AAPS joins coalition to urge against “unneccessary rulemaking” for cough medicines

AAPS signed on with 20 other groups to urge against “unneccessary rulemaking” for Dextromethorphan cough medicines.  Download PDF file of the letter.

The coalition letter reads:

Drug Safety and Risk Management Advisory Committee
Re: Advisory Hearing Regarding Dextromethorphan on September 14, 2010

Dear Committee Member,

We write on behalf of millions of taxpayers and concerned citizens represented by our organizations regarding a forthcoming hearing on cough medicines containing Dextromethorphan. The hearing could lead to an unnecessary rulemaking process that would require prescriptions for medications containing this ingredient. This would increase costs and limit accessibility for consumers and expand the regulatory regime to address a relatively narrow concern.

Dextromethorphan is considered a low priority to the DEA as incidence of its abuse is relatively scarce. A study released in 2009 by the SubstanceAbuse and Mental Health Services Administration showed that approximately 0.7 percent of drug-related emergency room visits involved Dextromethorphan. 31 percent of these were results of adverse reactions to medicine that was used as directed. This number drops even lower when controlling for accidental overdoses. Moreover, drug manufacturers, amply pressured by market demand for prudent oversight of their products, have taken great care to appropriately label and educate consumers regarding the risks of cough medicines containing Dextromethorphan. That over 100 commonly-used cold medications contain this ingredient is a testament to its efficacy and widespread safety.

What’s more, studies show that abuse of prescription drugs is twice as common as recreational use of cough suppressants. Thus, an effort to force medications containing Dextromethorphan behind the counter is both unnecessary and ill-conceived, as little evidence exists that this would address regulators’ anxieties regarding abuse.

A push to require prescriptions for medications that have been readily available for half a century will raise health care costs for consumers at a time they can least afford it; Americans are already facing higher taxes and increased health care expenses under the implementation of the new
health care law.

Altering the classification status of cold medicines could also lead to significant consumer confusion. Consumers associate various products with the characteristics they display or the ingredients they contain. If accessibility to these medicines is suddenly restricted, this would frustrate consumer expectations and present significant limits on consumers’ ability to purchase products with the attributes they seek.

Allowing the government to restrict the personal health decisions of consumers establishes a dangerous precedence; individuals are wellinstructed on the proper use of cold medications. There is little justification for this broad government overreach and arbitrary restriction of personal choice. For these reasons, we urge you to reject any proposal that would require a prescription for medications containing Dextromethorphan, and look forward to working with you to maintain open and honest regulatory policy.

Sincerely,
60 Plus Association, Jim Martin, Chairman
American Conservative Union, David A. Keene, Chairman
Americans for Tax Reform, Grover Norquist, President
Associate of American Physicians and Surgeons, Dr. Jane Orient, Executive Director
American Shareholders Association, Ryan Ellis, Executive Director
Campaign for Liberty, John Tate, President
Center for Fiscal Accountability, Mattie Corrao, Executive Director
Center-Right Coalition of Florida, Rick Watson, Chairman
Citizens for Health, Jim Turner, Chairman
Citizen Outreach, Chuck Muth, President
Council for Citizens Against Government Waste, Tom Schatz, President
Competitive Enterprise Institute, Fred L. Smith, Jr., President
Doctor Patient Medical Association, Kathryn Serkes and Mark Schiller, M.D., Founders and Co-Chairs
DownsizeDC.org, Inc., Jim Babka, President
Frontiers of Freedom, George Landrith, President
Institute for Liberty, Andrew Langer, President
Less Government, Seton Motley, President
Liberty Guard, Bob Guard and Joe Seehusen, Chairman and President & CEO
Property Rights Alliance, Kelsey Zahourek, Executive Director
Wyoming Liberty Group, Susan Gore, Founder
Young Americans for Freedom, Jordan Marks, Executive Director