March 22, 2006

Lawrence Diller's Statement to the FDA on March 22nd 2006

I am a behavioral-developmental pediatrician who has prescribed Ritalin and the other stimulants for nearly thirty years.  I have never been against medication.  Yet I applaud the courage of the previous advisory committee in broadening the discussion of the use of stimulants in our country beyond the cardiovascular consequences. 

The majority's recommendation for a black box warning was also meant to express their concern about the one in ten eleven year old boys taking these drugs in this country.  Can that many children have a serious psychiatric disorder requiring medication?  Indeed, in our country, Ritalin and Adderall have become life style drugs, performance enhancers, rather than solely a medical treatment.  To that end, even though the risks of sudden death are minimal to existential these drugs have to be extremely safe if we are giving them to children who are generally very normal and healthy.

And indeed the historical record of seventy years suggests that they are.  Nevertheless, their overuse highlights an ethical not medical dilemma because stimulants are not the moral equivalent to helping parents and schools address the needs of these children.

But I must alert you to the real present danger of prescription stimulants.  For years I and a few others have been deeply worried about the risks of prescription stimulant abuse especially in teens and young adults.  Now in the February issue of Drug and Alcohol Dependence we have the first hard data on the misuse and abuse of prescription stimulants.  Based on a 2002 government survey this data has been vetted by the Drug Enforcement Administration.  Twenty one million people over 12 have illegally used prescription stimulants at least once.  Three million have misused prescription stimulants alone.  Of those, approximately one in ten, or 75,000 between the ages of 12 and 25,  have gone on to meet DSM IV criteria for addiction or drug abuse.

The use of prescription stimulants are growing the fastest in the adult population so these numbers are probably larger in 2006.  Seventy five thousand prescription drug addicts dwarf the current cardiovascular casualties.  These numbers represent the fourth episode in our history of a doctor prescribed stimulant abuse epidemic.  And if our previous experiences are any guide then several years from now we are likely to look back at this time with regret, chagrin and anger.  Those who do not study history are condemned to repeat it and you may remember the grafitti on the walls of San Francisco's Haight-Ashbury in the late 1960's -- “Speed Kills.”  We must immediately address this new Ritalin abuse epidemic in our teens and young adults with much tighter controls on prescription and diversion to this population.  At the same time we need a rational policy for the use of these drugs with a much smaller group of preteens who can and do benefit from Ritalin safely.

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