Dana Casciotti, Cancer Prevention and Treatment Fund, October 24, 2011
I am the public health research director of the Cancer Prevention and Treatment Fund, a nonprofit center that uses research findings to improve prevention and treatment strategies. Our nonprofit does not accept money from pharmaceutical or device companies so I have no conflicts of interest.
My perspective today is as someone trained in public health at Johns Hopkins and previously worked at the National Cancer Institute. I am very familiar with clinical trials and research methodology.
You have already discussed how poor the follow-up was on the implant studies. I was disappointed that an FDA official implied yesterday that most of the post-market studies were fine, and only a few were not.
I completely disagree. It was not just the Mentor large study that was so outrageous after only 3 years, and Allergan barely kept half their augmentation patients after only two years.
The Adjunct studies were even worse – only 16-23% of the women were still in the studies after 5 years. The Core Studies were slightly better, but Mentor had only 58% of their patients at 8 years, and that is not acceptable in any of the places where I have conducted research.
Our nonprofit has talked to many women who have had serious problems with their breast implants, and I am talking about recent patients, not patients from 20 years ago. But, many of these patients have already missed work because of their illness and couldn’t take the time to be here this week. Some told us that their kids are going back to school this week, and they need to be there. Others didn’t even hear about this meeting in advance – it wasn’t exactly highly publicized to the general public.
But history should be our guide. We know that most new breast implants seemed great at first. It isn’t until years later that it becomes obvious that the “newer safer breast implants” also break and leak and cause problems. So, it may take a few years to get a better idea about the safety of the “new cohesive gel implants” but we already know after yesterday’s testimony and from talking to many other patients that these new implants can bleed silicone into the scar capsule even when the implant is intact. And even the new implants can break.
I also want to correct some misconceptions that were reflected in yesterday’s panel discussion. The large studies done by Allergan and Mentor are not asking women to come to the plastic surgeon’s office every year. Most years, they are asking women to fill out a questionnaire, which they can do online at home. I have seen copies of these questionnaires and they are much too long. By the time women get to the questions about their symptoms on page 22 of the Allergan questionnaire, for example, they will have already answered questions about 20 connective tissue diseases, many of which they never heard of and can’t pronounce, such as eosinophilic fasciitis. They will also have answered the same 20 questions about each of their children. I have to assume that by the time they get to page 22 to answer questions about symptoms they might actually have, they are in no mood to answer the question about “dilated red blood vessels under the skin surface that appear as red marks, especially on the face, hands, and lips.” Given these questions, I think it is very unfair to blame the low response rate on the patients.
Similarly, Mentor patients have told us that the symptoms listed on their questionnaire were often confusing and difficult to answer.
I have one more thing to add. The first 2 years of the Allergan and Mentor Core studies showed that self-esteem on the Rosenberg Self-esteem scale went down in most patients with implants, and that symptoms of connective tissue diseases went up. Those data were reported at previous FDA Advisory Committee meetings. But, those data are missing from the analyses that the FDA has reported for the 8-year and 10-year Core study follow-ups. I ask the FDA to explain why.
Conclusion of Post-Approval Studies: Many of these rates are too low to provide useful data for augmentation patients.
Rupture Rate: The FDA mistakenly reported the rupture rate per implant as if it were per patient. Previous data shows that the price per implant is approximately twice as high as per implant.
Mentor: Rupture Rate in MRI Cohort
Primary Augmentation
Primary Reconstruction
Revision
3 year
8 year
3 year
8 year
3 year
8 year
By Patient
.5%
.8%
4.8%
By Implant
.2%
13.6%
.5%
14%
3.9%
15.5% augment. 21.3% reconstr.
AllerganRupture Rate in MRI Cohort
Primary Augmentation
Primary Reconstruction
Revision
4 year
10 year
4 year
10 year
4 year
10 year
By Patient
3.4%(N=166)
20.5%(N=107)
10.9%
By Implant
1.7%(N=331)
10.1%
13.1%(N=182)
27.2%
5.7%(N=150)
6.3% aug6.7% rec
Why the Poor Follow-up?
Once company did a much better job than other. There is no excuse for Mentor’s poor performance because their patients and studies are like Allergan’s.
Plastic surgeons tell women that complaints are so safe that the women aren’t concerned about follow-up. Does the contribute to patient’s lack of interest in participating in these studies? Or are incentives poor? In addition, women are being “fired” by their plastic surgeons.
