Natrol DHEA 25mg, 180 Tablets (Pack of 2)
Transcription
Natrol DHEA 25mg, 180 Tablets (Pack of 2)
Join Prime Shop by Department J's Amazon.com Today's Deals Gift Cards Sell Help Hello, J Search Departments Health & Personal Care Join Your Account Prime "dhea" Related Searches: dhea 100mg, dhea 25mg, dhea 50 mg. Weight Loss Supplements Vitamins & Dietary Supplements Showing 1 - 16 of 2,393 Results + See more... Beauty Body Creams Bath Products Facial Treatment Products Books Health, Fitness & Dieting Alternative Medicine Other Diet Books Nutrition Biological Sciences + See more... Kindle Store Diets + See more... + See All 18 Departments International Shipping (What's this?) AmazonGlobal Eligible Natrol DHEA 25mg, 180 Tablets (Pack of 2) by Natrol $29.74 $17.21 ($0.05/tablet) Order in the next 5 hours and get it by Tuesday, Jun 11. (30) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite $16.35 ($0.05/tablet) Subscribe & Save Save more with monthly Subscribe & Save deliveries. More Buying Choices $11.75 new (8 offers) Ultimate Nutrition DHEA Platinum Series Capsules, 100 100-Count Bottle by Ultimate Nutrition $33.95 $22.09 ($0.22/count) Order in the next 7 hours and get it by Tuesday, Jun 11. (24) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite More Buying Choices $11.80 new (9 offers) Shipping Option (What's this?) Free Super Saver Shipping Health & Personal Care Feature Natural Unscented Travel Size Brand Natrol Life Extension Natrol DHEA 50mg, 60 Tablets (Pack of 3) by Natrol $27.84 $16.47 ($0.09/tablet) Order in the next 7 hours and get it by Tuesday, Jun 11. (13) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite $15.65 ($0.09/tablet) Subscribe & Save Ultimate Nutrition Save more with monthly Subscribe & Save deliveries. Pure Encapsulations More Buying Choices Jarrow $16.23 new (16 offers) Life-Flo DHEA + See more... Supplements Item Form Capsules Cream Liquid Oil Powder Tablets Nutritional Supplement Type Dehydroepiandrosterone Dhea 25 mg 120 Caps by Swanson Premium Brand $12.50 Order in the next 5 hours and get it by Tuesday, Jun 11. More Buying Choices $5.49 new (6 offers) (52) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite (DHEA) Life Extension, DHEA (Dehydroepiandroster... 50 Mg, Ca 60-Count by Life Extension Fiber Pregnenolone 7-Keto $17.43 $12.00 ($0.20/count) Only 6 left in stock - order soon. Androstenedione Omega 3 (19) Health & Personal Care: See all 1,207 ite More Buying Choices Resveratrol $12.00 new (22 offers) Book Format Paperback HTML MRM Micronized DHEA Vegetarian 50 mg Caplets, 90-Co Kindle Edition MRM Avg. Customer Review & Up $14.27 $11.39 ($0.13/count) Order in the next 3 hours and get it by Tuesday, Jun 11. & Up & Up (16) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite $10.82 ($0.12/count) Subscribe & Save & Up Condition New Save more with monthly Subscribe & Save deliveries. Used More Buying Choices new (22 offers) DHEA 100 mg 60 Caps by Swanson Ultra $13.99 Order in the next 7 hours and get it by Tuesday, Jun 11. (12) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite More Buying Choices $7.29 new (7 offers) ! " # Pure Encapsulations - DHEA Micronized 10mg 180 VegiC and Beauty] by Pure Encapsulations " " % & $ $25.30 ($6.32/oz) Order in the next 7 hours and get it by Tuesday, Jun 11. Only 15 left in stock - order soon. ( $ ! $25.30 new (44 offers) Schiff DHEA Plus Enhanced With Resveratrol 25 mg DHE Resveratrol, 350 Tablets by Schiff $15.25 More Buying Choices *! ( Health & Personal Care: See all 1,207 ite More Buying Choices %' # (10) Eligible for FREE Super Saver Shipping. )# + ' $9.03 new (3 offers) (21) Health & Personal Care: See all 1,207 ite DHEA 5mg Sublingual 100t by Douglas Labs $10.80 Order in the next 7 hours and get it by Tuesday, Jun 11. Only 9 left in stock - order soon. (6) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite More Buying Choices $10.80 new (13 offers) DHEA Micronized 25mg 180 VegiCaps by Pure Encapsulations $32.80 ($6.83/oz) Order in the next 6 hours and get it by Tuesday, Jun 11. Only 3 left in stock - order soon. (5) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite More Buying Choices $32.80 new (33 offers) DHEA-Mass DHEA 100mg 180 Capsules 2 Bottles by New Y $31.90 $23.90 (13) Free Shipping To USA, Hawaii And Alaska Health & Personal Care: See all 1,207 ite MRM DHEA Nutrition Supplements, 25 mg, 90 Count $13.98 $6.29 ($0.07/count) Add it to a qualifying order within 5 hours to get it by Tuesday, Jun 11 (3) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite More Buying Choices $4.95 new (15 offers) 7-Keto 100 mg 60 vcaps by Now Foods $39.99 $18.60 ($0.31/capsule) Order in the next 7 hours and get it by Tuesday, Jun 11. $17.67 ($0.29/capsule) Subscribe & Save Save more with monthly Subscribe & Save deliveries. More Buying Choices $13.90 new (51 offers) (210) Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite Life Extension DHEA, 25 Mg, Capsules, 100-Count (4) $16.33 $11.25 ($0.11/count) Only 6 left in stock - order soon. Health & Personal Care: See all 1,207 ite More Buying Choices $10.49 new (26 offers) Jarrow Formulas Seven (7)-Keto DHEA (Dehydroepiandr 100mg, 30 Capsules by Jarrow (172) $21.95 $10.49 ($0.35/count) Order in the next 6 hours and get it by Tuesday, Jun 11. Eligible for FREE Super Saver Shipping. Health & Personal Care: See all 1,207 ite $9.97 ($0.33/count) Subscribe & Save Save more with monthly Subscribe & Save deliveries. More Buying Choices $8.30 new (26 offers) Sponsored Products on Amazon (What's this?) DHEA 100 Hormone Balance Support For Men And Women Big Bulk DHEA-Mass DHEA 10 1 Bottle $14.95 $60.23 (1) New You Vitamins New You Vitamins Previous Page " 1 2 3 ... 20 Next Page , - DHEA Supplements Limited Time Sale Buy 2 Get 4 Free. Plus Free Shippi www.puritan.com/DHEA-Supplements Bioidentical Hormones MDs Naturally Restore Your Hormone Loss with Bioidentica www.bodylogicmd.com/Hormones DHEA Supplements 50% Off Sale Direct Manufacturer Free Shipping Qua www.pipingrock.com/dhea Prenatal Vitamins Site Join our Loyalty Program To Save Up To $250 on Pre www.citranatal.com/Join-The-Family !" # $% & ' # Search Feedback Did you find what you were looking for? If you need help or have a question for Customer Service, please visit the Help Section. Search powered by Your Recent History () * $+ Get to Know Us Make Money with Us Let Us Help You Careers Sell on Amazon Your Account Investor Relations Become an Affiliate Shipping Rates & Policies Press Releases Advertise Your Products Amazon Prime Amazon and Our Planet Independently Publish with Us Returns Are Easy Amazon in the Community › See all Manage Your Kindle Help Brazil Canada China France Germany India Italy Japan Spain United Kingdom 6pm AbeBooks AfterSchool.com AmazonFresh AmazonLocal AmazonSupply Business, Industrial & Scientific Supplies AmazonWebServices Scalable Cloud Services Askville Audible BeautyBar.com Book Depository Bookworm.com Casa.com CreateSpace Indie Print Publishing Made Easy Diapers.com Everything