|
All
of these inclusions will, if anything, tend to overestimate
the risk of events (relative to population statistics which
tend to exclude these diagnoses).
The
MI category includes the following adverse event reports:
12851, 12485, 12452, 13009, 13463, 13096, 12721, 13127,
13021, and 12843. The stroke category includes: 12483, 13062,
12713, 12733, 12861, 12980, 12888, 13336, 13418, 12460,
12487, 12871, 12921, and 13380. The seizures include: 12948,
12975, 13001, 13405, 13344, 11919, and 12927.
Reporting
Rate
The
true number of events among persons using ephedra alkaloid-containing
products is not known. The number of reported events is
likely to represent a fraction of the number of events occurring
among persons using ephedra products because of under-reporting
of events. The value of this fraction is unknown and numerous
factors may increase or decrease this value.
Factors
that might increase reporting include the severity of events,
the acuity of events, the rarity of the event in the exposed
population, close temporal relationship between exposure
and the event, and publicity surrounding the exposure.5
The events evaluated in this report (seizure, stroke, and
MI) are all acute, dramatic, usually severe, and often life-threatening.
In addition, it is expected that ephedra users are relatively
young, and therefore, these events are rare in this population
(as demonstrated in the first aim of this report). Further,
other traditional causes of these events (especially older
age) are less likely to be present and therefore to be attributed
as the cause of the events. Also, these are not events that
have long latency periods; MIs, strokes, and seizures are
acute events (albeit often occurring on a pre-existing substrate
such as atherosclerotic or congenital cardiovascular disease).
These events are not long-term, delayed consequences of
exposure that would be less likely to be reported. Finally,
there has been substantial publicity of adverse events and
ephedra alkaloid-containing products during the period studied.
All of these factors might increase reporting of adverse
events.
On the
other hand, several factors may reduce reporting of adverse
events. Reporting for dietary supplements may be less than
for over-the-counter (OTC) or prescription medications for
several reasons. Although, to my knowledge, there have not
been direct comparisons between actual reporting rates for
dietary supplements and traditional medications, both dietary
supplement users and physicians may be less likely to associate
and report adverse events with dietary supplements. People
also may be less likely to tell their "traditional
medicine" doctors about consumption of dietary supplements,
and doctors may be less likely to ask patients about dietary
supplement use.6 In a recent British study, 51%
of patients using herbal products stated that they would
probably consult a healthcare provider or pharmacist if
they had a serious adverse event after taking the product
compared with 67% for OTC medications.7 In addition,
an important source of adverse event reporting, pharmaceutical
companies, is not available to report adverse events from
dietary supplements.
Several
studies have been performed to try to estimate adverse event
reporting (although none, to my knowledge, have directly
examined dietary supplements). In one British study, 2.4%
of MIs following numerous medication exposures were reported.8
From this same study, cardiac arrest was reported at a rate
of 18%.9 In a study of seizures following vaccines
(a time of heightened awareness of the possibility of an
adverse event and using a system that promoted reporting),
the reporting rate was 24-42%.10 Two studies
performed by the same group of researchers tried to estimate
reporting rates using an indirect method of calculation,
but did not actually measure reporting rates. One study
estimated reporting of serious events in 1 in 4,610 events
(95% confidence interval from 2,514 to 8,454) while the
other estimated 1 in 605 (95% confidence interval from 0
to 1,444). Interpretation of these two studies' findings
is difficult because of the severely limited study design,
because the same investigators obtained such disparate results
using the same methodology, and because of imprecision (one
of the confidence intervals actually included 0, meaning
no under-reporting).11,12 Although not a direct
study of reporting rates, a report from FDA estimated that
25-50% of cases of eosinophilia-myalgia syndrome from dietary
supplements containing L-Tryptophan were reported following
a media campaign (in some ways, not dissimilar to the ephedra
experience).13
FDA
estimated that 10% of events were reported for the 1997
proposed rule on dietary supplements containing ephedra
alkaloids.14 Whether this applies to the serious
adverse events discussed here or whether rates are higher
or lower (for the reasons described above) is unknown. Therefore,
a range will be presented, from 1% to 20%. This provides
a reasonable range of possible results.
