Title: Risk Management and the Controlled Substances Act: The FDA Perspective
1Risk Management and the Controlled Substances
Act The FDA Perspective
- Deborah B. Leiderman, M.D., M.A.
- Director
- Controlled Substance Staff
- Center for Drug Evaluation and Research
- Food and Drug Administration
2Controlled Substances Act (CSA) 1970
- Enacted to comply with international treaties and
efforts to combat drug trafficking and to assure
drug availability for legitimate medical use - Established five schedules and levels of control,
CI-V - Drug classes opioids, depressants, stimulants,
hallucinogens
3CSA 1970
- Schedule I (CI)
- Most restrictive
- Reserved for drugs with high abuse potential and
no recognized medical use - Examples heroin, LSD
- Schedule II-V (CII-V)
- Descending abuse potential and restrictions
- Drugs have medical use in U.S.
4Schedule II Opioid Analgesics
- Highest level of control for drugs with
recognized medical use - Highest potential for abuse abuse potential
comparable to CI drugs - Pose the greatest risk to the public health
5Schedule II Opioid Analgesics
- Health care system, medical practice, and
prescribing patterns significant change since
1970 - CII drugs in past operating room and inpatient
settings - Advances in science, medicine, and
pharmacotherapy have transformed much disease and
trauma into chronic illness - Care moved to outpatient setting
6Schedule II Opioid Analgesics
- Oxycodone, morphine, fentanyl, hydromorphone
classified as CII under the CSA - Schedule II designation applies to all strengths
and dosage forms of the drug - No differentiation between 5 mg oxycodone and 160
mg OxyContin, fentanyl injectable 20 µg, 2 mg
patch, morphine 5 mg tablet - CII encompasses broad range of drug classes,
potencies, and dosages. Comparable to range
CIII-CV
7Range of Schedule II Drugs
OPIATES
BARBITURATES
STIMULANTS
Fentanyl 100-250 µg/2mL 2.5-10 mg/patches
Cocaine Topical Solution 4, 10
Morphine 10mg/mL inj. 15-30 mg tabs
Methamphetamine Amphetamine 5-30 mg caps tabs
Secobarbital Amobarbital Pentobarbital
MS Contin 15-200 mg tabs
Hydrocodone Substance
OxyContin 10-160 mg tabs
Hydromorphone 2-8 mg tabs
Oxycodone comb. 5-10 mg tabs
Oxymorphone 1-1.5mg/mL inj.
Methylphenidate 5-54 mg caps tabs
Methadone 5-40 mg tabs
8Range of Schedule III-V Drugs
Schedule IV
Schedule V
Schedule III
Codeine Hydrocodone (comb.) Dihydrocodeine Bupre
norphine
Codeine (comb.) Dihydrocodeine Diphenoxylate
Dextropropoxyphene Pentazocine Butorphanol
Zaleplon Zolpidem
Gamma hydroxybutyrate (GHB)
Sibutramine Modafinil
OPIATES
Dronabinol
DEPRESSANTS
Alprazolam Diazepam Midazolam Quazepam
STIMULANTS
Anabolic Steroids
BENZODIAZEPINES
OTHER
9What does Schedule II require?
- Manufacturing quotas set by DEA (input on medical
need from FDA) - Distribution tracking
- Import and export controls
- Registration of prescribers and dispensers
- No refills
10Schedule II does not require
- Physician/practitioner education
- Limits on drug quantity prescribed or dispensed
- Prescription monitoring
11Regulation of Controlled Substances
State Regulatory Authorities
Approval Labeling
Patients Community
12DEA Role
- CSA requires DEA to
- - Register drug manufacturers
- - Establish quotas
- - Register dispensers and prescribers
- CSA does not provide for
- - Prescriber education
- - Knowledge assessment
- - Active surveillance
13FDA Role
- Regulates drug manufacturers
- Reviews and approves drug products - -safe and
effective - Drug label primary method for communicating
information to prescribers and dispensers - Post-marketing Safety/Pharmacovigilance
- FDC Act does not distinguish between controlled
and other drug products
14State Role
- Boards of Pharmacy and Medicine primary
regulators of physicians and pharmacy practice - States may impose additional drug controls
- Authority, regulations, practices, and resources
vary across states
15Prescription Drug Monitoring Programs (PDMPs)
- State purview
- Goal to reduce illicit use of prescription drugs
- Deter and identify doctor shopping, illicit
sales of prescriptions and drugs, forged
prescriptions - Collect, review, analyze prescription data from
pharmacies - Variable structure, resources
- Database query some electronic
- Active surveillance
- 15 States active PDMPs 2002
16Regulation of Controlled Substances
State Regulatory Authorities
Approval Labeling
Patients Community
17Risk Management and Drug Scheduling
- High-dose, extended-release Schedule II opioid
analgesic products not distinguished from other
Schedule II drugs in CSA - Scheduling under the CSA does not manage all
risks of misuse, abuse, and overdose of
prescription drugs - Drug scheduling alone cannot address challenges
posed by high-dose opioid analgesics in context
of the modern health care system with the current
patterns of medical practice and ease of access
to information and drugs