Narcotics research, rehabilitation, and treatment. Hearings, Ninety ...

Narcotics research, rehabilitation, and treatment. Hearings, Ninety ... Narcotics research, rehabilitation, and treatment. Hearings, Ninety ...

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420[Exhibit No.17(a)]Statement of John Jennings, M.D., Associate Commissioner for MedicalAffairs, Food and Drug Administration, Department of Health, Education,AND WelfareMr. Chairman and members of the committee, I am Dr. John Jennings, AssociateCommissioner for Medical Affairs. The committee has been supphed with acopy of my education and professional background. Commissioner Edwards hasasked me to extend his regrets that a previous commitment prevents his being hereto discuss with j-ou current research in the treatment of narcotic addiction.We are all aware of the extent of the drug abuse problem and the increasingpublic concern about heroin addiction, in particular. A variety of therapeuticapproaches, many with some partial success, have been utilized over the pastseveral yesirs—ranging from chronic hospitalization through residential programssuch as Synanon, to outpatient psychotherapeutic efforts. The time, manpower,and money required in all of these approaches have resulted in only limited success,making a successful chemical therapeutic agent an attractive alternative.This has resulted in a search for a medication that would block the euphoriceffect of herion for addicts, prevent withdrawal symptoms, be eJBfective orally, longacting, free from toxic effects, and compatible with normal performance andreasonable behavior. The addict would have to be freed of his craving or hungerfor heroin.Methadone is currently under study for the maintenance treatment of narcoticaddiction. It has been an effective analgesic since it was synthesized at the end ofWorld War II. Although for more than a decade it has been known that low oraldoses of methadone would allay withdrawal symptoms, not until 1963 was itfirst observed that large oral doses could block the euphoric effects of even highdoses of other opiates or synthetic narcotics. Thus, the current widespread interestin methadone for the maintenance treatment of heroin addicts.Methadone is a marketed drug that has been approved through the newdrug procedures for three specific uses: As an analgesic, an antitussive, and fortreatment of withdrawal symptoms in heroin addiction. The last refers to theshort-term treatment of the acute symptoms resulting from the withdrawal ofheroin from those who have become physiologicalh^ dependent.Maintenance treatment of heroin addiction with methadone is investigationalbecause substantial evidence of its safety and effectiveness for this use is not yetavailable. Although there are studies which suggest that methadone maintenancemay be effective for some heroin addicts over a period of at least months, andperhaps a few years, we are only now beginning to obtain the kind of informationwhich may eventuall}' permit us to define the place of this drug in the treatmentof heroin addiction.Because it was available on prescription, the use of methadone for maintenancetherap.y became quite widespread following the early reports of success by Doleand Nyswander.In order to collect the type of scientific data needed to support approval of anew use of a drug, it was necessary that the maintenance programs follow protocols,including recordkeeping, that could yield such data. Investigational studies ofmethadone present problems not encountered in studies with other types of drugsbecause it is an addicting narcotic with a proven capacity for abuse.Therefore, to protect the community from the hazards of diversion and abuse,and to assure the development of valid data, guidelines for methadone maintenancestudies were developed tlirough the cooperation of the National Instituteof Mental Health, the Bureau of Narcotics and Dangerous Drugs, and the Foodand Drug Administration. These guidelines were published in the Federal Registeron April 2, 1971. Prior approval of both the Food and Drug Administration andthe Bureau of Narcotics and Dangerous Drugs, Department of Justice, is requiredbefore such studies may be initiated.Heroin addicts do not constitute a homogeneous population and proper treatmentrequires that we have some knowledge about which addicts may benefitfrom this treatment approach in contrast to other tht^rapy.Some investigators have reported that 70 to 80 percent of treated addicts arerehabilitated as judged bj^ reduction in criminal activity, improvement in employmentstatus, or schooling. Most of these reports, however, have not given adequateconsideration to the bias produced by patient selection. Some idea of the difficultyof interpreting such studies can be gained from a most recent evaluation of one