Estimate
of Person-Time Exposure to Ephedra
Source
of Data
Similar to many pharmaceutical products, there is no direct measurement of the number of individuals exposed to ephedra. Therefore, in order to estimate exposure, data are used from a recent survey of ephedra sales conducted by Arthur Andersen for the American Herbal Products Association (AHPA) (hereinafter AHPA Survey). This survey is attached as Exhibit 1. Briefly, Arthur Andersen mailed surveys to 42 companies that distribute dietary supplements containing ephedra alkaloids and whose products were listed in FDA's proposed rule. Of the 42 companies solicited, 13 (31%) reported on annual sales of products containing ephedra alkaloids for each year of the period of 1995 through 1999. All reports were anonymous. The number of servings (defined as the maximum amount to be consumed each use) sold for the years of interest is depicted in Table 2 below:
Estimate
of Total Sales
The
total number of servings for the years included in the adverse
event reports (June 1997-March 1999) is estimated to be
3,011,125,014 [(976,466,984/2 = one-half of 1997) + (1,751,381,254)
+ (3,086,041,072/4 = one-quarter of 1999)]. Because sales
may not be distributed evenly across a year, this is just
an estimate: sales in second half 1997 may represent more
than half of all annual sales in 1997, and sales in the
first quarter of 1999 may represent less than one quarter
of all sales in 1999.
Only
13 out of 42 companies (31%) provided data on ephedra supplement
sales, and not all companies who make supplements containing
ephedra alkaloids were included in the 42 surveyed. Therefore,
the numbers presented in Table 2 are clearly an underestimate
of total sales of ephedra alkaloid-containing dietary supplements.
However, to be as conservative as possible, the primary
calculations assume that these data represent the total
amount of ephedra sales. This will underestimate the number
of users and overestimate the risk of events among users.
As a secondary estimate of use (see below), it will be assumed,
arbitrarily, that the 13 companies reporting represent 75%
of all ephedra-containing supplement sales. This is simply
to estimate how sensitive the results are to the assumption
of sales.
Estimate
of Person-Years Exposure
In
order to estimate the amount of person-years of ephedra
use, two other pieces of data from the AHPA survey were
used.
First, the maximum amount, in milligrams (mg) of ephedrine alkaloids, recommended for each serving was ascertained in the AHPA survey (Table 3).
From these results, an estimate of the average serving size was calculated as follows: Table 4 displays the average serving size per category from Table 3 and the proportion of products that are within that serving size. The > 25 mg group was assumed
to be an average of 30 mg. Although this is arbitrary, an unstructured review of dietary supplements containing ephedra alkaloids revealed no products that list > 30 mg as the maximum serving size. Using the data above, the estimated average serving size is: 5*(33.3%)
+ 12.5*(26.2%) + 20.5*(39.3%) + 30*(1.2%) = 13.35 mg
It is
possible that the average serving size consumed is greater
than 13.35 mg, especially since the most common serving
size is 16-25 mg. If this were so, the estimate of person-years
exposure in these calculations will be falsely low (as discussed
below), and the risk among ephedra users will be falsely
high. It is also possible that consumers use less than 13.35
mg per serving. As stated previously, the variability in
use cannot be determined from this study, and the use of
an average serving size seems the most reasonable.
Second, the average daily maximum use was calculated from the following data from the AHPA survey.
Using the average dosage from each category, the average 24-hour maximum dosage is therefore: 37.5*(63/123) + 75.5*(60/123) + >100 mg%*(0%)= 56.0 mg
From the above two estimates (average serving size of 13.35 mg and average maximum daily dose of 56.0 mg), the average servings/day can be calculated: Average Max Dose (56 mg) ¸ Average servings/day (13.35 mg) = 4.2 servings/day
This
estimate is likely to be conservative (i.e., will underestimate
number of person-years) because most users probably consume
fewer than four servings per day. Although the reports from
the AHPA survey were anonymous and identification of companies
and products is not possible, a review of many of the web
sites listed in the FDA market analysis of ephedra-containing
products revealed that many products are marketed for less
than four servings per day, particularly those marketed
for energy or performance enhancement. Similarly, people
who use products for episodic effects, such as products
promoted for energy (which often state to take prior to
a workout), performance enhancement, cough or colds are
unlikely to consume four servings per day. Importantly,
although some products may be marketed with instructions
for use up to more than four tablets per day (e.g.,
"take 1 or 2 tablets three times a day"), none
were identified that recommended use more than four servings
a day (albeit all products were not surveyed). Because the
definition of "servings" in the survey was the
"maximum amount to be consumed each use,"
even products suggesting multiple tablets per use would
still not be used more than four times a day. Even if this
was misunderstood by the survey respondents as "servings"
rather than "episodes of use," a review of many
of the web sites listed by FDA in their market review suggests
that most products are labeled for no more than four "servings"
per day. In the AHPA survey itself, 48% of products were
marketed for energy or athletic performance. Therefore,
as discussed above, many people were likely to use the product
less than four times a day.