But The Baby DPReview Fabric IMDb Junglee.com Kindle Direct Publishing Look.com MYHABIT Private Fashion Designer Sales Shopbop Designer Fashion Brands Soap.com Vine.com Wag.com Warehouse Deals Woot Yoyo.com Zappos Score deals on fashion brands Download Audio Books Sewing, Quilting & Knitting Rare Books & Textbooks Prestige Beauty Delivered Movies, TV & Celebrities Everything to Live Life Green Kids’ Sports, Outdoor & Dance Gear Books With Free Delivery Worldwide Shop Online in India Everything For Your Pet Groceries & More Right To Your Door Books For Children Of All Ages Indie Digital Publishing Made Easy Open-Box Discounts Great Local Deals in Your City Kitchen, Storage & Everything Home Kids' Clothing & Shoes Never Gonna Give You Up A Happy Place To Shop For Toys Shoes & Clothing Community Answers Digital Photography Health, Beauty & Home Essentials Conditions of Use Privacy Notice Interest-Based Ads © 1996-2013, Amazon.com, Inc. or its affiliates ARTHRITIS & RHEUMATISM Vol. 54, No. 8, August 2006, pp 2550–2557 DOI 10.1002/art.21955 © 2006, American College of Rheumatology Mortality in Systemic Lupus Erythematosus S. Bernatsky,1 J.-F. Boivin,2 L. Joseph,3 S. Manzi,4 E. Ginzler,5 D. D. Gladman,6 M. Urowitz,6 P. R. Fortin,6 M. Petri,7 S. Barr,8 C. Gordon,9 S.-C. Bae,10 D. Isenberg,11 A. Zoma,12 C. Aranow,13 M.-A. Dooley,14 O. Nived,15 G. Sturfelt,15 K. Steinsson,16 G. Alarcón,17 J.-L. Senécal,18 M. Zummer,19 J. Hanly,20 S. Ensworth,21 J. Pope,22 S. Edworthy,8 A. Rahman,11 J. Sibley,23 H. El-Gabalawy,24 T. McCarthy,24 Y. St. Pierre,1 A. Clarke,1 and R. Ramsey-Goldman25 Objective. To examine mortality rates in the largest systemic lupus erythematosus (SLE) cohort ever assembled. Methods. Our sample was a multisite international SLE cohort (23 centers, 9,547 patients). Deaths were ascertained by vital statistics registry linkage. Standardized mortality ratio (SMR; ratio of deaths observed to deaths expected) estimates were calculated for all deaths and by cause. The effects of sex, age, SLE duration, race, and calendar-year periods were determined. Results. The overall SMR was 2.4 (95% confidence interval 2.3–2.5). Particularly high mortality was seen for circulatory disease, infections, renal disease, non-Hodgkin’s lymphoma, and lung cancer. The highest SMR estimates were seen in patient groups character- Supported by the Systemic Lupus International Collaborating Clinics (SLICC) investigators group, in collaboration with the Canadian Network for Improved Outcomes in Systemic Lupus (CaNIOS). Dr. Bernatsky’s work was supported by Lupus Manitoba. Dr. Bernatsky is recipient of a Canadian Institutes of Health Research Junior Investigator award, a Lupus Canada Fellowship, and a Canadian Arthritis Network Scholar award. Dr. Joseph is recipient of a Canadian Institutes of Health Research Senior Investigator award. Dr. Fortin’s work was supported by the Arthritis Centre of Excellence at the University of Toronto, Arthritis & Autoimmunity Research Centre, University Health Network, and Lupus Canada. Dr. Fortin is recipient of an Investigator award from The Arthritis Society and the Canadian Institutes of Health Research. Dr. Petri’s work was supported by the NIH (grant R01-AR-437337) and the CRC (grant M01-RR-00052). Dr. Gordon’s work was supported by Lupus UK. Drs. Nived and Sturfelt’s work was supported by the Swedish Medical Research Council (grant 13489). Dr. Steinsson’s work was supported by The Science Fund of Landspitalinn University Hospital. Dr. Senécal’s work was supported by the Canadian Institutes of Health Research (grant MOP-62687). Dr. Clarke’s work was supported by the National Cancer Institute of Canada (grant 013135), The Arthritis Society (grant 99105), the Canadian Institutes of Health Research (grant 100005), and the Singer Family Fund for Lupus Research. Dr. Clarke is recipient of a Canadian Institutes of Health Research Investigator award. Dr. Ramsey-Goldman’s work was supported by the Arthritis Foundation (Clinical Science grant), the Greater Chicago Chapter of the Arthritis Foundation, the NIH (grants AR-02138 and AR-48098), and the Lupus Foundation of Illinois (Chapter grant). 1 S. Bernatsky, MD, PhD, Y. St. Pierre, MSc, A. Clarke, MD, MSc: Montreal General Hospital, Montreal, Quebec, Canada; 2J.-F. Boivin, MD, ScD: McGill University, Montreal, Quebec, Canada; 3L. Joseph, PhD: Montreal General Hospital, and McGill University, Montreal, Quebec, Canada; 4S. Manzi, MD, MPH: University of Pittsburgh School of Medicine and Graduate School of Public Health, Pittsburgh, Pennsylvania; 5E. Ginzler, MD: State University of New York–Downstate Medical Center, Brooklyn; 6D. D. Gladman, MD, M. Urowitz, MD, P. R. Fortin, MD, MPH: Toronto Western Hospital, Toronto, Ontario, Canada; 7M. Petri, MD, MPH: Johns Hopkins University School of Medicine, Baltimore, Maryland; 8S. Barr, MD, MSc, S. Edworthy, MD: University of Calgary, Calgary, Alberta, Canada; 9C. Gordon, MD, FRCPC: University of Birmingham, Birmingham, UK; 10S.-C. Bae, MD, PhD, MPH: Hospital for Rheumatic Diseases, Hanyang University, Seoul, South Korea; 11D. Isenberg, MD, A. Rahman, PhD, MRCP: University College, London, UK; 12A. Zoma, MB, ChB: Hairmyres Hospital, Glasgow, UK; 13C. Aranow, MD: Albert Einstein College of Medicine, Bronx, New York; 14M.-A. Dooley, MD, MPH: University of North Carolina at Chapel Hill; 15O. Nived, MD, PhD, G. Sturfelt, MD, PhD: University Hospital, Lund, Sweden; 16K. Steinsson, MD, PhD: Landspitalinn University Hospital, Reykjavik, Iceland; 17G. Alarcón, MD, MPH: University of Alabama at Birmingham; 18J.-L. Senécal, MD: University of Montreal School of Medicine, and Hôpital Notre-Dame, Montreal, Quebec, Canada; 19M. Zummer, MD: Hôpital Maisonneuve-Rosemont, Montreal, Quebec, Canada; 20J. Hanly, MD: Queen Elizabeth II Health Sciences Centre and Dalhousie University, Halifax, Nova Scotia, Canada; 21S. Ensworth, MD: University of British Columbia, Vancouver, British Columbia, Canada; 22J. Pope, MD, MPH: St. Joseph’s Hospital, University of Western Ontario, London, Ontario, Canada; 23J. Sibley, MD: Royal University Hospital, Saskatoon, Saskatchewan, Canada; 24H. El-Gabalawy, MD, T. McCarthy, MD: University of Manitoba, Winnipeg, Manitoba, Canada; 25R. Ramsey-Goldman, MD, DrPH: Northwestern University, Chicago, Illinois. Drs. Clarke and Ramsey-Goldman contributed equally to this work. Address correspondence and reprint requests to S. Bernatsky, MD, PhD, Division of Clinical Epidemiology, Montreal General Hospital Research Institute, 1650 Cedar Avenue, Room L10-424, Montreal, Quebec H3G 1A4, Canada. Submitted for publication November 24, 2005; accepted in revised form March 30, 2006. 