Cumulative Complications
Cumulative complication rates are decreasing in data the FDA has presented now compared to a few years ago! That’s impossible. They should stay the same or increase from 4 years to 10 years. (Allergan: swelling decreased from 23% to 9%)
Since come complication rates are going down there is a problem with the data. Either the company is not reporting complications correctly or the sample is changing in ways that reduce complications.
Allergan:Cumulative Complications
Health Complications
Primary Augmentation
3 yearsN=494
10 yearsN=455
Reoperation
21%
36%
Removal/replacement
8%
21%
Capsular Contracture III or IV
8%
19%
Breast pain
6%
11%
Loss of Nipple Sensation
3%
6%
Seroma
3%
2%
Hematoma
1%
2%
Skin sensation changes
2%
2%
Skin Rash
3%
1%
Redness
3%
1%
Infection
1%
1%
Bruising
9%
.4%
Allergan: Cumulative Complications
Cosmetic Complications
Primary Augmentation
3 yearsN=494
10 yearsN=455
Swelling
23%
9%
Implant malposition
3%
6%
Scarring
8%
4%
Asymmetry
3%
3%
Ptosis (sagging)
3%
2%
Implant palpability
2%
Wrinkling
2%
MentorComplications: Augmentation
By Patients, Cumulative KM Risk Rates of Complication with ≥ 1% Rate through 2 and 3 years
Health Complications
Augmentation N=551
2-Year Rate
3-Year Rate
8-Year Rate
Reoperation
12%
15%
20%
Nipple sensation changes
9%
11%
12%
Capsular contracture III or IV
8%
8%
11%
Implant removal w/ or w/o replacement
4%
5%
7%
Breast Mass
2%
2%
5%
Hematoma
3%
3%
3%
Breast sensation changes
2%
2%
3%
Breast Pain
2%
2%
3%
Infection
2%
2%
2%
MentorComplications: Augmentation
Cumulative KM Risk Rates of Complications through 2 and 3 yrs
Cosmetic Complications
Augmentation N=551
2-Year Rate
3-Year Rate
8-Year Rate
Hypertrophic scarring
6%
6%
Ptosis
2%
2%
AllerganCumulative Complications
Health complications
Primary reconstruction
3 yearsN=221
10 yearsN=98
Reoperation
46%
72%
Removal/replacement
25%
54%
CC III/IV
16%
25%
Breast Pain
6%
7%
Infection
2%
3%
Seroma
5%
2%
Redness
6%
2%
Skin Rash
3%
2%
Hematoma
2%
Bruising
4%
1%
Delayed wound healing
2%
1%
AllerganCumulative Complications
Cosmetic Complications
Primary Reconstruction
3-yrsN=221
10-yearsN=98
Asymmetry
15%
23%
Wrinkling
4%
10%
Swelling
16%
7%
Implant palpability
7%
Scarring
6%
6%
Implant malposition
5%
2%
Ptosis (sagging)
1%
0%
MentorComplications: Reconstruction
By patient, Cumulative KM Rates of Complications with ≥ 1% Rate through 2 and 3 years
Health Complication
ReconstructionN=151
2-Year Rate
3-Year Rate
8-Year
Reoperation
25%
26%
39%
Implant removal w/ or w/o replacement
12%
13%
23%
Capsular Contracture III/IV
7%
9%
15%
Infection
5%
5%
6%
Metastatic disease
2%
2%
6%
Breast Mass
3%
4%
5%
Seroma
5%
5%
5%
Breast pain
2%
2%
3%
Recurrent breast cancer
2%
2%
2%
Implant extrusion
1%
1%
1%
Hematoma extrusion
2%
2%
?
Necrosis
.4%
1%
?
Cumulative Complications
Mentor seems to have stopped reporting certain complication rates. For example, asymmetry. For example, asymmetry and ptosis, 2 complications for reconstruction patients, are simply not reported at 8 years.
What else might Mentor have decided not to report?
Given these problems, it is difficult to have faith in the integrity of the Mentor data.
MentorComplications: Reconstruction
By patient, cumulative KM Risk Rates of Complications with with ≥ 1% Rate through 2 and 3 years
Cosmetic Complication
ReconstructionN=251
2-Year Rate
2-Year Rate
8-Year Rate
Implant malposition/displacement
2%
2%
3%
Asymmetry
5%
7%
?
Ptosis
3%
7%
?
Hypertrophic scarring
6%
6%
?
Wrinkling
2%
3%
?
Conclusions:
Incentives are lacking for companies or surgeons to do post-market research correctly. Enforcement is needed to provide incentives.
Data are not capturing the problems many implant patients report-especially Mentor.
Literature is funded by silicone and implant companies, and medical foundations with conflicts of interest.
