X-Message-Number: 1486 Date: 22 Dec 92 05:36:11 EST From: "Steven B. Harris" <> Subject: The FDA & Saul Kent Dear Cryofolks: In the recent debate we've heard some egregious remarks about Saul Kent and the FDA, and I thought it time to address both of these subjects from a different perspective, just to balance things out. FDA I'll start with the FDA. The Food and Drug Administration was originally (early in this century) charged with establishing the purity and safety of foods and drugs. As such, it was tolerable, and even did a certain amount of good in acting as policeman against certain types of actions which we all agree constitute "fraud" (putting horsemeat in the hamburger, putting sugar instead of antibiotic in the antibiotic pills, etc.) Then, something horrible happened. A tranquilizer drug called Thalidomide caused a number of deformed babies in Europe. The woman commissioner of the FDA at that time, Francis O. Kelsey, M.D., had a pharmacist husband who did not like the way the routine pharmacology tests had been done on Thalidomide (some- thing having nothing to do with reproduction), and by the sheerest chance the resulting red-tape holdup by the FDA caused introduction of Thalidomide to be delayed in the U.S., until it become apparent in 1960 that it was a dangerous drug. Following this, JFK gave Dr. Kelsey a medal for basically being a bureau- crat and allowing Europeans to be guinea pigs for Americans, and everyone congratulated themselves, without thinking too much about what the consequences of such an across-the-board delay policy might be, when applied to all new drugs. In 1962 a new congressional law gave FDA power over not only safety, but also efficacy of new drugs, and the regulatory monster that we know today was born. And a monster it is. Today, mostly because of FDA-caused foot-dragging, the cost of developing a new drug has risen to an average of about a quarter of a BILLION dollars in the U.S., a price which the consumer pays when he/she picks up any prescrip- tion for a newer drug (if you want to directly assess the regula- tory cost of the FDA, try buying pharmaceuticals in Mexico sometime, and note that they can be, for the identical product made by the identical company, sometimes 1/10th the price). The regulatory cost in lives is more difficult to assess, but is probably significant. The high cost of drugs caused by heavy regulation has led not a few poorer people to stop taking what the doctor ordered, sometimes with expensive or even tragic results. Even worse, new drugs now are quite often available in Europe for years before being available in the U.S., and in the interim patients die for lack of treatment. For instance, one estimate puts the number of people who died of heart conditions as the direct result of the historical FDA's multi-year lag-time in evaluating beta-blocker drugs in the hundreds of thousands-- a number which makes up for Thalidomide many times over. It is important to understand that this situation arises via one of the significant shortcomings of democracy. Politically, the FDA comes under severe pressure for passing a drug which is later shown to be unsafe, but much less pressure for the equally dangerous failure to pass a drug which is later found to be efficacious. This is because patients who die as the result of a drug-reaction are seen to die because of the drug, but patients who die as the result of lack of a drug (especially one which the local docs are not familiar with) are seen to die of the *dis- ease*. And even if the local doctor understands the FDA's role in preventing the patient from being properly treated, "Stenosis of the Government" is not a medical diagnosis, and cannot be written on a Death Certificate. It is also important to understand that this situation arises because of a certain laziness of the citizenry in understanding that the decision of whether to take a specific drug for a specific purpose, is only partly a scientific one. The reason for this is that, even if (rare case) the probabilistic risks and the benefits of "taking the drug vs. not taking it" have been defined by science, the *balancing* of these risks and benefits is still an ethical and moral decision, and one which varies wildly from person to person, due to circumstance and personal preference. To put it succinctly, the decision to try a new and possibly dangerous treatment may well and properly be influenced by how much pain the prospective treatment-taker is in, and how soon he or she can expect to die if nothing is done. Unfortunately, however, these factors do not enter into decisions made in Washington, D.C., basically because Washington, D.C. is not in pain, and Washington D.C. is not dying. If you are the patient, then, you may expect that having a decision about your treatment made for you in Washington will not be satisfactory, because they do not know you or your problems in Washington. Nearly any dis- placement of medical problem decision-making from patient and physician toward a place thousands of miles away, is bound to result in needless suffering. Thus, the FDA as it functions today is basically engaged in an evil enterprise. The people who run the FDA may not be evil people (though surely some are) but unfortunately, this does not change the facts about the FDA's general impact upon the world. The FDA, remember, is in the game for the political