2550 MORTALITY AND LUPUS ized by female sex, younger age, SLE duration <1 year, or black/African American race. There was a dramatic decrease in total SMR estimates across calendar-year periods, which was demonstrable for specific causes including death due to infections and death due to renal disorders. However, the SMR due to circulatory diseases tended to increase slightly from the 1970s to the year 2001. Conclusion. Our data from a very large multicenter international cohort emphasize what has been demonstrated previously in smaller samples. These results highlight the increased mortality rate in SLE patients compared with the general population, and they suggest particular risk associated with female sex, younger age, shorter SLE duration, and black/African American race. The risk for certain types of deaths, primarily related to lupus activity (such as renal disease), has decreased over time, while the risk for deaths due to circulatory disease does not appear to have diminished. Systemic lupus erythematosus (SLE) is a chronic autoimmune disorder that can be severe and life threatening. Death in patients with SLE may be due to lupus activity (when vital organs or systems are involved), to complications of treatment (particularly infections), or to long-term sequelae (such as cardiovascular disease). Although the literature regarding mortality in SLE has been growing, it is still important to consolidate and confirm what previous findings have suggested. Through collaborations with the Systemic Lupus International Collaborating Clinics (SLICC) (1) and the Canadian Network for Improved Outcomes in Systemic Lupus (CaNIOS) investigator groups, we have constructed a unique multicenter international cohort of unprecedented size. We compared the mortality in this SLE cohort with geographically appropriate age-, sex-, and calendar-year period–matched general population mortality rates. Because of the exceptionally large number of patients and person-years of observation in our sample, we provide novel data comparing all-cause and disease-specific relative mortality (in SLE compared with the general population) across groups characterized by sex, age, SLE duration, geographic location, race, and calendar-year period. PATIENTS AND METHODS Study subjects. All adult (age ⬎16 years) patients with definite SLE according to American College of Rheumatology (ACR) (2,3) or clinical criteria were eligible for inclusion. A 2551 patient was considered to have met the clinical criteria if a rheumatologist had confirmed that he/she had a definite diagnosis of SLE whether or not 4 ACR criteria had been met. However, the vast majority of our patients did in fact meet the ACR criteria. The study base encompassed 23 collaborating lupus centers in 7 countries. These centers, listed in Appendix A, were located in North America (Canada and the US), the UK (England and Scotland), Iceland, Sweden, and South Korea. Patients have been followed up in outpatient clinics and/or in the inpatient hospital setting. Although most investigators are based at tertiary academic centers, they actively encourage the enrollment of patients from community physician practices, and thus, the patients represent a spectrum of disease. This cohort has been used to examine cancer incidence in SLE (4). Most of the patients at the participating centers were prospectively enrolled, although some had been retrospectively enrolled after being followed up for a period of time in the clinic at the respective center (see Appendix A). At each center, patients lost to followup were not excluded; in general, patients seen more than once at any of the participating study centers were included in the study. Data collection. Data were collected on each patient’s date of birth, sex, dates of SLE diagnosis and cohort entry, and date of death, if applicable. Probabilistic linkage to vital statistics registries was performed for patients deceased or lost to followup, with the National Death Index in the US cohorts and with regional vital statistics registries for the non-US cohorts. In probabilistic linkage (the current standard for linking with administrative databases), registries are provided with key data on patients (name, date of birth, and unique numeric identifier), and previously validated algorithms are used for selecting matches on the basis of probability of a correct match. For 3 centers (2 in Canada [Winnipeg and Vancouver] and 1 in the UK [London]), linkage of lost-tofollowup patients to vital status registries was not permitted by local ethics approvals; death data at these centers consisted of the information recorded in the clinical records. These 3 centers contributed only a small number of patients (513 of the sample total of 9,547 patients), very few of whom were lost to followup. To be conservative, in the primary analysis, we assumed that any lost-to-followup patients from these centers remained alive until the end of the observation interval; in sensitivity analyses, we repeated the standardized mortality ratio (SMR) calculations using the last date seen for all lost-to-followup patients. Analysis. For death overall and for cause of death, we determined the ratio of the observed number of deaths to the expected number of deaths (the SMR). We examined the most common identified causes of death, calculating event rates and cause-specific SMRs. In secondary analyses, SMRs were estimated for subgroups according to sex, age group, duration of SLE, and geographic location (country). We also estimated SMRs across calendar-year periods (1970–1979, 1980–1989, and 1990–2001). In addition, we generated race-specific SMRs for the US patients only, since the US mortality rates were the only available general population figures that were stratified by race (for whites and blacks/African Americans). To calculate SMRs, the expected numbers of deaths were obtained by multiplying person-years at risk in the cohort by the geographically appropriate age-, sex-, and calendar-year 2552 BERNATSKY ET AL period–matched mortality rates. The person-years for each patient were determined by subtracting the later of 2 entry dates (the beginning of the vital statistics registry observation interval or the first visit to the respective lupus clinic) from the earlier of 2 exit dates (end date of vital statistics registry data or death). The SMRs were calculated by dividing the observed number of deaths by the expected number, and 95% confidence intervals (95% CIs) were calculated using methods described elsewhere (5) for Poisson parameters. Information on deaths by cause was grouped according to International Classification of Diseases, Ninth Revision (ICD-9) codes. In additional secondary analyses, we used the entire sample to perform a multivariate hierarchical regression to determine independent effects of the factors examined (sex, age group, SLE duration, calendar-year period, country) on the SMRs among the patients in the SLE cohort. The hierarchical model allowed for differences in effects from one country to the next. Poisson regression methods were used, with the logarithm of the expected number of deaths serving as the offset variable. The model included an extra variance term to handle slight overdispersion in the data. For each variable in the model, one of the categories was chosen as a reference, and the