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I was diagnosed with breast cancer and had a mastectomy at the age of 25.
I waited 5 years before I decided to have reconstructive surgery. I played tennis, jogged, and taught aerobics. But the prosthesis often shifted or fell out of my bra when I perspired. So, as a well-educated woman, I did my homework on breast implants prior to choosing the plastic surgeon to perform my reconstructive surgery. However, I was told that they would “last a lifetime” and “complication were rare”.
Within 3 months of the initial reconstruction, I was back on the operating table. My body had formed a capsule around the implant and the implant had shifted up under my collarbone. The searing pain at that time was causing my shoulder to become immobile.
My symptoms began slowly. At first I attributed the fatigue, aches, and pains to just getting older. (I was only 36 years old!) This was 6 years after I had been implanted.
Pam Noonan Today
Then I got a severe case of the flu, and 6 weeks later I was still so fatigued that my life was being drastically effected. I had GI problems, sleep disorders, night sweats, chronic fatigue, myalgias, and joint pain.
Before I had the implant removed (10 years after the initial reconstruction), I was again wearing a partial prosthesis over the implant. Capsular contracture had again become a problem and I was misshapen and lopsided. The explantation was the 5th surgery at my breast site.
I never fully recovered. I have gone to various doctors and specialists and have been given a list of various possible diagnoses. Atypical Connective Tissue Disease is number one, but that diagnosis was made quite a bit later, not within the first 10 years.
To date, my out of pocket medical expenses exceed $40,000. My husband and I are self-insured. The insurance policy that we took out carried an exclusion. I was not covered for any illness or disability related to the reconstructive surgery. Apparently the insurance companies understood that there are health risks associated with breast implants and they are not willing to bear the financial costs.
There is not a miracle cure for me. But I hope that by telling you what happened to me, you will understand why better research on breast implants is so important.
Kathleen Van Fossen Nye
Kathleen Nye, Age 22, Mastectomy PatientNecrosis after 5th Replacement Surgery
My name is Kathleen Van Fossen Nye and I am from Reading PA. I am not well enough to travel to this meeting so I thank you for the opportunity to have my words read before this panel.
I first got breast implants after undergoing a bilateral mastectomy at the age of 22 at the U.S. Naval Hospital in Portsmouth, VA.
My experience with implants is like a history book on breast implants, because I started with some of the early implants and those were repeatedly replaced as newer models became available.
I beseach you to make sure that well-designed and implemented long-term studies are conducted on all breast implants that are sold. Then make these studies available to the public on the internet so women can read them for full disclosure.
When I was 22, the doctor claimed I was lucky to live when reconstruction was available with silicone breast implants. He said before the implants I would have walked around with a sunken chest. He also said they would never sag, that I would be the sexist old lady in the nursing home. In addition, they would self-seal if I was stabbed in the breast.
I wasn’t so lucky, after all. My original breast implants had to be cut off my chest wall, because the mesh backing from the implants grew into the chest wall. The implants had become as hard as rocks.
I was told that the new silicone gel implants were greatly improved and would not get hard. In addition, if for any reason they do get hard, all the doctor had to do was squeeze the breast until they break the scar tissue capsule.
Claims of being able to break the scar capsule were not true. After 5 years of squeezing the hardened breast, I could no longer take the pain. My doctor told me it was my fault because I had no breast tissue. However, he told me that the new Meme implants were covered with polyurethane foam that would stay soft and never get hard, so he was going to use these new and improved implants.
When asked about the safety of the foam, I was told to trust the doctor because he knew what was best for me.
And yet, the new implants also got hard. The old Meme implants were removed and I had surgery to get a new set of Meme implants.
For 3 years I was weak and sick and after visiting three different doctors complaining of pain and lumps on the edge of the implant, two doctors told me it was scar tissue. The third doctor said to give me peace of mind he would remove the lumps. The implants were removed and the 3 lumps were biopsied.
Foreign material was found in two of the masses. The mass that was sandwiched between the other two was cancer.
After chemo and radiations treatments I had two expanders and I was implanted once again, against my wishes.
Within 3 months, I developed necrosis and the implant pushed itself up and out through my skin.
My physical health has suffered greatly. I have had over 25 breast related surgeries, including 6 sets of implants and 4 single silicone implants, 2 expanders, and 4 individual saline for the left breast.
I now have lupus and many other health problems.
I have given my history to show you that there is always great optimism about the newly designed implants, but as the years go by, the optimism gives way to reality and those old implants are always replaced with new ones, until those new ones become the bad old implants that need to be replaced.