power, not for the benefit of the citizenry. Thus (for instance) the FDA will not permit any information about the *dangers* or possible side effects of particular herbal preparations to be printed on the bottle label, even though such warnings might do much good, because the FDA does not want to set the precedent of providing usage information of any kind on bottle labels. Damned be the consumer. In another case, the FDA has consistently, for more than ten years, prohibited vitamin companies from making claims about the ability of the vitamin folic acid to prevent certain birth defects, while evidence mounted all the while. This year the American Society of Pediatrics formally recommended that all women of childbearing age take a supplement of folic acid, yet still the FDA will not permit vitamin manufacturers to inform the public about folate. Since there is no place the FDA can hide on this issue, however, it now seems likely that, rather than admit that the claims for a single vitamin supplement pill were correct, the FDA will soon *mandate* adding folate to flour as part of the enrichment process. We thus seem likely to go very soon from a situation where manufacturers are prohibited from telling of the benefits of supplementation with a vitamin, directly to one in which manufacturers are obligated to add that same vitamin to your food without your request. Going from prohibited to required without going through the intermediate state of individual choice is a nice illustration of the way our government thinks, to be sure, but in the meanwhile, while all this is sorted out, more children will surely be born deformed because their parents lacked information on supplementation. Once again, however, the mission of the FDA is power, not the prevention of birth defects. Anyone who still thinks otherwise did not learn the right lesson from Thalidomide. Saul Kent Which brings us to Saul Kent. Saul Kent is presently locked in legal battle with the FDA over charges that he made "illegal claims" for certain vitamins (actually, any claims for vitamins at all are illegal) and that he imported substances which according to the FDA are "pharmaceuticals" instead of "nutrients" (like CoQ10). All of the issues which Saul and the FDA differ are those upon which knowledgeable people might reasonably differ, and none involve what you and I would consider out-and- out fraud, yet Saul is under indictment for federal vitamin crimes enough to send him to jail for the rest of his life and more (I'm not kidding). Such is the sickness of the FDA. Interestingly, there is nothing which Saul has been indicted for which is not now routinely practiced by a great number of AIDS- drug "buyer's clubs" in this country, yet the FDA (for reasons purely political) leaves the AIDs-drug industry and community pretty much alone. Such is the *slickness* of the FDA. Again, please see what I said above about power. Which brings me to the subject of empathy for Saul's plight among a number of cryonicists on this forum--- the singular absence of which is astounding. Wake up, everyone. If you're a cryonicist and you're NOT upset over the idea of the governmental suppression of what it considers quackery and false medical claims, then you'd better sit down for a minute and take stock of your basic philosophy. As a cryonicist you've got a little cognitive dissonance coming. The FDA is not your friend. In fact, since the FDA does not consider "aging" a "disease," and therefore would not consider the licensing of any drug which was found to combat aging, the FDA is your sworn enemy. It follows that anyone who *fights* the FDA deserves the gratitude of every thinking cryonicist. Anyone. Saul Kent, of course, is not just anyone, but also one of us. He has not only been a cryonicist for almost 30 years (he was Secretary for the Cryonics Society of New York before many people on this forum were born), but he is also probably the single largest benefactor of Alcor. When Alcor faced an eviction notice due to insurance problems in 1987, and could not find rental anywhere else due to the same problems (this meant the end of the organization and potentially the loss of the patients), it was Saul who largely organized and engineered the Symbex bailout that got us our own building. That Saul's recent fight with the FDA has diverted his money from cryonics support to lawyer support is a tragedy and a personal loss to every cryonicist, and one they should blame on the FDA, not Saul. No, Saul is not going to be funding cryonics from a jail cell, should be find himself in one. Anyone who thinks so should think again. There has been a certain amount of griping on this forum about the political pull of Saul at Alcor, but I only see this in terms of the fact that cryonics is not a democracy, nor is meant to be. Does Saul have too much power? I don't know. I do know, however, that if political power were given out solely in terms of how much lifetime and money and commitment an organization's members had spent in its service and the service of its ideals, then Saul would surely have relatively MORE power then he presently has in Alcor, not less. On the whole, I don't think it's something to worry about too much. The power of the government, on the other hand.....now that's something to worry about. Steve Harris Rate This Message: http://www.cryonet.org/cgi-bin/rate.cgi?msg=1486