estimate for each of the other categories is thus interpretable as the relative risk compared with the reference, adjusted for the other factors in the model. Finally, we undertook secondary analyses of the 291 deaths for which lupus was the assigned cause, evaluating stratified rates of lupus-related death for groups characterized by demographics, SLE duration, and calendar-year period. RESULTS The 9,547 patients were observed for a total of 76,948 person-years (average followup 8.1 years). The calendar-year period of observation was 1958–2001, although the majority of the observation interval occurred between 1970 and 2001. Most of the patients (71%) entered into the observation interval within the first 2 years of their SLE diagnosis. As expected, given that SLE is a disease primarily of women, 90% of the patients were female (n ⫽ 8,607). The number of person-years of observation was divided among the age groups ⬍40 years (33,001 person-years), 40–59 years (30,976 person-years), and ⱖ60 years (12,971 personyears). Regarding SLE duration, the person-years of observation were fairly equally divided among the duration groups of 0–4 years (27,037 person-years), 5–9 years (21,931 person-years), and ⱖ10 years (27,980 personyears). Within the observation interval, 1,255 deaths occurred; lupus was the assigned cause of death in 291 cases (3.8 events per 1,000 person-years). The most common types of deaths not directly attributed to SLE were deaths due to circulatory disease (ICD-9 codes 390–459); this includes all types of heart disease, arterial disease, and cerebrovascular events (strokes). Other common types of deaths resulted from neoplasms (ICD-9 codes 140–239), nephritis (ICD-9 codes 580– 589), and infections (ICD-9 codes 001–139; these codes do not include pneumonia [ICD-9 codes 480–486] or the term bacteremia [ICD-9 code 790.7], although they do include the term septicemia [ICD-9 code 038]). Circulatory disease was the identified cause of 313 deaths, for a rate of 4.1 events per 1,000 person-years; cancer was the cause ascribed to 114 deaths, for a rate of 1.5 events per 1,000 person-years; and infection (not including pneumonia) was identified as the cause of 45 deaths, for a rate of 0.6 events per 1,000 person-years. The overall (all-cause) SMR estimate was 2.4 (95% CI 2.3–2.5). For death due to circulatory disease, the SMR was 1.7 (95% CI 1.5–1.9). For the ICD category of infectious causes of death, the SMR was 5.0 (95% CI 3.7–6.7); for pneumonia (which in the ICD codes is classified under respiratory diseases), the SMR was 2.6 (95% CI 1.6–4.1). For cancer overall, the SMR was 0.8 (95% CI 0.6–1.0); in terms of cancer types, for Table 1. Unadjusted SMR estimates for all-cause mortality and for death by cause* Cause of death (ICD-9 code) All deaths Disease of the circulatory system† All disease (390–459) Heart disease (390–429)‡ Stroke (430–459)‡ Malignancy† All neoplasms (140–239) All hematologic cancer (200–208)‡ NHL (200, 201)‡ Lung cancer (162)‡ Infections† Infections (001–139) Pneumonia (480–486)‡ Other† Respiratory, excluding pneumonia (460–479, 487–519) Renal (580–589) Observed Expected 1,255 SMR (95% CI) 526 2.4 (2.3–2.5) 313 126 21 184.3 73.8 19.3 1.7 (1.5–1.9) 1.7 (1.4–2.0) 1.1 (0.7–1.7) 114 15 138 7.2 0.8 (0.6–1.0) 2.1 (1.2–3.4) 8 44 2.8 19.4 2.8 (1.2–5.6) 2.3 (1.6–3.0) 45 19 9.0 7.2 5.0 (3.7–6.7) 2.6 (1.6–4.1) 14 10.4 1.3 (0.8–1.6) 34 4.3 7.9 (5.5–11.0) * Data shown are for 23 participating sites in North America, Europe, Iceland, and Asia, for a total 9,547 patients (76,948 person-years), and for the calendar-year period 1958–2001. SMR ⫽ standardized mortality ratio; ICD-9 ⫽ International Classification of Diseases, Ninth Revision; 95% CI ⫽ 95% confidence interval; NHL ⫽ non-Hodgkin’s lymphoma. † Cause-specific death data on this level of detail were available from all centers except for Iceland (n ⫽ 221), Sweden (n ⫽ 114), Saskatchewan (n ⫽ 306), and Manitoba (n ⫽ 158). ‡ Cause-specific death data on this level of detail were available from all centers except for Iceland (n ⫽ 221), Sweden (n ⫽ 114), Saskatchewan (n ⫽ 306), Manitoba (n ⫽ 158), and Scotland (n ⫽ 1,937). MORTALITY AND LUPUS 2553 Table 2. Unadjusted SMR estimates, stratified by sex, age, and SLE duration* SMR (95% CI) Sex Female Male Age, years ⬍40† 40–59 ⱖ60 SLE duration, years ⬍1 1–4 5–9 10–19 ⱖ20 2.5 (2.3–2.7) 1.9 (1.7–2.2) 10.7 (9.5–11.9) 3.7 (3.3–4) 1.4 (1.3–1.5) 5.4 (4.7–6.3) 2.5 (2.2–2.8) 2.1 (1.9–2.4) 2.0 (1.8–2.3) 2.0 (1.7–2.4) * SMR ⫽ standardized mortality ratio; SLE ⫽ systemic lupus erythematosus; 95% CI ⫽ 95% confidence interval. † Within the age group ⬍40 years, the SMR for very young adults (ages 16–24 years) was particularly high, at 19.2 (95% CI 14.7–24.7). The SMR for adults ages 25–39 years was 8.0 (95% CI 7.0–9.1). non-Hodgkin’s lymphoma (NHL), the SMR was 2.8 (95% CI 1.2–5.6), and, for lung cancer, the SMR was 2.3 (95% CI 1.6–3.0) (Table 1). Patient groups characterized by any of the following: female sex, younger age, or SLE duration ⬍1 year, all had particularly high SMR estimates (Table 2). This phenomenon was evident not only for all-cause mortality, but also for cause-specific mortality estimates, including death due to circulatory diseases, infections, and renal disorders. Within the age group ⬍40 years, the SMR for very young adults (ages 16–24 years) was particularly high, at 19.2 (95% CI 14.7–24.7). Figure 1 presents the unadjusted SMR estimates by calendar-year period. Across calendar-year periods, there was a dramatic decrease in total SMR estimates, which was demonstrable for specific causes, including death due to infections and death due to renal disorders. However, Figure 1. Unadjusted standardized mortality ratio (SMR) estimates, by calendar-year period. Figure 2. Unadjusted standardized mortality ratio (SMR) estimates, stratified by country. Korea represents South Korea. the SMR due to circulatory diseases tended to increase slightly from the 1970s to the year 2001. Unadjusted SMR estimates stratified according to geographic location are shown in Figure 2. Although slight differences may be present, overall the evidence suggests a relatively consistent increased risk of death (⬃2-fold) in SLE patients compared with the general population. However, although Figure 2 indicates that the unadjusted country-specific estimates are largely overlapping, it appears that the magnitude of effect may be somewhat less for certain groups, notably the Swedish. This may in part relate to various factors, including differences in demographic makeup or clinical characteristics of the cohort members; an important factor may also relate to site-specific variations in the enrollment criteria and methods (as outlined in Appendix A). Race-specific SMR estimates for the US patients were as follows: whites 1.4 (95% CI 1.2–1.7), blacks/African Americans 2.6 (95% CI 2.3–2.9). The overall raceadjusted SMR for the US sites was 2.2 (95% CI 2.0–2.4). In sensitivity analyses, when we repeated the SMR calculations using