
The Food and Drug Administration is an agency of the US department of Health and Human Services. The approval of pharmaceutical drugs is one of the agency’s many duties. A drug that has met the Agency’s criteria via testing and review, is stamped “FDA-Approved.” Those drugs which have not met criteria, sadly, are “UNapproved.” The process of approval is intended to determine drugs as safe for an intended use, and also to thoroughly evaluate any adverse reactions and risks.
Now, we all know the story of drugs removed from the market due to severe side effects, health complications, and even death. The recalled products are many, and this should be a clear indication that the FDA-Approval system is certainly no more fool-proof than a presidential election. Caveat emptor never rang more true than today.
It is simply not possible for the FDA to evaluate all drugs and medications on the market. Mostly, this limitation is financial. The process of obtaining new drug FDA approval entails a horrifically enormous price tag. Trust me, Nieman Marcus aint got nothing on the FDA. If you ever wondered why an approved drug is so expensive at the pharmacy counter, this is where you start looking (in contrast to assuming the pharma companies are stealing from you). Remember, for both drugs that ultimately are approved AND those that fail the approval process, the financial burden on the pharmaceutical company must be recovered somehow… unfortunately, we are the somehow. Also note, when this process is no longer financially feasible for the pharma companies, who will bring innovative new drugs through research and development and to the market? The government? NO! That’s when the medical marvel gears of innovation stop… but that’s a whole other blog… back on topic…
Drugs that are both FDA-approved and unapproved are also strictly limited in how they can advertise a drug- for benefits, risks, etc. A drug approved for the use in a specific type of infection, can only be labeled and advertised to treat that specific type of infection. A drug that may clinically work for several conditions can only be labeled to treat those conditions which have gone through the FDA process and been approved. A product or drug that has been approved to treat a specific condition but is used to treat a condition NOT part of the approval, is then being used in an “off-label” fashion.
When estradiol (a common form of bioidentical estrogen replacement), an approved drug, is “compounded” by a pharmacist (under direction by a physician) into a cream containing a specific dosage – it now becomes “off-label.” It’s now off-label because the dosage is different, the form (vehicle) is different, and possibly the indication (what the drug is being used to treat) is different. The FDA recognizes that compounding pharmaceuticals can be a more effective mode of treatment for some patients, and it does not seek to halt pharmaceutical compounding. At the same time, you must realize that the risks and safety of this altered form of use has not be evaluated by the FDA.
To emphasize the functional limitations of FDA-approval in real-life medical practice, consider the following example: Antibiotic eye drops are FDA-approved and indicated ONLY for bacterial conjunctivitis (bacterial surface eye infections). The most common prescribed use of the product is pre-operative and post-operative eye surgery (cataract surgery, LASIK, etc). Every one of these peri-operative prescriptions is then off-label. What I’m saying is that these drugs are used more off-label than on-label. Furthermore, you would be a fool not to insist on using these eyedrops before and after any eye surgery, despite its off-label use. Can you say, “system FAIL?”
So we’re back where we started- caveat emptor…well, not exactly. Now that you understand the definitions, your experienced bioidentical hormone expert can help you decide on the treatment that is best for you. It goes without saying that the FDA could never replace a knowledgeable physician with your best interests at heart. We have experience with many compounding pharmacies, but have maintained relationships with only those that have proven consistent quality control as evident by happy patients. How happy are you now?