It is 49 years and about 3 generations of women since Drs Cronin and Gerow implanted the first breast implants. If the manufactures’ make safety claims, they should back them up with studies that really provide accurate long-term data, not biased samples where half of the patients are missing and we don’t know if the half that are missing are healthy or terribly sick.
Anne Stansell
Anne with Ruptured Implants
My name is Anne Stansell and I live in New Mexico. I wish I could be there today, but I hope you will listen to my story.
I am a breast cancer survivor. I was diagnosed at the age of 39. The doctor said I needed mastectomies, radiation therapy, and breast implants. Implants were just part of the treatment, no discussion. I trusted the doctors who I felt had just saved my life.
I was fine for the first five years. Then I became very ill. I was diagnosed with Graves Disease and fibromyalgia. My eyes were so dry that my retina tore.
My implants were taken out about two years later. I had to fight with my insurance company to get them to cover the removal.
Half of one of my implants was gone. Where did the silicone go? I don’t know. Here is a photo of me with my half empty implants.
They couldn’t remove all the silicone from my body, but even so I began to get better almost immediately. My family noticed the difference even before I did.
I’m still recovering, and I can work some now.
When I heard about the new post-market studies, I saw that the complication rate was high, but was surprised that the complication rate wasn’t even higher. I had many of the same local complications. I can’t even remember how many surgeries I needed. Silicone was found in my side, when it migrated from the broken implant.
At a previous meeting, the data indicated that cancer patients and augmentation patients also had an increase in some autoimmune symptoms during the first two years after getting implants. I think my symptoms started in the third year, so it is likely that those signs and symptoms will increase over time, just like mine did. But it doesn’t seem that the post-market studies measured symptoms. It seems that they just measured diagnosed diseases.
When the FDA approved breast implants, they demanded post-market studies to find out how often these debilitating complications occur. But based on the women I’ve talked to with breast implants, it seems that the women with implant problems tend to stop going to their plastic surgeons and are therefore dropping out – or being intentionally dropped out – of the studies.
I didn’t have informed consent as a cancer patient, and from what I hear from other patients, that is still true today.
This meeting is focused on research but to do the right research, you need to listen to the patients who were harmed by implants. We illustrate the data. We are the examples of what can – and has – happened to tens of thousands of women across the country.
Carolyn Wolf
My name is Carolyn Wolf; I live in Virginia. I have paid my expenses to be here and I have no conflicts of interest.
At 41, I had subcutaneous mastectomies due to fibrocystic disease. Reconstruction was with Dow Corning silicone implants (1972).
Seven years later, small burning blisters formed on my neck. I stopped wearing neck jewelry, though allergy tests were negative. I wear no makeup. I continue to develop these blisters, and other implants report they have similar blisters.
By the 15th year, my implants had become very hard; after 17 years I was hospitalized for 3 days with all the symptoms of a heart attack, but tests showed no heart problems. I asked the internist “could the implants have caused this?” and was told “no”. In hindsight, I think this episode was the result of silicone leaking from my left implant.
Three years later, I had developed joint problems on my left side, my shoulder, elbow, knee, ankle and foot. Gradually my fingers and toes became numb.
I went for checkups every year at Walter Reed. No suggestion was ever made for an MRI until a bubble appeared on top of my right breast, about 26 years after getting implants. Because there was a long wait to get an MRI, a radiologist did an ultrasound. The report was “no cancer, everything okay”.
About a year later, I started feeling burning in my scalp; it felt like a red hot worm crawling along the part line. I also had three episodes when long strings of silicone came out of my ear.
Twenty-eight years after implantation, the left breast collapsed fully. I finally had my firstMRI, which showed both implants extensively ruptured. When the implants were surgically removed in 2000, the total material that came out would not have filled a small sized Styrofoam coffee cup. Obviously the rest had leaked or deteriorated into my body.
Because of continuing dizziness and brain fog, a brain MRI was performed in 2001. This showed more than 20 lesions on my brain. EMG tests showed much damage to my left eye, to my left arm and hand, and extensive neuropathy in the extremities. The neurologist studied a Mayo –he was no charlatan.
Three years ago I was hospitalized with Giant Cell Temporal Arteritis, with the same pain in my scalp. I have been able to control the inflammation with high doses of Prednisone.
I am diagnosed with connective tissue disease, multi-nodal thyroid chronic fatigue; fibromyalgia, PMR, asthma and COPD; MS-like syndrome with neuropathy; platinum poisoning (my platinum lever is 140, 35 times normal by CDC/OSHA standards), and Irritable Bowel Syndrome.