the last date seen for all lost-tofollowup patients, the results were essentially unchanged. Table 3 presents the results of the multivariate hierarchical regression to determine independent effects of the factors examined (sex, age group, SLE duration, calendar-year period of SLE diagnosis, country) on the relative SMR estimates among SLE patients. These adjusted estimates were consistent with the unadjusted results in terms of suggesting independent effects for each variable of interest (female sex, younger age, SLE duration ⬍1 year, calendar-year period) on the risk of death among the SLE patients (relative to the general population). However, the 95% CIs were wider, and in the case of the effects of different calendar-year periods, the estimates did overlap and include the null value. Regarding secondary stratified analyses for rates of death due to SLE, we found that lupus-related death 2554 BERNATSKY ET AL Table 3. Results of adjusted multivariate regression to determine independent effect of variables on SMR estimates* Adjusted SMR (95% CI)† Female sex Age, years ⬍40 40–59 ⱖ60 SLE duration, years ⬍1 1–4 5–9 10–19 ⱖ20 Calendar-year period of SLE diagnosis 1970–1979 1980–1989 1990–2001 Country Canada England Scotland Iceland US Sweden South Korea 1.2 (1.0–1.4) 6.4 (5.5–7.5) 2.6 (2.3–3.0) 1.0 (reference group) 7.7 (5.9–10.2) 3.2 (2.5–4.1) 2.4 (1.8–3.0) 1.8 (1.4–2.2) 1.0 (reference group) 1.3 (1.0–1.5) 1.2 (1.0–1.4) 1.0 (reference group) 1.8 (1.6–2.1) 1.6 (1.2–2.2) 1.3 (1.1–1.5) 1.2 (0.9–1.6) 1.0 (reference group) 0.8 (0.5–1.4) 0.7 (0.3–2.0) * SMR ⫽ standardized mortality ratio; 95% CI ⫽ 95% confidence interval. SLE ⫽ systemic lupus erythematosus. † Variables adjusted concomitantly for all others (sex, age, SLE duration, calendar-year period, and country). rates were a little higher for men (3.6 deaths per 1,000 person-years) than for women (2.7 deaths per 1,000 person-years), although the 95% CIs for these estimates overlapped. With respect to age, very young individuals (ages ⬍25 years) had the highest rate of deaths due to SLE (5.3 deaths per 1,000 person-years, 95% CI 3.7–7.5) compared with other age groups; the estimates across other age groups (for those ages ⱖ25 years) were all very similar, with an average of 2.5 deaths due to SLE per 1,000 person-years (95% CI 2.2–3.5). There were generally very few differences regarding lupus-related death rates for groups characterized by SLE duration, and no trend over calendar time was observed for deaths due to lupus. DISCUSSION The primary value of this work is that it formally presents the increased risk of mortality in SLE compared with that in the general population, and it examines the particular risk in groups of patients characterized by demographic and other factors. The increased risk of mortality in SLE is by no means a new phenomenon; on the contrary, it has been a point of concern for some years. However, our results do emphasize what has been demonstrated previously in smaller samples. In addition, because of the large numbers of patients and person-years of observation in the multicenter cohort, we were able to provide data comparing all-cause and disease-specific relative mortality (in SLE patients compared with the general population) across groups characterized by age, sex, SLE duration, calendar-year period, geographic location, and race. In terms of the slightly higher total SMR estimates suggested for females, some prior work by others has suggested greater mortality in male than in female SLE patients (6,7). However, this previous work did not calculate mortality rates relative to the general population. The longevity of males is generally lower than that of females; thus, when comparing the effect of sex on mortality in SLE patients, it is preferable to use a parameter such as the SMR. Similarly, the SMR provides a clearer understanding of which age group of SLE patients has the greatest increased risk (compared with the general population counterparts), since mortality rates in the general population increase with age. Although the highest SMR estimates for our sample were seen within the first year, there was evidence that death rates in SLE patients are much higher than those in the general population throughout the course of SLE, even up to 20 years of SLE duration. Overall, across countries, we noted a relatively consistent increased risk of death in SLE patients compared with the general population. Slight regional differences were present (Figure 2); adjusting for sex, age, SLE duration, and calendar-year period appeared to remove most of this variation (Table 3). Small residual regional differences may be due in part to differences in cohort assembly (see details in Appendix A) and may reflect variations in other factors, including disease characteristics (and severity), medication exposures, comorbidity, and racial mix. We note that the cohorts from countries with the lowest SMR point estimates (Sweden, Iceland, and Scotland) were population based. This may indicate the potential role of sample recruitment in the findings. Among SLE patients in the US, the question of why blacks/African Americans have a higher SMR than whites is an interesting one; previous work has also shown this phenomenon (8,9). Since the results of other studies have suggested worse renal involvement and outcomes in black/African American (and also black Caribbean) patients (10–13), a reasonable hypothesis is that the higher SMR estimate in blacks is driven in part by SLE severity and comorbidity. Another related factor may be economic status, since poverty has been sug- MORTALITY AND LUPUS gested to contribute to increased mortality in SLE (6,14). Previous work has suggested high mortality in Asian SLE patients as well (15), but estimates relative to the general population are lacking. We are unable to comment about racial groups other than white and black/African American patients in the US. Early work by Urowitz et al (16,17) first drew attention to the importance of mortality due to circulatory disease in SLE, particularly late in the disease course. As their work and that of others has suggested, circulatory disease (related to the heart, arteries, and cerebrovascular events) is a common cause of death in SLE (9,18,19). Previous work by Manzi et al (20) has shown a very high incidence of cardiac events (specifically, myocardial infarction and angina) in SLE patients compared with the general population. Our data substantiate an increased risk of death due to circulatory causes in SLE patients compared with the general population. We identified an increased risk of death due to specific cancers, including hematologic malignancies (particularly NHL) and lung cancer. This is of interest given recent data showing a heightened incidence of these types of cancer in SLE (4), and it is not concordant with surveillance bias as the explanation for the observed association between cancer and SLE. An increased risk of death was also estimated for infections and