[e-drug] FDC in India

E-DRUG: FDC in India
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The Menace of combo drugs
India should enforce legislation against the Fixed Dose Combination (FDC) drugs.

Deccan Herald, Thursday, 3 April 2008
By Dr Gopal Dabade
www.deccanherald.com/Content/Apr32008/editpage2008040260701.asp [copied as fair use]

The beans have been spilt. This is what happens when top bureaucrats have difference of opinion and bring their differences to the streets. The Drug Controller of India, New Delhi found out that the State Drug Controller of Tamil Nadu, had given licenses to manufacture Fixed Dose Combinations (FDCs) of drugs that he himself would have objected to. What was initially a war of words between the two bureaucrats soon ended with litigation in the High Court of Tamil Nadu.

In a big blow to the Drug Controller of India's efforts to phase out FDCs of drugs from the Indian market, the court has given a stay on a petition filed by Confederation of Indian Pharmaceutical Industries (CIPI), in November 2007.

Combination of drugs
We need to get to some medical jargons before understanding this issue. What are FDCs? FDCs are combination of two or more active drugs presented to the patient (or consumer) in a single dosage form. An example: Paracetamol is a drug used to treat fever and Ibuprofen is a drug used to treat inflammation. When these two drugs are combined and given in a single dosage form it is known as FDC. Text books of medicine or of pharmacology or the medical scientific community do not accept this combination and so this is known as "irrational combination."

And there are several such FDCs in the Indian market! The Drug Controller of India has objected to around 300 FDCs (market worth around Rs 3,500 crore) that the State Drug Controller of Chennai has cleared by giving manufacturing permission to various drug companies.

A group of public health experts who have examined this issue in depth say that there are several such unscientific drug combinations in the Indian market. For example, an analysis of the top-selling 300 drugs showed that that 60 per cent of them are irrational. Further FDCs which account for more than 90 per cent of the total retail sales in India do not find any mention in standard textbooks of medicines.

The list includes several categories, apart from common pain-killers, of drugs like many FDCs of antibiotics, antimicrobials and antidiarrhoeal. Even drugs needed to treat the common conditions like anemia and cough do not confine to standard scientific guidelines and thus are irrational FDCs. The World Health Organisation explicitly mentions that "Indeed, it can be argued that the very existence of an FDC discourages adjustment of doses to the patient's need".

FDCs are not new in the Indian market but what is worrying is that initially it started with few dozen drugs and then they flooded the market in the next two decades.

Need for legislation
Responding to the pressure for newer products, drug companies used to invent combinations of two or more drugs, often launched without an assessment of their therapeutic benefits. In response the Health Ministry has amended the Drugs & Cosmetics Act in 1988 to address this new development.

So the rule 122 (E) of the Drugs & Cosmetics Act requires submission of all relevant pre-clinical and clinical trial data for FDC drugs. In addition, the amendment makes it abundantly clear that the state Drug Controlling authorities have no power to issue licences for FDCs. Most of the State Drug Controllers in any case do not have the expertise or facilities to assess the merits and demerits of drug combinations.

Not all FDC's are bad. In fact FDCs have certain advantages in certain specific and selected situations. Indeed out of the total number of 347 essential drugs mentioned in the latest list of essential medicines by WHO (March 2007), only 26 (7.5 per cent) are acceptable FDCs. Apart from these most of the FDCs are not only unnecessary but are big public health problems.

India needs to take a lesson from its neighbouring Bangladesh. As a result of Bangladesh Drug Ordinance 1982, several hundreds of FDCs were removed from the market. This ordinance was based on the World Health Organisation's essential drug list and recommendations. There is an urgent need in India too to clear the mess. Will it happen? Only time will tell.
   
Dr Gopal Dabade
57, Tejaswinagar
Dharwad 580 002
India
Tel 0836-2461722
Cell (0)9448862270
www.jagruti.org
www.aidanindia.org
www.daf-k.cjb.net

E-DRUG: FDC in India (3)
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Dr Gopal is right. The highest body of drug control DTAB met
recently and found that most of the banned FDCs banned are ILLOGICAL.
In my view most of FDCs emerged due to pharma companies' desire to evade
price controls, and compromised drug adminstration officials.
It is highly regretable that some industry associations have taken the
stance that the drug controller of India has no power to ban a FDC.

V.Bhava Narayana
Editor Pharmed Trade News

3-3-62A, New Gokhale Nagar
Ramthapur. Hyderabad 500 013
INDIA
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URLhttp//www.pharmedtradenews.com

E-DRUG: FDC in India (4)
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Hi,
  
Obviously, the concern of Dr G Dabhade is supportable.
   
There is indeed need to provide some good authorities (rights) to the Drug Controller for legislative action. It should be in a sequential manner with top position being a central body followed by local state structures.

In adddition, the (questionnable) role of pharmaceutical companies shall not be ignored for influencing such process of regulation and control of FDCs especially irrational FDCs in Markets.

What is truley desired is a strict action by regulatory authority (CDSCO New Delhi) for the benefit of common man in India.
   
We can call it as one of the parts of its action, a list of banned drugs with some FDCs is provided on the website of CDSCO.

  or the following link.

  www.cdsco.nic.in/html/Drugsbanned.html
   
Regards,
   
Kiran Chaudhari
MD (Pharmacology)
GMC, Nagpur.
E-mail: kiranchaudhari7@yahoo.co.in

E-DRUG: FDC in India (5)
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Not all FDCs are bad. However, regulation to present the strength of FDCs
is often missing or weak. For example, I have seen 4 different ways to do
it for the same tablet of Sinemet (levodopa and carbidopa):

A) No strength, only a word like 'mite';
B) Only the milligrams of levodopa, 100
C) The sum of milligrams of levodopa and carbidopa, 125
D) The two strengths with a dash between, 25/100. This is the best way to do
it.

When there is more than one strength of an FDC, which amount has changed?
Ingredient A? Ingredient B? Or both ingredients A and B?

I have written an article (2001) and a letter (2006) in Pharmaceutical
Journal in UK about the problem.
http://www.pharmj.com/Editorial/20010623/comment/spectrum.html
http://www.pharmj.com/Editorial/20060325/comment/lett06.html

My recommendation:

For FDCs with fantasy name and two or three active ingredients, as a minimum
the numerical strength should be indicated in the product name.

If denotations (mg, Units) are omitted, the values should be separated by a
dash (solidus) or '+'.

For FDCs with four or more active ingredients the term 'multi ingredient'
should be printed directly beneath the product name.

Stein Lyftingsmo
Hospital Pharmacy of Elverum
Norway
www.lyftingsmo.no