I am not the only woman with these kids of experiences. There are still thousands of women who have had leaking silicone breast implants in their bodies for decades. Many cannot afford surgery to remove them. Others, like me, had doctors who told them that their health problems are unrelated to their implants. In recent years, many of those doctors are saying “the FDA says they are safe and leaking silicone does not cause problems.” And many women believe the doctors, and just get sicker and sicker. Many of them just “give up” and even commit suicide – and it is NOT because they don’t have knobs on their chests.
I ask the Advisory Committee to think about how your recommendations will affect these women. Why is there no research focused on the women with leaking silicone implants and what happens to them?? The FDA did such a study 10 years ago, but the manufacturers say the newer implants are safer. But there are not studies to PROVE whether that is true, because the studies required by the FDA follow women for only 10 years.
Is the FDA willing to publicly state that silicone and platinum leaking into women’s bodies, year after year, is “perfectly safe”?
So far, the FDA keeps requiring the companies to do research, but the research if NOT getting done properly. Women are being terribly harmed as a result.
Please make sure that these research requirements are enforced.
Conclusions of Pam, Kathleen, and Anne in their Joint Testimony
So far, the post-market studies have all started studying women from the time they got implants for the next 10 years — although many women dropped out of the studies before 10 years had passed. In our experience, many women with implant problems have told us that they no longer felt welcome in their plastic surgeon’s office, so they sought health care from other doctors. We are concerned those are the women who dropped out of the post-market studies. If they are, then the complication rate is much higher than the studies are reporting.
We have heard on the news where plastic surgeons say that breast implants have been studied more than any other medical device. We don’t know if that is true, but if it is true, that is an indictment of research on other medical devices. The studies of breast implants aren’t asking the right questions. You need independent researchers, not the implant companies, to do this research.
We may not be your typical breast cancer reconstruction patients, but we have talked to a lot of women who have stories just like ours. The FDA needs to interview women like us, and ask questions about our kinds of symptoms. Then, include those symptoms in the studies that are done.
And why not find the women who were in the implant studies that started 10 years ago, and follow them for the next 10 years? Complications are much more rare at first and increase over time. So, starting with women who had implants put in 10 years ago would provide much more useful safety information than starting with women who got implants 2 years ago.
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Women with breast cancer often choose mastectomy because they don’t want to ever have to think about the cancer again. Unfortunately, the latest research shows that if they get reconstruction with silicone gel implants, they are likely to have many complications and need additional surgery.
Everyone agrees that breast implants are not lifelong devices. In fact, about half of reconstruction patients have their implants removed within 8-10 years. Even more women have leaking implants or other problems that require removal, but are reluctant to undergo surgery again. Those women were not counted by the companies that did the research.
There are two manufacturers that make breast implants in the U.S, and both got FDA approval to sell their silicone implants on the condition that they conduct 10-year studies on more than 40,000 women with implants. One company, Mentor, is doing a very poor job and that is why in August 2011 consumer advocates and public health experts asked the FDA to rescind approval of Mentor silicone gel breast implants. Mentor started their study of 40,000 women but within 3 years they lost track of 79% of their patients. In comparison, Allergan lost track of just over 25% of their reconstruction patients in the first two years.
When so many patients drop out of a study, it raises a lot of questions. Did the companies lose track of the patients because the patients did not stay in touch with their surgeon? Did patients stop going to the doctor because their implants were removed? Did they drop out of the study because they died or got very sick, or because they were so happy with their implants and their lives that they didn’t want to be bothered going back to the plastic surgeon or filling out questionnaires? Patients tell our organization that plastic surgeons are very enthusiastic about staying in touch with patients who are satisfied, but not with patients who are having problems. Some patients report being “fired” by their doctors, who let them know they are no longer welcome! When that happens, the research findings are biased and don’t provide accurate information about safety.
Another problem with the studies is that most did not ask about many of the complications that women with leaking implants tell us about. For example, in August 2011, women who got their breast implants in the last few years told the FDA that they suffered from joint pain, hair loss, memory loss, and other autoimmune symptoms. Instead, the studies asked women if they had been diagnosed with rare diseases or other types of cancer. Most women with implants assumed that the joint pain, memory loss, and fatigue they experience are from getting older, but when their implants were removed they felt younger and healthier than they had in years.
The huge number of patients who “dropped out” of these studies, and especially the Mentor studies, are such a problem that these results would not be publishable in any peer-reviewed journal. If a company can’t provide solid scientific evidence that their implants are safe for long-term use, we believe they should not be allowed to sell them in the U.S.