renal disease. It is well known that infections, often attributed to the use of immunosuppressant medications, are a frequent cause of death in SLE (9,18,21). An increase in the rate of death due to renal disease reflects the potential seriousness of nephritis in SLE (9,22). Our work shows a dramatic 60% decrease over time in the standardized all-cause mortality rates, from 1970–1979 (SMR 4.9) to 1990–2001 (SMR 2.0). Work in several SLE cohorts over the last 3 decades has suggested an improvement in survival, at least early in the course of SLE (17,23–25). Results of our work are consistent with increased survival over time, in keeping with previous findings, although we note that the use of different methodologies may produce somewhat different estimates from one study to the next. It is important to keep in mind that, since the SMR estimate compares the observed number of deaths in SLE patients with the expected number of deaths in the general population, the decrease over the last 2 decades probably reflects improvements specific to the excess mortality in SLE rather than a general increase in population longevity. A decrease in deaths due to infections over time may be due to the evolution of strategies to limit the incidence of infections when immunomodulators are used (for 2555 example, by limiting cumulative exposure). An alternative explanation is that in more recent eras, there is more effective recognition and treatment of infectious complications. It seems clear that certain types of deaths, primarily related to lupus activity (such as renal disease), have decreased over time. However, the trend for circulatory disease shows no such decline, a finding suggested as well by Bjornadal et al (19). This may reflect in part the complex nature of cardiovascular disease in SLE. Classic atherosclerosis risk factors, such as hypertension and hypercholesterolemia, do play a role, although recent work has suggested that additional risk is conferred by some disease-related characteristics, such as SLE duration and, perhaps, severity (26). However, other elements, such as medication exposures, may also alter atherosclerosis risk in SLE. Limitations of our study should be considered. We cannot be certain that the causes of death in our SLE patients were identified correctly, since we relied primarily on death registry linkage results. However, important biases in our estimates would only arise if misclassification occurred differentially between SLE patients versus the general population. A fairly large number of deaths were ascribed to SLE itself; it is possible that the primary cause of death was actually another condition (e.g., cardiovascular disease or infection), but the patient’s preexisting diagnosis of SLE may have led to this being listed as the cause of death. This might lead to an underestimation of some of the causespecific SMR estimates; however, the data on causes of death recorded for SLE patients do not suggest that this effect is likely (27). Although we believe that our cohort is probably representative of the general population of lupus patients, it is not a random sample. Therefore, claims of representativeness must be made very cautiously, since unobserved selection biases may certainly operate. Most investigators involved in our multicenter cohort are based at tertiary academic centers, although they actively encourage the enrollment of patients from community physician practices. The patients enrolled do represent a spectrum of disease severity, but sicker patients may indeed be overrepresented. We do note that our findings are consistent with the results reported by Bjornadal et al (19) in their assessment of a population-based cohort, which was assembled using administrative databases (which are not without their own sources of bias and error). In conclusion, the data from our very large multicenter international cohort emphasize what has 2556 BERNATSKY ET AL been demonstrated previously in smaller samples. The results highlight the increased mortality rate in SLE patients compared with the general population. This increased mortality is highest in patient groups characterized by female sex, younger age, or SLE duration ⬍1 year, although an increased risk of mortality in SLE patients compared with the general population was generally seen across all demographic groups. The country-specific estimates also showed a relatively consistent increased risk of death in SLE patients compared with the general population. There was evidence of a striking increase in mortality among black/African American SLE patients in the US, although a smaller increase in mortality was also present for white SLE patients in the US. The decrease in SMR estimates over time for our lupus cohort is encouraging, but the residual increased risk of death in SLE suggests that continued efforts should focus on developing better means of preventing and treating the sequelae of SLE as well as other comorbidity, particularly cardiovascular disease. ACKNOWLEDGMENTS Angela Allen, Natalie Gonzalez, and Katie Arrigo functioned as research co-coordinators responsible for all US sites. We wish to thank the following physicians for their significant assistance in providing access to patients and collecting data: Simon Bowman, Linda Lee, Moon-Ho Leung, Ibraheem Nahr, and Martha Sanchez. Stephanie Heaton, RN, assisted with data collection for the Birmingham, UK, lupus cohort. The National Death Index and regional or national vital statistics registries provided vital status information on deceased and lost-to-followup patients. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. REFERENCES 1. Isenberg D, Gladman D. The Systemic Lupus International Collaborating Clinics Group: origins and outcomes. Lupus 2001;10: 375–7. 2. Hochberg MC. Updating the American College of Rheumatology revised criteria for the classification of systemic lupus erythematosus [letter]. Arthritis Rheum 1997;40:1725. 3. Tan EM, Cohen AS, Fries JF, Masi AT, McShane DJ, Rothfield NF. The 1982 revised criteria for the classification of systemic lupus erythematosus. Arthritis Rheum 1982;25:1271–7. 4. Bernatsky S, Boivin JF, Joseph L, Rajan R, Zoma A, Manzi S, et al. An international cohort study of cancer in systemic lupus erythematosus. Arthritis Rheum 2005;52:1481–90. 5. Breslow ND. Statistical methods in cancer research. The design and analysis of cohort studies. Lyon: WHO International Agency for Research on Cancer; 1987. p. 302–4. 6. Ward MM, Pyun E, Studenski S. Long-term survival in systemic lupus erythematosus: patient characteristics associated with poorer outcomes. Arthritis Rheum 1995;38:274–83. 7. Manger K, Manger B, Repp R, Geisselbrecht M, Geiger A, Pfahlberg A, et al. Definition of risk factors for death, end stage renal disease, and thromboembolic events in a monocentric cohort 20. 21. 22. 23. 24. 