In addition,
the estimate of use is likely to be low because the average
serving is probably greater than 13.35 mg (as discussed
above). If so, the calculation of 4.2 servings/day, above,
is an overestimate (because the denominator should be greater
than 13.35), and the number of person years (total sales
divided by servings/day) will be an underestimate.
Using
the conservative estimate of 4.2 servings/day and the total
number of servings sold in the time period of interest of
3,011,125,014, the estimated person-days of exposure is
717,426,006 (3,011,125,014 servings ¸ 4.2 servings/day)
or 1,965,551 person-years of ephedra use. This is the primary
estimate used for the calculations in this analysis. If
only 75% of all ephedra products were represented by the
13 companies responding (who represented only 31% of all
companies surveyed), the estimate of person-years of ephedra
use would be 2,620,734 person-years. This number was used
as a secondary estimate of person-years of exposure. As
mentioned previously, the purpose of this secondary analysis
is simply to determine how sensitive the assumptions are
to the estimate of person-time of exposure. If the average
use was less than 4 servings/day, the above estimates of
person-years exposure will be an underestimate.
In fact,
some recent data suggest that usage is greater than the
estimated 2 million person-years. In a recent survey of
patients presenting to anesthesiologists in the preoperative
period, investigators in Texas found that over 11% of patients
ages 18-80 years old were taking products containing ma
huang. See Exhibit 2. Because this was a selected
patient population, it is difficult to generalize these
findings to the rest of the population. Whether the need
for surgery reflected a population less likely to use supplements
(e.g., the use of ephedra for weight training may be less
in this population) or more likely to use them (e.g., if
obesity-related disease was the reason for some surgeries,
this could lead to more use) is unknown. Also, because underreporting
of use of dietary supplements may occur,6 this
estimate may be low. With these caveats: even assuming that
this estimate applied only to adults ages 20 to 64 in the
U.S. in 1997 (approximately 156 million [Population Estimates
Program, Population Division, U.S. Census Bureau, Washington,
D.C. 20233]), there would be an estimated 17 million ma
huang (ephedra) users. Even if the duration of use were
only three months, this would represent over five million
person-years of use.
Estimate
of Baseline Risk in the Population
The
estimates of risk among ephedra users (estimated number
of users ¸ estimated number of person-years) was then
compared with the population background risk. The estimated
risk of seizures, strokes, and MIs in the general population
who are the same age and gender as the cases among ephedra
users cannot be known exactly. Therefore, a range of probable
risk is presented, based on the results of Aim 1 of this
report. The risk in the U.S., under-65 population derived
from Aim 1 was used. The upper age of 65 is used because
no events were reported in individuals over 65. When possible,
the lower age limit is 15, corresponding to the youngest
reported case in this series. Because different results
do not produce exactly the same estimates, a range is given.
Because all U.S. data derive from prior to 1995 (and most
derive from the 1980s), it is extremely unlikely that these
rates are influenced by users of ephedra alkaloid-containing
dietary supplements in the population. That is, the rates
are likely to be truly representative of the background
risk of events in the absence of ephedra-containing supplement
use.
Presentation
of Results
For
each outcome (seizure, stroke, MI), the estimated rate of
events per 100,000 person-years of ephedra use is presented
graphically over a range of reporting rates of adverse events.
The primary exposure time is 1,965,551 person-years, and
the secondary time is 2,620,734 person-years. The range
of background risk in the population (per 100,000 person-years)
is displayed as a gray box over the graph to show the range
of possible risk of events in the general population.
Back to top RESULTS:
Aim
1 Incidence of Events in the Population
A
total of 383 articles were identified for seizures. Review
of the abstracts of these articles revealed that 11 were
studies of population-based incidence. All 11 were reviewed
and 4 met criteria to be included.
Of the
374 papers on stroke, 44 were selected on the basis of review
of the abstracts and 40 were found. (Four were not available
at our University library.) An additional 8 were identified
on the basis of a review paper, and 7 of these were available
in our library. Of the 47 papers reviewed, 24 met criteria
for this review.
For
MI, 654 papers were identified and, of these, 51 abstracts
appeared to meet criteria for inclusion. Of these, 45 were
reviewed and 6 were not available. Of the 45 reviewed, 11
met criteria to be included.
Seizures
Table
6 presents the incidence rates of seizures. The range of
incidence rates are from about 20 per 100,000 to 76 per
100,000. Excluding infants and adults over 65 years old,
the rates are approximately 11 to 60 per 100,000. In the
U.S., 15-65 age group, the incidence of events in these
studies ranges from about 20 per 100,000 to about 60 per
100,000.
