Hello All,
Below is a copy of the MHRA response (UK drug safety body) to my statin adverse reaction report and my response to that reply. The commentary from the MHRA is worth reading very carefully. I have no wish to overwhelm people with a huge amount of technical literature. I do wish people to be accurately informed. For people who find it difficult to read a lot of technical argument, it can be summarised as follows:
My report is spontaneous and incapable of providing incidence data so it would appear to be discounted as worthless (in the strictly scientific sense) but it also appears to prevent the MHRA from listening to any patient derived information. I have responded with my view of this conduct and I have added a new paper reference that shows that statins reduce the function of the heart muscle. I guess that we now wont see a reply until after the new year holiday but I will keep people informed.
I wish you all a happy Christmas and a peaceful new year.
Dear Mr Cable,
Thank you for your three emails and informal report on the subject of statins and a possible association with neurodegenerative disorders. I will answer all of these emails (one of which was addressed to Claire Tilstone) in this single response.
The Medicines and Healthcare products Regulatory Agency (MHRA) together with independent expert advice from the Commission on Human Medicines (CHM) is responsible for ensuring that the overall balance of benefits and risks of medicines is positive at the time of licensing and remains so thereafter. The safety of all medicines including statins is actively monitored by the MHRA on an ongoing basis.
Cardiovascular disease is a significant problem in the UK and the British Heart Foundation (2008) has estimated that it is the cause of more than one in three deaths - nearly 198,000 a year. Statins have been shown to reduce the risk of cardiovascular events and save lives for certain patient groups. This has been demonstrated in a number of large trials of long duration, carried out in a diverse set of patients.
However, no medicine that is effective can also be completely free from side-effects. The decision to prescribe a statin is a joint one that should involve both the patient and his/her GP, and include a consideration of both the benefits and risks of the medicine as well as the personal medical history of the patient. Prescribing practice policy on a national basis is determined by the National Institute for Health and Clinical Excellence (NICE) who produce guidelines for prescribers.
The MHRA uses many methods to monitor the safety of all medicines, including spontaneous adverse drug reaction reports (via the Yellow Card Scheme, to which anyone – doctors, coroners, nurses, pharmacists, patients, can report), as well as randomised clinical trials, observational studies and sources from the literature.
A possible association between statins and amyotrophic lateral sclerosis (ALS) has been considered relatively recently by the MHRA. This potential signal was highlighted by a report by Edwards et al (Drug Safety 2007; 30 (6): 515-525) which used Vigibase (the spontaneous reporting database of the WHO programme for International Drug Monitoring) and found a disproportionately high reporting rate for ALS/ALS-like syndrome in association with statins.
Because of the recognised limitations of spontaneous reporting, the Food and Drug Administration (FDA) has since published an analysis of 41 placebo controlled clinical trials ranging from 6 months to 5 years in duration. This analysis found no suggestion of a link between statin treatment and ALS. It is published in Pharmacoepidemiology and Drug Safety (2008; 17(11): 1068-1076) by Colman et al.
The MHRA have more recently carried out a study of statins and ALS using the General Practice Research Database (GPRD). This study also found no evidence for a link between ALS and statins; instead it found that whilst the number of prescriptions for statins has increased dramatically between 1995 and 2007, the prevalence and incidence of ALS appears to have declined. These results were discussed by the Pharmacovigilance Expert Advisory Group, an independent expert group of the CHM, who concluded that the data did not support an association.
Your report clearly highlights many of the limitations of spontaneous data. In particular the following points need consideration: a temporal relationship for a suspected reaction does not prove causality; the patient group in question (statin users) is likely to have a higher background incidence of these types of disorders; the sample obtained will be influenced by many factors for example media attention that affect the rate of reporting, and the sample will be biased in the case of e.g. a petition such as that described in your report: not only will the people who fill in such a survey be unrepresentative of the population as a whole but also the petition is actively recruiting patients who have suffered an adverse event. For these reasons and several more, notably the lack of an accurate denominator, it is not possible to generate any form of incidence rate from these data. This is why studies such as that conducted in the GPRD, as described above, are so important.
We recognise that the clinical application of statins is a developing field and prescribing guidelines are changing to reflect the latest evidence. This means that a significant amount of new information is becoming available as more people start taking statins. However, please be assured that the MHRA, together with CHM, will continue to review any important new evidence and will, if necessary, take further regulatory action to minimise any risk to patients.