421of the best known programs. Although the program had a very broad criteria foradmission, more applicants were not admitted to the study than were admitted.In general, those patients admitted to the study and remaining in treatment,when compared to the overall heroin addict population, tended to be older, moreoften white, and in better health. This group, which had an improved employmentstatus and reduced criminahty, was not representative of the total heroin addictpopulation. Therefore, this study, as well as others reported to date, cannot beused to generahze the results to the entire addict population.Whether those not accepted for treatment would have fared as well as thoseaccepted is unanswered. Reports have not provided the kind of data that enablesbetter patient selection. Also, data are needed to distinguish the role played bythe drug itself from the role played by the psychological, social, and occupationalrehabilitative efforts in such programs; a mai'ked proliferation of programs mayproduce many in which only the drug is used and no rehabilitation is provided.Methadone maintenance treatment ma}' be a valuable therapy in reducingheroin addiction, but we believe it is wise to proceed cautiously in moving towardits general prescription use for this purpose. We need better evidence to determinethe safet.y of this treatment. One of the hazards of methadone treatment is thatyoung drug users who are not ph3'siologicall3' dependent on heroin might becomeaddicted to methadone as a result of treatment. We do not wish to have a potentiallyvaluable therapy discredited because of its misuse by some practitionerswhile its efficacy is being evaluated.We now have 257 investigational new drug exemption (IND) numbers assignedto sponsors representing 277 methadone treatment programs. We have requested6-month status reports from these programs instead of the customary annualreports, in order to obtain adequate data as soon as possible.We expect our recently published regulations to serve as a valuable tool ininsuring compliance with existing requirements. In this regard, we have recentlyundertaken a program for the inspection of all methadone maintenance studies.By mid-July, we will have completed inspection of an initial 40 to 50 programsthroughout the country, selected on the basis of various criteria.In addition to achieving correction of any deficiencies, we hope to stimulateimproved practices and better data collecting procedures. In these inspections,whenever possible, medical officers from our Bureau of Drugs will accompanydistrict field inspectors. Bj^ the end of the year all programs will have been inspected.All of this will be done in close cooperation with the Bureau of Narcoticsand Dangerous Drugs, which in addition has its own program for surveillance ofthe methadone studies.When necessary, a sponsor will be given a time limit to correct deficiencies orface loss of his investigational status. However, before a program is terminated,we will contact local health departments, medical societies, and other approvedmethadone maintenance programs in an effort to insure that continuing treatmentfor the addicts is available.In addition to review by our own personnel, we have appointed a committee ofoutside experts to assist in evaluating data as it accumulates, as well as otheraspects of the ongoing programs. The committee will also be called on to assistin reviewing any new drug applications for methadone maintenance.The concept of narcotic blockade has stimulated a search for other drugs, drugswith no addicting potential, with greater safet.y and of longer duration thanmethadone. Acetylmethadol promises some hope in that its duration of action is72 hours in contrast to the 24 hours in which methadone remains effective. Thus,an addict could take his medication, even under supervision, on a twice weeklybasis. However, the possible toxicity of acetylmethadol needs further study.Cyclazocine is another narcotic antagonist that has been studied for the treatmentof heroin addiction. Its use has been limited, however, because it has somenarcotic actions of its own, can produce respiratory depression, and may beaddicting.Naloxone, recently approved for marketing as a narcotic antagonist, has somesimilarity to cyclazocine but lacks its narcotic actions, and in particular, does noproduce respiratory depression. Naloxone has no reported addictive potential buits short duration of action, 4 to 6 hours, limits its usefulness. It has also, likecyclazocine, been tested on a pilot study basis for the treatment of heroin addiction.It is hoped that similar agents having the properties of naloxone but a longerduration of action can be synthesized.To reduce the availability of addictive drugs, a variety of agents are beingsynthesized and tested to obtain a potent analgesic with no abuse potential. Four