More Surgery and Other Problems from Implants
So what does the newest research data show? Only the better studies can tell us anything about safety, so we relied on only the few “Core studies” where at least 60% of the patients were followed up for at least 8 years. However, if women were taken out of the studies when their implants were removed, these complication rates are lower than they really were.
The Allergan Core Study followed 98 reconstruction patients who got implants for the first time.
Within 4 years, 41% had another operation to fix an implant problem. The most common complications and reasons for reoperation were dissatisfaction with how they looked, capsular contracture (painful hardening of the breast), hematoma (build-up of blood outside a blood vessel), or seroma (build-up of liquid). One in fourpatients had at least one implant removed. Other common complications included breast pain, infections, and swelling.
Within 10 years, 72% of the women underwent at least one additional operation to correct implant problems and 54% had at least one implant removed. One in four had serious capsular contracture and 23% complained of asymmetry. Other complications, such as breast pain, ranged up to 7% each. However, 27% of the implants were ruptured, affecting approximately half the women. The number of women affected by ruptured implants is much higher than the percentage of implants ruptured, because most women have two implants (but only rarely do both implants rupture at the same time).
The Mentor Core Study followed 251 reconstruction patients.
After 3 years, 27% had another operation to fix and implant problem (for the same reasons as listed above). Almost 13% had an implant removed. One in ten had serious capsular contracture and up to 7% reported other complications such as asymmetry.
Within 8 years, 39% had another operation to fix an implant problem and 23% had an implant removed. More than one in seven suffered from serious capsular contracture. However, 14% of the implants were ruptured, affecting approximately one in four women.
Why are the complication rates less high for Mentor? There are a few problems with the Mentor statistics. For example, some common complications, such as asymmetry, are not reported for the cumulative 8 year data. Also, Mentor complications were reported at 3 and 8 years, compared to 4 and 10 years for Allergan. In addition, Mentor lost more women to follow-up in their study. Those that had problems may have been more likely to drop out of the study or be dropped from the study when their implants were removed.
U.S. health regulators said they would consider setting up a registry that tracks safety problems with breast implants, after too many patients dropped out of company-funded studies.
But the U.S. Food and Drug Administration emphasized on Wednesday that silicone implants were safe and would stay on the market, despite calls for their removal by consumer groups.
Expert advisers who held a two-day meeting to discuss post-approval safety studies for silicone implants urged the FDA to establish a registry.
“We believe it’s a good idea to have a conversation about a breast implant registry. … (But) we believe implants are safe and effective and should remain on the market,” Dr William Maisel, deputy director of the FDA’s devices division, told reporters after the meeting.
In 2006 the FDA approved silicone gel-filled breast implants sold by Allergan and Johnson & Johnson’s Mentor unit on condition both companies follow 40,000 women for 10 years to look at safety issues, as well as extend smaller pre-approval studies.
So far, Allergan has collected preliminary two-year data for 60 percent of participants, while Mentor has collected three-year data for only 21 percent — well below the 65 percent the FDA said would be acceptable.
“It’s very inefficient to enroll 40,000 patients, and only get data on 400 on them (for rare symptoms). So having registries is a much more high-value approach,” said Jason Connor, a biostatistician on the advisory panel.
There were almost 400,000 breast enlargement or reconstruction procedures in the United States in 2010, according to the American Society of Plastic Surgeons. That includes silicone and saline implants.
In June, the FDA said the risks of breast implants are well understood, after looking at the companies’ results as well as reports of negative events and scientific literature. It said women who get silicone implants are likely to need additional surgery within 10 years.
The agency had banned silicone implants for most U.S. women in 1992 after some said the devices leaked and made them chronically ill.
The companies and FDA advisers said patients and their doctors may not have enough incentives to stay in the company-funded studies, especially if they have to fill out a 27-page questionnaire every year, or do expensive medical procedures such as MRIs that test if their implant has ruptured.
A registry, which would track any patient who has had a breast implant, can provide broader data, making it easier to identify any complications, such as rupturing of the device.
Panel members said women should be encouraged to enroll in the registry by linking participation to the warranty on their devices, or to their surgeons’ certification.
Maisel also said it was important to involve different groups, including advocacy groups and physicians, to make sure patients understand the benefits of sharing information about their implants.
“What we’ve heard over the last two days is that it takes a whole community,” Maisel said. “You can have the most well-meaning company, but if the patients don’t want to participate in the study, that’s out of their control.”
However, some groups said the agency was letting manufacturers, especially Mentor, off the hook.
“You can’t ignore the fact that Allergan has three times more patients participating than Mentor. You can’t not hold Mentor responsible for that,” said Diana Zuckerman, president of the National Research Center for Women & Families.