Strokes
Table
7 presents the incidence rates of strokes. The incidence
of stroke increases with age. However, strokes do occur
in the younger population. In the less than 65-year-old
population, the stroke incidence ranges from 0 to 363 per
100,000, depending on the age group. In the U.S., under-65
adult population, the incidence of strokes in these studies
ranges from about 3 per 100,000 to about 363 per 100,000,
again depending on the age group.
Myocardial
Infarctions
Table 8 presents the incidence rates of MIs. The incidence of MI increases with age, but MIs do occur in the younger population, both men and women. In the less than 65-year-old population, the MI incidence ranges from 0 to 1939 per 100,000, depending on the specific age group included. In the U.S., under-65 adult population, the incidence of MIs in these studies ranges from about 0.2 per 100,000 to about 337 per 100,000, again depending on the specific age group.
* CI=confidence
interval
Ü No
identifiable cause to incite event at the time of event
á No identifiable cause to incite event at the time of event and no prior, remote central nervous system insult to explain the event
* CI=confidence interval
* CI=confidence
interval
Summary
of Aim 1:
In
summary, there is a wide range of estimated incidences of
seizures, strokes, and MIs. Although strokes and MIs are
more likely to occur in the older population, they occur
in all age groups. Unprovoked seizures can occur with equally
high frequency among all age groups.
Aim
2 Estimates of Incidence of Events Among Ephedra Users
Seizures
Figure
1 presents the range of estimated risk of seizures per 100,000
person-years of ephedra use. The age range of seizures reported
to FDA is 21-51 years old. The background risk of seizure
in the U.S. population in approximately this age range is
derived from the two U.S. studies presented in Table 6.
In the study of Hauser et al.,16 the rates in
the 21-40 and 41-60 year age groups are approximately 25-35
and 20-35 per 100,000, respectively. In the study by Annegers
et al.,18 the rates per 100,000 in the 15-24,
25-34, 35-44, and 45-54 age groups are, respectively: 50.9,
59.6, 23.3, 20.0, and 24.8. Therefore, Figure 1 uses a range
of 20 to 60 per 100,000.
Using
the above estimates, Figure 1 demonstrates that the estimated
risk of seizures among ephedra users is unlikely to exceed
the underlying risk in the population, even under the most
extreme assumptions of 1% reporting of events and the most
conservative assumption of ephedra use. Although most of
the risk estimates are lower than the population range,
this should not be interpreted as a protective effect of
ephedra. It is possible that reporting rates are, in fact,
towards the lower limits shown in the graph because seizures
are more common in the younger population and often not
life-threatening; therefore, these events may be less likely
to be attributed and reported to FDA.
Stroke
Figure
2 presents the range of estimated risk of stroke per 100,000
person-years of ephedra use. The age range of strokes reported
to FDA is 18-64. Sixty-nine percent of reports with known
age involved people over the age of 34 and almost half were
in people older than 45.
The
background risk of stroke in a similar age range is derived
from several U.S. studies presented in Table 7. In Petitti
et al.,19 the risk of stroke in women 15-44 is
10.7 per 100,000. The study of Broderick26 estimated
the stroke incidence in people under 45 years old to be
about 10 per 100,000; in those 45-54, about 100 per 100,000;
and in those 55-64, about 200 per 100,000. Brown et al.34
estimated the risk in men and women 0-34 years old to be
only 4 and 3 per 100,000 respectively, but the risk increased
substantially in those over 34: in men the incidence ranged
from 36 to 363 per 100,000 and in women, from 29 to 195
per 100,000. In Kittner et al.,39 the incidence
of stroke is separated into infarction and hemorrhage. Combining
these (as they are combined in the estimates of strokes
among reports to FDA), the incidence in the 15-39 age group
varies (depending on gender and ethnicity) from about 7
to about 20 per 100,000. In the 40-44 year age group, the
range is about 42 to 146 per 100,000. Given the wide range
of estimates in the literature, and to be conservative,
Figure 2 uses a range of 3 to 60 per 100,000. The upper
range of 60 was used because it represents the lowest rate
in people 45-54 in the U.S. studies. This upper limit may
be too low because almost half of all reported strokes occurred
in individuals older than 45 years, and over 20% were in
people older than 54; the incidence in the 45-64 year old
population is almost uniformly over 60 per 100,000 and often
substantially higher (e.g., around 100-20023,25,26,29,30,40)
.
For
almost all of the assumptions made, the incidence of strokes
among ephedra users is within the estimated range for background
risk in the population. For many of the assumptions made,
the risk is no greater than even the lower end. Only for
the most conservative assumption of use and the assumption
of 1% reporting is the estimate above the range. However,
it is not strikingly higher and is certainly consistent
with the higher stroke rates of a population that includes
people over the age of 45.