25. of 338 patients with systemic lupus erythematosus. Ann Rheum Dis 2002;61:1065–70. Reveille JD, Bartolucci A, Alarcon GS. Prognosis in systemic lupus erythematosus: negative impact of increasing age at onset, black race, and thrombocytopenia, as well as causes of death. Arthritis Rheum 1990;33:37–48. Mody G, Parag K, Nathoo B, Pudifin D, Duursma J, Seedat Y. High mortality with systemic lupus erythematosus in hospitalized African blacks. Br J Rheumatol 1994;33:1151–3. Ginzler EM, Diamond HS, Weiner M, Schlesinger M, Fries JF, Wasner C, et al. A multicenter study of outcome in systemic lupus erythematosus. I. Entry variables as predictors of prognosis. Arthritis Rheum 1982;25:601–11. Hopkinson N, Jenkinson C, Muir K, Doherty M, Powell R. Racial group, socioeconomic status, and the development of persistent proteinuria in systemic lupus erythematosus. Ann Rheum Dis 2000;59:116–9. Walsh SJ, Algert C, Rothfield NF. Racial aspects of comorbidity in systemic lupus erythematosus. Arthritis Care Res 1996;9:509–16. Bastian H, Roseman J, McGwin G, Alarcon G, Friedman A, Fessler B, et al. Systemic lupus erythematosus in three ethnic groups. XII. Risk factors for lupus nephritis after diagnosis. Lupus 2002;11:152–60. Alarcon GS, McGwin GJ Jr, Bastian HM, Roseman J, Lisse J, Fessler BJ, et al, and the LUMINA Study Group. Systemic lupus erythematosus in three ethnic groups. VIII. Predictors of early mortality in the LUMINA cohort. Arthritis Rheum 2001;45: 191–202. Samanta A, Feehally J, Roy S, Nichol F, Sheldon P, Walls J. High prevalence of systemic disease and mortality in Asian subjects with systemic lupus erythematosus. Ann Rheum Dis 1991;50:490–2. Urowitz M, Bookman A, Koehler B, Gordon D, Smythe H, Ogryzlo M. The bimodal mortality pattern of systemic lupus erythematosus. Am J Med 1976;60:221–5. Urowitz M, Gladman D, Abu-shakra M, Farewell V. Mortality studies in systemic lupus erythematosus. Results from a single center. III. Improved survival over 24 years. J Rheumatol 1997;24: 1061–5. Abu-shakra M, Urowitz M, Gladman D, Gough J. Mortality studies in systemic lupus erythematosus. Results from a single center. I. Causes of death. J Rheumatol 1995;22:1259–64. Bjornadal L, Yin L, Granath F, Klareskog L, Ekbom A. Cardiovascular disease a hazard despite improved prognosis in patients with systemic lupus erythematosus: results from a Swedish population based study. J Rheumatol 2004;31:713–19. Manzi S, Meilahn E, Rairie J, Conte C, Medsger T, JansenMcWilliams L, et al. Age-specific incidence rates of myocardial infarction and angina in women with systemic lupus erythematosus: comparison with the Framingham Study. Am J Epidemiol 1997;145:408–15. Cervera R, Khamashta M, Font J, Sebastiani G, Gil A, Lavilla P, et al, the European Working Party on Systemic Lupus Erythematosus. Morbidity and mortality in systemic lupus erythematosus during a 5-year period: a multicenter prospective study of 1,000 patients. Medicine (Baltimore) 1999;78:167–75. Moss K, Ioannou Y, Sultan S, Haq I, Isenberg D. Outcome of a cohort of 300 patients with systemic lupus erythematosus attending a dedicated clinic for over two decades. Ann Rheum Dis 2002;61:409–413. Bongu A, Chang E, Ramsey-Goldman R. Can morbidity and mortality of SLE be improved? Best Pract Res Clin Rheumatol 2002;16:313–32. Stahl-Hallengren C, Jonsen A, Nived O, Sturfelt G. Incidence studies of systemic lupus erythematosus in Southern Sweden: increasing age, decreasing frequency of renal manifestations and good prognosis. J Rheumatol 2000;27:685–91. Uramoto KM, Michet CJ Jr, Thumboo J, Sunku J, O’Fallon WM, MORTALITY AND LUPUS Gabriel SE. Trends in the incidence and mortality of systemic lupus erythematosus, 1950–1992. Arthritis Rheum 1999;42:46–50. 26. Roman MJ, Shanker BA, Davis A, Lockshin MD, Sammaritano L, Simantov R, et al. Prevalence and correlates of accelerated atherosclerosis in systemic lupus erythematosus. N Engl J Med 2003;349:2399–406. 27. Ward MM. Education level and mortality in systemic lupus erythematosus (SLE): evidence of underascertainment of deaths due to SLE in ethnic minorities with low education levels. Arthritis Rheum 2004;51:616–24. 2557 APPENDIX A: INTERNATIONAL SYSTEMIC LUPUS ERYTHEMATOSUS COHORT, PARTICIPATING CENTERS Country (no. of patients)* North America Canada (2,688)† US (3,558)† UK England (712)† Scotland (1,937)# Other Sweden (114)† Iceland (221)† South Korea (317)† Total ⫽ 9,547 Centers Calgary, Alberta‡; Halifax, Nova Scotia‡; London, Ontario§; Montreal, Quebec (Hôpital Maisonneuve-Rosemont§, Montreal General Hospital‡, Hôpital Notre-Dame¶); Saskatoon, Saskatchewan‡; Toronto, Ontario‡; Vancouver, British Columbia§; Winnipeg, Manitoba (Health Science Centre and Manitoba Clinic)§ Baltimore, Maryland¶; Birmingham, Alabama‡; Chapel Hill, North Carolina¶; Chicago, Illinois¶; New York, New York (Albert Einstein College of Medicine, Bronx§; State University of New York–Downstate Medical Center, Brooklyn‡); Pittsburgh, Pennsylvania¶ Birmingham‡; London‡ Lanarkshire§ Lund‡ Reykjavik¶ Seoul¶ * The number of patients at each center corresponds to the number of patients present during the time that vital status registry data were available. † At least 95% of cohort members met 4 of the American College of Rheumatology (ACR) diagnostic criteria for systemic lupus erythematosus (SLE) (2,3); patients diagnosed clinically as having SLE but meeting fewer than 4 ACR criteria are not excluded. ‡ Prospective assembly. § Retrospective assembly. ¶ Retrospective and prospective assembly. # Any hospital discharge diagnosis of SLE, primary or nonprimary. Cohort entry date is first discharge date with SLE as a diagnosis. Downloaded from ard.bmj.com on June 10, 2013 - Published by group.bmj.com 58 CONCISE REPORT Suicide attempts in patients with systemic lupus erythematosus F B Karassa, M Magliano, D A Isenberg ............................................................................................................................. Ann Rheum Dis 2003;62:58–60 Background: Suicide and suicide attempts, although well recognised in patients with systemic lupus erythematosus (SLE), have been commented on relatively little. Objective: To obtain a better understanding of the reasons for suicidal behaviour in patients with SLE. Methods: The records of 300 patients with SLE were reviewed to identify completed or attempted suicides. Results: Five patients made seven attempts at suicide over a 20 year follow up period; one of them was fatal. All of those attempting suicide had a history of neuropsychiatric SLE (NPSLE) presenting with depression and they made the attempts soon after the onset of NPSLE (median time 12.5 months). Two patients had appreciable disease activity at the time of the suicide attempt. Lymphopenia was present in five suicide attempts. Anti-SSA/Ro antibodies were detected in three patients, none of whom had anti-SSB/La. All patients apart from one responded to treatment for depression; the remaining female patient made two subsequent suicide attempts, with a fatal outcome despite intensive treatment. Conclusion: Greater awareness of the risk of suicide in patients with psychiatric manifestations of