I hope that this information is helpful.
Vigilance and Risk Management of Medicines (VRMM)
My own response to this MHRA letter follows:
Thank you for your response to my e-mail messages concerning the self-reported adverse effects of HMG-CoA reductase inhibitors.
I am pleased to learn that MHRA and CHM will continue to review any important new evidence that may precipitate the need for regulatory action. I accept your point about spontaneous reporting but I did deal with that specific issue when describing the limitations of self-reported phenomena in my report. If the patients do not describe what they are experiencing how is anyone else to know precisely what the patients are feeling and experiencing? I agree that the background incidence of neurological conditions is likely to be higher in people who take statins (the question why is precisely the issue with which I am concerned) which was one of my prime reasons for writing an informal report detailing these self-reported adverse events.
The undeniable result of HMG-CoA reductase inhibition of cholesterol synthesis within the mevalonate metabolic pathway is that several other vital processes, which are unrelated to the production of cholesterol, are also affected. I have not found any satisfactory explanation or rationale in the literature that specifically requires the adjunctive inhibition of Coenzyme Q10, prenylated proteins, dolichols and heme A. Total cholesterol level is not altered by dietary intake but the notion still enjoys wide acceptance, to the point where we have minor celebrities appearing on television regaling us with tales of 'success' in lowering our numbers while imploring us all to cut our cholesterol by eating less of it. Why must the nation endure such nonsense? Low cholesterol levels are a robust predictor of early mortality and the literature supports that proposition.
Yes, cardiovascular disease in the UK is a significant problem, I have not found (from my reading of any of the major studies) that statins are saving lives in any significant numbers. The pharmaceutical study sponsors control the findings data and polish it to show their therapeutic agents in a good light. Drug companies discuss relative risk rather than absolute risk and the study exclusion criteria usually excludes subjects who are likely to smudge the perfection which is claimed for the statin therapies.
The fundamental fallacy of Ancel Keys's Seven Countries Study (excluding all of the countries which did not support the hypothesis) when combined with the less than stellar results from Framingham, could have been expected to halt the madness that is our annually falling cholesterol level targets. The UK permits the selling of statins as OTC medicines and it is clear that pharmacists may not be the best people from whom to seek accurate advice especially if they were to reflect the failure of substantial numbers of clinicians to acknowledge or understand statin-mediated adverse reactions. Why is there a reliance on chemical interventions to reduce cholesterol? Cholesterol is vital to life and it is essential to healthy neurological function. Cholesterol has not yet been shown to be the primary cause of cardiovascular disease.
There does not appear to be any science which supports the notion that female mortality rates benefit from statin therapy within either the primary or secondary treatment arenas. There are a few cases where men are shown to derive some small benefit within a very narrow age range. When I was considering the NICE guidelines following on from the technical appraisals, I was surprised to see that the manufacturers of statins were included in the discussions about national prescribing policy, which appears to be a long way short of an arm's-length arrangement. The chair of the Cholesterol UK Charity was calling for statins to be put in the water supply!
Any blanket treatment that is prescribed for all of the population (probably against their will and without their knowledge as would be case if statins were tipped into the water supply) is the very antithesis of medical practice and tantamount to healthcare by fiat. I must have missed the meeting where it was agreed that medicating people for life was going to be the substitute for a gentle, healthy lifestyle with the appropriate and minimal medical intervention, based upon informed consent, when required.
Yes, my informal report of the spontaneous reporting of adverse reactions was completely unregulated, nevertheless, it does not alter the take-home message. People who take statin therapy are quite likely to fail to comply with their prescribed treatment because of the severity of the adverse reactions they experience. The adverse reactions are likely to be severe because of the mode of action of statins, despite the persistent failure of the pharmaceutical industry to recognise the frequency and the severity of the effects that the reporting patients have attributed to statin therapies. My suggestion for further research would be easy to initiate rapidly and it would give a true picture of the extent of statin-damaged patients. One could also hope that statins would reduce mortality from cardiovascular disease but that is a forlorn hope given that statins will damage every patient, if they survive long enough to take them as was intended.