Myocardial
Infarction
Figure
3 presents the range of estimated risk of MI per 100,000
ephedra users. The age range of MIs reported is 15-59, and
30% of reported events occurred in people over the age of
44. Among MIs in those younger than 44, 57% were in men.
Based on the two U.S. studies presented in Table 6, the
range of MI incidence in the population ages 15-44 is about
5 per 100,000 (women only, ages 15-44)19 to 41
per 100,000 (ages 25-44).48 Because 30% of MIs
occurred in people older than 44, these latter estimates
do not reflect the higher incidence in the > 44 population.
For example, in the latter study, the incidence was 234
per 100,000 in those 45-54. However, a summary incidence
for all people ages 15 to 59 is not available from the U.S.
It is certainly higher than the estimates for those younger
than 45. For example, in one French study, the incidence
in men 30-59 was 103 per 100,000.43 Nonetheless,
a conservative range of 5-41 per 100,000 person-years was
used.
For
almost all of the assumptions made, the incidence of MI
among ephedra users is within the estimated range for background
risk in the population. For many of the assumptions made,
the risk is no greater than even the lower end. Only for
the most extreme assumptions of under-reporting and usage
was the incidence higher than the population-range. As for
stroke, this estimate was not strikingly higher. Furthermore,
because the population range is for people less than 45
years old, the comparison is biased towards showing more
events among the older ephedra MI cases.
Limitations
As
discussed previously, there are numerous limitations to
the analysis for Aim 2. This is due to the many limitations
of adverse event reporting data and the limited data available
on the exposed population. First, the true number of adverse
events is not known, for the reasons previously described.
An attempt was made to provide a range of estimates that,
if anything, would overestimate the number of events. For
example, all events, including those in the "insufficient
data" group and those that may not be included in background
estimates (e.g., unstable angina and transient ischemic
attacks), were included. Because the reporting rate of adverse
events is not known, a range of estimates was used with
the lowest estimate (1%) likely representing a true lower
estimate given the severity and nature of the events studied
(although even this cannot be known for sure). Second, the
number of exposed individuals was not known. Again, attempts
were made to, if anything, underestimate this number. For
example, it was assumed for the primary estimates that,
even though only 13 companies reported on ephedra sales
(31% of those surveyed), this represented total sales of
ephedra. The average number of servings per day used for
the calculations (four) was also probably an overestimate,
thus underestimating the number of ephedra users. The data
from the Texas study suggest that, in fact, the person-time
estimate used was indeed an underestimate. Third, it is
likely that not all ephedra sold was actually consumed.
This is a limitation of all analyses using sales data and
is similar for studies of drugs that use prescription data
(because not all patients take the drugs that are prescribed).
However, in randomized trials of OTC ephedrine combined
with caffeine, the drop-out rate from side-effects is about
4-16%.51,52 Even assuming that 16% of all ephedra
sold is not consumed, the results do not substantially change.
Fourth, and most importantly, a direct comparison of risk
of events among users of ephedra alkaloid-containing products
versus non-users cannot be made. Such a comparison is necessary
to determine if there is or is not an association between
ephedra use and the outcomes examined.
Of
course, different assumptions of all parameters and different
time periods of reporting may have led to somewhat different
results. This simply highlights the known limitation of
using adverse event reporting and sales data to answer questions
about cause-and-effect relationships.
Summary
of Aim 2
This
analysis demonstrates the need to consider background risk
in evaluating adverse event reports. Although seizures,
strokes, and MIs are relatively rare in the younger population,
they do occur. Given the substantial number of people who
are likely to use dietary supplements containing ephedra
alkaloids, the number of events reported may not be inconsistent
with the expected number of events in the absence of ephedra
use. Only under the most extreme assumptions was the estimated
risk of events near the upper limit of estimated risk in
the population. In no instance was the risk extremely elevated,
as it was, for example, with fenfluramine. When fenfluramine
and dexfenfluramine were removed from the market the estimated
prevalence of valve abnormalities based on case-series was
over 30-fold higher than the estimated population prevalence.
However, this analysis was not designed to rule in or out a possible cause-and-effect relationship between ephedra and the outcomes evaluated, nor could it do so. Only formal comparative studies can be used to compare the risk of events in ephedra users compared with non-users. In their absence, this analysis suggests that the adverse events reported among ephedra users may very well represent simply the background rate of events expected among such a large number of people, unrelated to ephedra use.
References
Back to top |
|
|
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||