421of the best known programs. Although the program had a very broad criteria foradmission, more applicants were not admitted to the study than were admitted.In general, those patients admitted to the study <strong>and</strong> remaining in <strong>treatment</strong>,when compared to the overall heroin addict population, tended to be older, moreoften white, <strong>and</strong> in better health. This group, which had an improved employmentstatus <strong>and</strong> reduced criminahty, was not representative of the total heroin addictpopulation. Therefore, this study, as well as others reported to date, cannot beused to generahze the results to the entire addict population.Whether those not accepted for <strong>treatment</strong> would have fared as well as thoseaccepted is unanswered. Reports have not provided the kind of data that enablesbetter patient selection. Also, data are needed to distinguish the role played bythe drug itself from the role played by the psychological, social, <strong>and</strong> occupationalrehabilitative efforts in such programs; a mai'ked proliferation of programs mayproduce many in which only the drug is used <strong>and</strong> no <strong>rehabilitation</strong> is provided.Methadone maintenance <strong>treatment</strong> ma}' be a valuable therapy in reducingheroin addiction, but we believe it is wise to proceed cautiously in moving towardits general prescription use for this purpose. We need better evidence to determinethe safet.y of this <strong>treatment</strong>. One of the hazards of methadone <strong>treatment</strong> is thatyoung drug users who are not ph3'siologicall3' dependent on heroin might becomeaddicted to methadone as a result of <strong>treatment</strong>. We do not wish to have a potentiallyvaluable therapy discredited because of its misuse by some practitionerswhile its efficacy is being evaluated.We now have 257 investigational new drug exemption (IND) numbers assignedto sponsors representing 277 methadone <strong>treatment</strong> programs. We have requested6-month status reports from these programs instead of the customary annualreports, in order to obtain adequate data as soon as possible.We expect our recently published regulations to serve as a valuable tool ininsuring compliance with existing requirements. In this regard, we have recentlyundertaken a program for the inspection of all methadone maintenance studies.By mid-July, we will have completed inspection of an initial 40 to 50 programsthroughout the country, selected on the basis of various criteria.In addition to achieving correction of any deficiencies, we hope to stimulateimproved practices <strong>and</strong> better data collecting procedures. In these inspections,whenever possible, medical officers from our Bureau of Drugs will accompanydistrict field inspectors. Bj^ the end of the year all programs will have been inspected.All of this will be done in close cooperation with the Bureau of <strong>Narcotics</strong><strong>and</strong> Dangerous Drugs, which in addition has its own program for surveillance ofthe methadone studies.When necessary, a sponsor will be given a time limit to correct deficiencies orface loss of his investigational status. However, before a program is terminated,we will contact local health departments, medical societies, <strong>and</strong> other approvedmethadone maintenance programs in an effort to insure that continuing <strong>treatment</strong>for the addicts is available.In addition to review by our own personnel, we have appointed a committee ofoutside experts to assist in evaluating data as it accumulates, as well as otheraspects of the ongoing programs. The committee will also be called on to assistin reviewing any new drug applications for methadone maintenance.The concept of narcotic blockade has stimulated a search for other drugs, drugswith no addicting potential, with greater safet.y <strong>and</strong> of longer duration thanmethadone. Acetylmethadol promises some hope in that its duration of action is72 hours in contrast to the 24 hours in which methadone remains effective. Thus,an addict could take his medication, even under supervision, on a twice weeklybasis. However, the possible toxicity of acetylmethadol needs further study.Cyclazocine is another narcotic antagonist that has been studied for the <strong>treatment</strong>of heroin addiction. Its use has been limited, however, because it has somenarcotic actions of its own, can produce respiratory depression, <strong>and</strong> may beaddicting.Naloxone, recently approved for marketing as a narcotic antagonist, has somesimilarity to cyclazocine but lacks its narcotic actions, <strong>and</strong> in particular, does noproduce respiratory depression. Naloxone has no reported addictive potential buits short duration of action, 4 to 6 hours, limits its usefulness. It has also, likecyclazocine, been tested on a pilot study basis for the <strong>treatment</strong> of heroin addiction.It is hoped that similar agents having the properties of naloxone but a longerduration of action can be synthesized.To reduce the availability of addictive drugs, a variety of agents are beingsynthesized <strong>and</strong> tested to obtain a potent analgesic with no abuse potential. Four

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