At no point did I tell the informants what they must write nor were they coached in how to describe the effects they were experiencing. They were free to write whatever they wished and that is what is absolutely compelling abut their accounts. The failure of a substantial number of clinicians to attribute adverse reactions to statin therapies suggests that there is widespread disbelief among clinicians that statins can cause any harm. When a satisfactory explanation is forthcoming as to the fate of the organism, after the inhibition of several vital processes which are unrelated to cholesterol production, then and only then will the picture be anything like complete.
I have absolutely nothing to gain from informing the MHRA pharmacovigilance section about my concerns. I don't sell anything and I no longer work for the NHS. Neither am I looking for fame or fortune. Despite these facts, I am finding it very difficult to understand why it is so hard to engage with the bodies and institutions that are charged with overseeing the health and safety of the public. When Merck patented Lovastatin, they also patented the addition of Coenzyme Q10 in an effort to ameliorate or prevent statin induced myopathy. Why, almost 20 years after that event, is there no adjunctive prescribing of coenzyme Q10?
I am not clinician and I have no research pedigree, neither am I an academic. I do feel that your dismissal of my report, ostensibly because it was spontaneous reporting, is a little hasty. If the editor of the Journal of Independent Medical Research, Professor Trevor Williams, could find some value in my informal report then I am reasonably sure that some value exists. My fear is this: If the MHRA reacts in manner that fails to recognise the potential harm that statins will inevitably cause, then a tableau vivant that is redolent of the thalidomide disaster will ensue and many more people will be damaged needlessly. I am merely the messenger and it is only the message which is crucial, not the person who had delivered the information.
This abstract was copied directly from PubMed and it represents a prime example of the literature not supporting the widespread and indiscriminate use of statin therapies. Any thoughtful person will want to know why statins, which are prescribed to reduce the risk to the cardiovascular system, actually decrease myocardial function. This sort of anomaly abounds in the literature and I can supply you with hundreds of examples that provoke similar questions. When lay people can find so much scientific evidence that cautions against the use of statins, without the open access to the literature that you enjoy, it is right to ask the questions that are begged by such evidence.
Clin Cardiol. 2009 Dec 21;32(12):684-689. [Epub ahead of print]
Statin Therapy Decreases Myocardial Function as Evaluated Via Strain Imaging.
Rubinstein J, Aloka F, Abela GS.
Cardiology Division, Department of Medicine, Michigan State University, East Lansing, Michigan.
OBJECTIVES: The purpose of this study was to evaluate the effects of statin therapy on myocardial function as measured with echocardiography with tissue Doppler imaging (TDI) and strain imaging (SI) independent of its lipid-lowering effect.
BACKGROUND: Statin use is known to improve outcomes in the primary and secondary prevention of ischemic heart disease, but their use is also associated with myopathy, muscle weakness and in rare cases, rhabdomyolysis. We sought to evaluate whether TDI and SI is able to identify changes in myocardial function associated with statin use.
METHODS: Myocardial function was evaluated in 28 patients via echocardiography with TDI and SI. We identified 12 patients (5 females) without overt cardiovascular disease (including hypertension, smoking, and diabetes) that were on statin therapy and compared their echocardiographic findings with 16 (12 females) age, sex, and cholesterol-profile-matched controls. Tissue Doppler imaging parameters of diastolic (E(')/A(') and E/E(')) and systolic (S') function were measured. Regional systolic function was obtained by SI in 4-chamber, 2-chamber, long axis, and average global views.
RESULTS: There was no significant difference in myocardial function as measured by Doppler and minor differences as measured via TDI among the 2 groups. There was significantly better function noted with SI in the control group vs the statin group in the 4-chamber (-19.05% +/- 2.45% vs -16.47% +/- 2.37% P = 0.009), 2-chamber (-20.30% +/- 2.66% vs -17.45% +/- 4.29% P = 0.03), long axis (-17.63% +/- 3.79% vs -13.83% +/- 3.74% P = 0.01), and average global (-19.0% +/- 2.07% vs -15.91% +/- 2.81% P = 0.004) views.
CONCLUSION: Statin therapy is associated with decreased myocardial function as evaluated with SI. Copyright (c) 2009 Wiley Periodicals, Inc.
PMID: 20027659 [PubMed - as supplied by publisher]
Kind regards,
Jeff Cable
Cable J: Adverse Events of Statins - An Informal Internet-based Study. JOIMR 2009;7(1):1
http://www.joimr.org/JOIMR_Vol7_No1_Dec2009.pdf