Officials Say They Will Work With Companies to Improve Follow-Up Rates
After two days of testimony on what the FDA should do about troubled long-term safety studies of silicone-gel breast implants, agency officials said the studies would continue.
“The current post-approval studies will continue,” said William Maisel, MD, MPH, chief scientist in the FDA’s Center for Devices and Radiological Health, in remarks after the meeting. “The FDA is committed to seeing them completed and making sure the follow-up rates improve.”
The safety studies in question, of nearly 100,000 women with breast implants, which the FDA said were the largest ever required of manufacturers after their devices were marketed to the public, have lost track of up to 79% of the women they enrolled just three years into planned 10-year efforts.
As a result, FDA epidemiologists testified yesterday, the studies had lost the ability to find rare complications, including connective tissue diseases, that they were designed to look for.
Save or Scrap Troubled Studies?
In a second day of testimony, the General and Plastic Surgery Devices Panel of the Medical Devices Advisory Committee to the FDA heard plenty of opinions about what should happen with the studies.
Some panelists felt the companies should be compelled by the FDA to finish the studies they had agreed to complete as a condition of the approval of their devices. They asked FDA officials what regulatory powers the agency could wield to do that.
“If you do not meet the conditions of approval the FDA does have regulatory authority to either impose civil penalties or other regulatory actions,” said Mark N. Melkerson, director of the Division of Surgical, Orthopedic and Restorative Devices at the FDA’s Center for Devices and Radiological Health.
The agency said it was not considering taking silicone breast implants off the market.
Some consumer advocates thought that option ought to be on the table, however.
“It has now been 25 years since FDA declared silicone breast implants a class III device, and in that period, only weak attempts have been made to assess the safety of these implants,” said Kate Ryan, of the nonprofit Breast Cancer Action, which is based in San Francisco.
“Follow-up rates on the two large studies are dismal,” Ryan said in testimony. “Given that these studies were a condition of approval, Mentor should have done much more to ensure it had the technical skills to locate women and provide women with incentives to participate in this important research.”
Manufacturers Respond
Manufacturers fired back against the notion that they weren’t doing enough to complete the studies.
“To imply that patient safety is not first on our radar is simply inaccurate,” said Caroline Van Hove, a spokeswoman for Allergan. She said the company hoped that the meeting would give the FDA an opportunity to more fully appreciate the complexity of the required studies.
“In general, we are highly committed to collecting quality data in a way that is possible for them and possible for us,” she said.
In other testimony, panelists heard from plastic surgeons like Dennis Hammond, MD, of Cedar Rapids, Mich., who participated in the clinical trials of Mentor’s Memory Gel implants.
In contrast to the 21% of patients retained overall by one of the Mentor studies, Hammond said he’d kept track of about 76% of the women he was following.
Panelists asked him how he did it.
“You’ve got to have dedicated surgeons that are really interested in making this study work,” Hammond said. He said he had one staff member devoted to follow-up with women in the clinical trial and that he allocated about half a day of clinical time each week to seeing women in the study for follow-up visits.
Additionally, “A really compelling part would be if the patient had some sort of compensation. It doesn’t have to be wild, really, just something they get back to compensate for the drive in.”
Allergan, the maker of Natrelle implants, which had a 60% follow-up rate with patients after two years, said they paid women a small amount of money for filling out annual questionnaires and coming back to scheduled office visits. Mentor did not.
“While it was certainly admirable to try to get 40,000 patients [in each study] to come back, that just wasn’t going to happen,” Hammond said.
Perspective of Surgeons
The American Society of Plastic Surgeons (ASPS) agreed, and it urged the FDA to consider other data sources, besides the troubled studies, if the agency still felt the need for continued safety monitoring.
“There has been shown to be no relationship between silicone breast implants and connective tissue disorders, which was the main reason these studies were agreed to on the release of these products,” said Phil Haeck, MD, president of the ASPS, in testimony to the panel. “This issue has been settled with the post-approval study data as it already stands now.”
Haeck said sources like the FDA’s own surveillance system, the Manufacture and User Facility Device Experience (MAUDE), which relies on clinicians to report instances of adverse events associated with devices, case reports, patient registries in the U.S. and Europe, and reviews of medical studies, could be relied on to spot any rare events that might arise.
Consumer advocates, like Dana Casciotti, PhD, the public health research director at the Cancer Prevention and Treatment Fund, said annual, 27-page questionnaires women were asked to complete should be shortened and simplified.
“I’ve seen copies of these questionnaires, and they are much too long” and technical, she said.
