CHAPTER 1 Introduction: The Nature of Drugs & Drug Development & Regulation reveal unpredictable benefits and toxicities but do not gener-ally test a prespecified hypothesis and cannot prove cause and effect. Analytic epidemiologic studies consist of observations designed to test a specified hypothesis, eg, that thiazolidinedi-one antidiabetic drugs are associated with adverse cardiovascu-lar events. Cohort epidemiologic studies utilize populations of patients that have (exposed group) and have not (control group) been exposed to the agents under study and ask whether the exposed groups show a higher or lower incidence of the effect. Case-control epidemiologic studies utilize populations of patients that have displayed the end point under study and ask whether they have been exposed or not exposed to the drugs in question. Such epidemiologic studies add weight to conjectures but cannot control all confounding variables and therefore cannot conclusively prove cause and effect. Meta-analyses utilize rigorous evaluation and grouping of sim-ilar studies to increase the number of subjects studied and hence the statistical power of results obtained in multiple published studies. While the numbers may be dramatically increased by meta-analysis, the individual studies still suffer from their varying methods and end points, and a meta-analysis cannot prove cause and effect. Large randomized controlled trials (RCTs) are designed to answer specific questions about the effects of medications on clinical end points or important surrogate end points, using large enough samples of patients and allocating them to con-trol and experimental treatments using rigorous randomization methods. Randomization is the best method for distributing all foreseen confounding factors, as well as unknown confounders, equally between the experimental and control groups. When properly carried out, such studies are rarely invalidated and are considered the gold standard in evaluating drugs. A critical factor in evaluating the data regarding a new drug is access to all the data. Unfortunately, many large studies are never published because the results are negative, ie, the new drug is not better than the standard therapy. This missing data phenomenon falsely exaggerates the benefits of new drugs because negative results are hidden. *I thank Ralph Gonzales, MD, for helpful comments.
The Food & Drug Administration
The FDA is the administrative body that oversees the drug evaluation process in the USA and grants approval for marketing of new drug products. To receive FDA approval for marketing, the originating institution or company (almost always the latter) must submit evidence of safety and effectiveness. Outside the USA, the regulatory and drug approval process is generally similar to that in the USA.
As its name suggests, the FDA is also responsible for certain aspects of food safety, a role it shares with the US Department of Agriculture (USDA). Shared responsibility results in complications when questions arise regarding the use of drugs, eg, antibiotics, in food animals. A different type of problem arises when so-called food supplements are found to contain active drugs, eg, sildenafil analogs in “energy food” supplements.
The FDA’s authority to regulate drugs derives from specific legislation (Table 1–5). If a drug has not been shown through adequately controlled testing to be “safe and effective” for a specific use, it cannot be marketed in interstate commerce for this use. *
Unfortunately, “safe” can mean different things to the patient, the physician, and society. Complete absence of risk is impossible to demonstrate, but this fact may not be understood by members of the public, who frequently assume that any medication sold with the approval of the FDA should be free of serious “side effects.” This confusion is a major factor in litigation and dissatisfaction with aspects of drugs and medical care.
The history of drug regulation in the USA (Table 1–5) reflects several health events that precipitated major shifts in public * Although the FDA does not directly control drug commerce within states, a variety of state and federal laws control interstate production and marketing of drugs.