, 4. Ileadache, .and tachycardia were most often seen. Almost all symptoms appeared within the first In approximately one-third two hours. symptoms persisted for up of the cases, to 6 h. another one-third of the cases . had symptoms for up to 10 to 12 h, and had symptoms persistthe remaining one-third ing for widely varying lengths of time. 4. by Age 2-4 in ‘lable Combination Es t i-mated Dose Ingested B Y Symptomatic Patients PPA Caffeine mg/kg mg mgk mg (hr) 2 (100) 19 and Dosage I ; 1 Table PyAA-fuct 1. I- * rtanufacturer PPA hg) Catlaine h9) Other Substances “‘-in2 Drops/ Alva A m m o -r ml=5 drops Pharmacal 25 O + Thinz BackAlva Amco To-Nature Pharmacal Tablet Reducing Plan - Ex Strength Formula 75 + -- fhi w-Span )lax Strength Alva 75 + WV Trim Down Ajem 75 we UnitroI 75 .a- Plan Diet tepsules 0 0 Vita Slim Thompson hedical 50 0 + Porter and Dietsch 25 25 * Drug Republic Drug CdpSUieS X-11 Rcducing Plan Tablet Amco Pharrnacrl containing weight control product, subsequent treatment, follow-up or evaluation by the poison control center staff or at a treatment facility. All ages were included. For patients evaluated and treated at home, telephone contact was maintained to resolution of symptoms or for twelve hours, whichever was longer. Patients were excluded from the study for the following reasons: ingestion of significant amounts of other .drugs conconunitant with the study drugs, ,lck of satisfactory history, and patients &hose condition was later determined to be of another origin. RESULTS During the five months of the study, a total of 70 patients met the criteria of the study. The data from these patients form the basis of this report. Thirtyfour percent of the patients were male (24) and 652 were female (46) despite a mean even sex ration in the O-5 age group. The ages studied ranged from 9 m to 20 p (mean 5.0 y, SD = 5.74 y) for males, and 13-54 y (mean 13.4 y, SD 12.1 y) for females. The patients were divided into two groups: Those involved with accidental childhood ingestion (9 m to 8 y) and the self-destructrve or substance abuse patients (age llThe ages and sex ratios of the 54. former group were near equal with no striking In the intentional group differences. there is a 1:6.5 ratio of mnles to females and a distribution of ages in females which indicates the m isuse of these substances is not limited to a discrete age group. The preponderance of females using these substances compared to males may be indica‘ive of the more likely purchaser of diet 1.,. ..-.ids. Young adults (ages 13-21 y) Comprised 301. of all cases and almost 75% of the intentional group. Children ages O-5 accounted for 5G?: of all cases seen. Vet Hum Toxic01 2 is a t of the products invol; some cases several non-proprietary *in the 70 cases. ftt products were involved. Dexatr imo (reyl ar or extra-strength 1 products accounted for 71.4% of all the products involved suggesting ready availability in the homes from either advertising or sales success. Both Dexatrimo products are combinations of PPA and caffeine. Ten cases (14.3%) involved only PPA, the remaining 60 cases (85.7%) involved combinations of both PPA and caffeine in varying doses and amounts. No products with only caffeine were involved. None of the PPA-only cases involving children under 14 developed symptoms although small amounts were generally ingested. All of the patients over 14 who ingested The only PPA developed mild symptoms. symptoms described in these four patients included nausea, vomiting, abdominal cramps, headache, hot flashes, diaphoresis, dyspnea, irritability and tachycardia (140 beatsfmin). In patients with only PPA involved, the onset of symptoms was usually within 30 rain to 1 h and the duration of symptoms Only one patient required averaged 13 h. hospitalization. An estimated ingested dose in the symptomatic patients was 17.5 mg/kg. The fixed dosage ratios of PPA to caffeine (Table 1) ranges from a low of 1:l to a at a given dose high of 1:4. Therefore, of PPA the amount of caffeine present in the product may vary by a factor of four. This makes defining the dosages of either PPA or caffeine in combination difficult Table 3 describes with the available data. symptomatic patients by age with the estimated doses of PPA and caffeine ingested and the dose to weight relationship. All patients over age 13 were symptomatic regardChildren less of the history of ingestion. in the O-2$ y age range generally took Table 2. Brands of Diet Aids involved in Seventy Human Poisonings. grand Name Appedrinc Exposures Maximum Strength Control Dex-A-Diet 11 4, 1 5 f -7.1 1 i 1.4 1.4 29 41.4 21 30.0 6 8.6 Hungrex 1 1.4 Permathene-12 1 1.4 Dexatt im Dexatr im Extra Dietac: Pre-Meal Maximum Pre-Real 12 Hour Oiet Strength 1 Aid Tablets Strength Once-A-Day Diet Aid Drops Diet Aid 1 : Qhen-Pro-75 1.4 Super r.4 Qdrinex X-11 2.9 1.4 Unknown 2, 2 Av 1983 6D 5: -_I ..," br caffeine raises questions ;tbout . .+of*PPd with the stxrious react ions nt)ted in earlier published reports. The Gureau of Drugs/FDA is current Ly preparing a report on serious ,-orbidity and mortality assocjated with .iet pills containing PP.