Panel members seemed to agree, and some suggested that future questionnaires might yield better data if they focused on symptoms rather than diagnosed diseases, since many connective tissue diseases, like lupus, are difficult to diagnose.
Perspective of Surgeons continued…
Patients who took time off work and paid their way to testify at the meeting urged the FDA to keep trying to answer questions about the long-term and rare complications of breast implants.
“Not everyone gets sick, but those who do, we pay dearly,” said Sharon Schwengler of Phoenix.
WASHINGTON — After two days of discussion and testimony about silicone breast implants, a top government health official said he had heard nothing to shake his faith in the safety of the widely used implants.
“We felt that way before the meeting, and we continue to feel that way after the presentations and discussions over the past two days,” Dr. Maisel said.
There are risks to the implants, however, Dr. Maisel said, including ruptures, a hardening of the area around the implants, the need to remove the implants, scarring, pain, infection and asymmetry. “Women should feel assured that the F.D.A. continues to believe that currently marketed silicone breast implants are safe,” he said.
Some patients and women’s groups who testified at the meeting disagreed.
Diana Zuckerman, president of the National Research Center for Women and Families, a research and education group, told an expert panel that the two companies that manufacture silicone breast implants — Johnson & Johnson and Allergan — had done a poor job of studying patients who got the implants, as the F.D.A. required them to do.
“And without proper data, we still don’t know how safe or effective they are and whether there are certain patients at risk for extremely negative outcomes,” Ms. Zuckerman said.
Dr. Maisel agreed that the studies conducted by the two companies had failed to follow as many patients as the agency had hoped.
One purpose of this week’s meeting was to ask the expert panel what the agency and the two companies should do about that poor follow-up. Some suggested that patients should be paid for participating; others mentioned that doctors should get some money, too.
There was some criticism of the 27-page research form that patients who participate in the study are required to complete and whether it could be shortened. Nearly all expressed hope that a registry could be created that would follow all breast implant patients, but such registries are expensive to maintain and complicated to create.
The committee also agreed that patients should no longer be told that they should get a magnetic resonance imaging test three years after getting implants and every two years following.
The reason for telling patients to get M.R.I.’s is that silicone breast implants sometimes rupture without women being aware, and an M.R.I. can reveal this unseen problem.
But many patients ignore the requirements because M.R.I.’s are expensive and it is not clear what they should do when an unseen rupture is discovered; the risks associated with ruptured implants may not be greater than the risks of the operation needed to take them out.
“F.D.A. continues to believe, as does the panel, that M.R.I. is the gold standard for evaluating breast implants for silent rupture,” Dr. Maisel said. “But there was consensus among the panel that the requirements for ongoing M.R.I.’s should be removed.”
Dr. Maisel promised that the F.D.A. would study whether to follow this advice.
Margaret A. Hamburg, M.D.
Commissioner
Food and Drug Administration
10903 New Hampshire Ave
Silver Spring, MD 20993-0002
Dear Commissioner Hamburg:
We are writing to make very clear that there is a significant element of the public health community that includes patient, consumer and scientific integrity advocates that strongly oppose any efforts by the FDA to loosen the current conflict of interest rules for members of FDA advisory committees. In fact, it has been our position that the agency’s management of such potential conflicts of interest needs to be made stronger.
Over the past several years, organizations that are members of the Patient, Consumer, and Public Health Coalition have consistently raised concerns that advisory committee member conflicts of interest, both disclosed and undisclosed, continue to raise the specter of bias in the advice that advisory committees provide the agency. The perception and reality of conflicts of interest seriously undermines the public’s faith in the integrity of recommendations made by advisory panels to the agency.
Earlier this year, in the context of our public comments on proposals regarding renewal of Prescription Drug User Fees, we once again brought up the issue of conflicts of interest and our belief that FDA must do more to manage potential conflicts in order to keep the public trust. We understand that there are differences of opinion on this issue. However, your suggestion that most patient and consumer stakeholders want to loosen the rules is truly disappointing and puzzling to us.
We respectfully request an opportunity to discuss our concerns with you as soon as it is possible to schedule a face-to-face meeting.
Annie Appleseed Project
Breast Cancer Action
Center for Medical Consumers
Community Catalyst
Consumer Federation of America
Consumers Union
Jacobs Institute for Women’s Health
National Consumers League
National Research Center for Women & Families / Cancer Prevention and Treatment Fund
National Women’s Health Network
THE TMJ Association
Union of Concerned Scientists
U.S. PIRG
Woody Matters
For more information, contact Paul Brown at (202) 223-4000 or pb@center4research.org