%, cnffeine, and cphedr ine, singly or in combination with each other (Kawazo HE: Personal ComqunicaLions. FDA, February 1982). The discrepancy in the severity of reactions in the FDA report and the current study suggests many questions. The incidence of such react ions, their mechanisms of action and the true hazard to the community from such products remains to be addressed. 5. 6. I popularity of OTC diet aids will cant inue to produce signif icant numbers of ingestions, both accidental and intent ional. The results of this study indicate the majority of overdoses involving OTC diet aids wi13. not be serious and may only require decontamination of the digestive care. tract and supportive U’e recommend that emesis be induced with reported ingesmore than tions of diet aids involving 8-10 mg of PPA in children. Deliberate by adults require careful consiingestions derat ion of the history of ingest ion, the agents involved, and the intent of the victim. In most cases, emesis should be induced in all adult poisonings unless there is strong evidence not to. In children a dose of S-10 mg/kg would be expected to produce only mild symptoms; however, the ..impact and trauma of forced emesis is conless hazardous and preferable to c-c’ -&dered ‘-,‘allowing a victim to develop even mild spmptoms. The use of this dose as a cutoff for the induction of emesis is consistent with our clinical impression that amounts tolerated of PPA below this quantity are well and are not expected to result in’any more serious side effects. Obviously, if the history of ingestion cannot reliably be ascertained treatment should be performed. Physicians and poison control centers should recognize that these agents can produce life-threatening cardiac arrhythmias, hypertension, and other serious effects. 7. 8. 9. 10. k8, Senekjian failure due renal fled J 74:1548-lSt9. Salmon PR: HO. to Hypertensive Knight phenylpropanolanine. 1981. crisis with 15. 60-61, Lancet LA: PhenylpropanolamineJAMA 223(3):324-325, LC, Kimura Annals CC: Allergy Allergy &O(l) JJ, Sweet hypotension (Trimolets). 1973. to ~32-34, B, et al: lfyperby induced Hed J Aost I: 1979. of the Lancet appetite suppressant 2 (8132):42-43, 1979. Convulsive seizures due J Hed Sot NJ 76:591-592. to phenyl1979. 1980. reaction caused Am J Psychiat 17. Amphetamine-l ike react ions to phenylDiet2 AJ: JAMA 245:601-602, 1981. propanolamine. , Achor HB, Extein 1: Diet aids, mania, and affecAm J Psychiat I38:392, lYeI. tive illness. le. Paul i MW: oral diet 19% Psychotic agents. 16. Schaffer CB, by proprietary 137:1256-1257, Phenylpropanolamine Whyte JC: Hed J Aust 1:71.5, 1981. 19. Elliott CF. hypertension. 20. Bernstein E, Diskant BM: Phenylpropanolamine: Ann Emerg a potentially hazardous drug. 311-315, 1982. Turner JE, Cravey RH: A fatal ingestion caffeine. Clin Tox lO(3) :341-344, 1977. 22. 23. 1 24. 28. t&Gee MB: Caffeine J Forensic female. Josephson CW, Stine a case of paroxysmal 5~776-778, 3, and Med 11: of poisoning in a 19 year oid Sci 25(1):29-32, 1980. RJ: Caffeine intoxication: atria1 tachycardia. JACEP 1976. Sul! ivan JL: Caffeine poisoning in an infant. J Peds YO66):1OZ2-1023, 1977. Kulkarni PB. Dorand RD: Caffeine toxicity in neonate. Pediatrics 64(2) :254-255, 1979. a Shen W, D’Souza TC: Cola-induced psycotic organic brain syndrome. Rocky Mt Ned J 76(6):312313. 1979. Banner U, Czajka overdose in PA: Acute caffeine the neonate. Am J Dis Child 134:495-498. 1980. MY DC, 2 Long T. secondary Emerg Toxic01 indomathacin. Hypertension and cerebral hemorrhage King J: Hed J Aust 2~258, after trimolets ingestion. 1979. Hcrowitz JD, Lang WJ, Xwes LG, et al: Hywrtensive responses by phenylpropanoiamine in Jnorectic Lancet 1 (8159): and decongestant preparations. Eskarnade. Hun RB, Vasquez arrhythmias. Speer F, Carrasco phenylpropanolamine, city Vet with 1979. 14. 1: acute South Peterson induced Vandongen R: Severe Hyper tenaf an appetite suppressant Deocampo PO: propanoiamine. after Sci 25: at: Lee KY, Beilin LJ, sion after ingestion (phenylpropanolamine) 1 (8126):1110-1111, 13. 27. et Cuthbert fiF, Greenberg HP, Morley SW: cough and cold rerredies: a potential danger to patients on monoamine oxidase inhibitors. Br tied J 1: 404-406, 1969. Mctaren EH: Severe hypertension produced by interaction of phenylpropanolamine with methyldopa and oxprenolol. Brit Hed J 2:283-284, 1976. 175-176. 26. TF, Pheny]Lancet Bennett WH: Hazards phenylpropanolamine. 25. Ouffy G: 12. REFERESCES outcome of J Forensic Lonnerholm disturbances. 1979. Jb, &Neil tension and postural phenylpropanolamine 21. Reports thwenias G, Wiaerlov E, propanolamine and mental 1978. 11. Horowitz The challenge to pharmacists and physicians is fo educate the consuming public to the safety and proper use of these and other substances for weight reduction. Treatment of serious adverse reactions or overdosage with OTC diet aids will continue to be a clinical problem as long as the public demand for this method of weight control . remains constant. Consumer ‘03. 1: 13;’ 2:1367-1368, The likely Anon : The new diet pills. ~4-16, 1982. Delayed fatal Patterson FK: possible Ru-tussz overdose. 349-352, 1ycvo. Med J Apr ned 1993 tO:549, Madden to street 1981. Caffeine R, et al: drug ingestion. toxiAnn