SLE may help to reduce the incidence of this potentially fatal phenomenon. A suicide attempt is an act of self inflicted harm accompanied by explicit or implicit intent to cause death. Although only one in eight to 10 people attempting suicide succeed, suicide remains a major cause of death. More than 90% of suicide victims are psychiatrically ill and 45–77% of them have a mood disorder at the time of death.1 Chronic physical illness is an important risk factor for suicide. Systemic lupus erythematosus is one with a risk quoted to be fivefold higher than expected.2 Many factors may contribute to this occurrence: pathophysiological changes in the brain resulting from the underlying disease (NPSLE), depression related to the variable course and the unpredictable nature of the disease, and corticosteroids may rarely induce mental disturbance. METHODS We reviewed the medical records of the first 300 patients with SLE attending our lupus clinic over a 20 year period to identify attempted and completed suicides. Our aim was to identify any potential risk factors for the suicide in these patients related to their underlying condition. All patients fulfilled the American College of Rheumatology (ACR) 1982 revised criteria for the classification of SLE.3 Demographic, clinical, and laboratory data as well as current and previous treatments were recorded from patients’ charts. Disease activity was evaluated using the British Isles Lupus Assessment Group (BILAG) index (version 3).4 Neuropsychiatric lupus (NPSLE) was defined according to the ACR definitions.5 Table 1 lists the details. www.annrheumdis.com RESULTS Since 1979 five patients with SLE (2%), four women and one man, made seven suicide attempts, although only one was fatal. The mean age of the patients at the time of the suicide attempt was 41 (SD 8.69) years and median disease duration 2.5 years (range 1–11 years). All patients had a history of depression at the time of the suicide attempt. None of them were inpatients at the time of the attempt. Only one patient had expressed prior suicidal intent and was found to have left a suicide note (patient 1); none of the others had, as far as we could ascertain, expressed suicidal thoughts or gave warnings. After two attempts patients were unable to describe clearly how they became vulnerable to suicidal impulses; however, four patients expressed difficulties in coming to terms with the diagnosis of SLE. One patient (patient 3) reported sleeping difficulties and irritability in the year before the attempt at suicide. Psychological factors such as unemployment, being separated, and being isolated in the community due to the chronic illness were present in all patients. Ingestion was the only form of suicidal behaviour and involved analgesic drugs regularly used by patients in six cases; the other ingestion was of turpentine fluid. All patients were reviewed by a psychiatrist and received treatment for depression. All of the patients had evidence of NPSLE before the time of attempted suicide. Patients 2–5 all had depression with or without an anxiety state at the time of the attempt. Patient 1 had a complicated history and two psychiatrists who were seeing her gave divergent opinions. On balance we thought it reasonable to regard her as being depressed at the time of her first suicide attempt but this was not as clear cut at the time of the second attempt. She had progressive cognitive dysfunction as manifested by a decline in verbal IQ and memory impairment, with a profound effect on the patient’s mood and feeling of hopelessness. Median time from the onset of involvement of the central nervous system (CNS) to the attempt at suicide was 12.5 months (range 3–27 months). In two out of three patients who were evaluated with brain MRI multiple white matter lesions were found. Two patients had appreciable disease activity at the time of the attempt. Lymphopenia was present in six instances, in two the lymphocyte count was less than 0.7×109/l. Anti SSA/Ro antibodies were detected in three patients whereas none of them had anti-SSB/La. After the suicide attempt patient 1 was treated with pulses of cyclophosphamide and methylprednisolone (the first cycle was followed by the suicide attempt), patient 4 received three pulses of methylprednisolone and oral prednisolone was increased in patients 2, 3, and 5 (by a mean of ............................................................. Abbreviations: ACR, American College of Rheumatology; BILAG, British Isles Lupus Assessment Group; CNS, central nervous system; NPSLE, neuropsychiatric systemic lupus erythematosus; SLE, systemic lupus erythematosus Downloaded from ard.bmj.com on June 10, 2013 - Published by group.bmj.com 53/F/I 29/F/W 40/F/B 44/M/W *The BILAG index is scored as follows: A, disease of sufficient activity to warrant disease modifying treatment with high dose steroids or immunosupression; B, disease of less activity than in A, requiring only symptomatic treatment, antimalarial drugs, or low dose steroids; C, stable mild disease; D, system was previously affected but currently inactive; E, system was never involved; †no data available on patient 1 at the time of the last suicide attempt; ‡DNA: normal range <50 units/ml; §C3: normal values 0.75–1.75 mg/ml; B, black; I, Indian; W, white; M, male; F, female; CNS, central nervous system; CVS, cardiovascular system. 2.2 1.1 – 0.3 1.2 1.2 0.6 3 5 – 14 43 – 9 0.87 0.9 – 0.93 1.16 1.2 1.2 260 262 – 1800 68 170 10 8 6 – 13 3 13 7 D C – B C C C E E – E D E E C C – D E D E D D – C B D E D D – B C C B B D – B D A B 1 1 1 2 3 4 5 39/F/W 5/99 9/00 4/01† 8/89 10/95 12/99 7/99 B B – B C C C C C – D D C D Musculoskeletal CNS Mucocutaneous BILAG index for each organ system General manifestations Date of suicide Age/sex/ ethnic group Patient No Table 1 BILAG index (version 3) for each organ system on suicidal attempts* CVS/ respiratory Vasculitis Renal Haematological Total score DNA‡ C3§ ESR Lymphocytes (109/l) Suicide attempts in patients with systemic lupus erythematosus 59 20 mg/day). Patient 1 continued to deteriorate cognitively despite the treatment with cyclophosphamide and anti-CD20 monoclonal antibody directed at NPSLE manifestations. This patient made two subsequent attempts of suicide, the last one being fatal. DISCUSSION Patients with SLE are at almost five times greater risk for suicide than expected.2 In our cohort of patients 2% had a documented history of attempted suicide. Could we have missed more suicide attempts? We cannot completely exclude this possibility but consider it unlikely as the BILAG form that we complete at every patient assessment specifically records depression and any worsening of this feature would have led to further enquiries about suicide attempts. As a control we reviewed the notes of 140 patients with primary Sjogren’s syndrome followed up by us from 1988 to 2001. To date none have attempted suicide. All our patients who made attempts at suicide had been diagnosed with depression at some time before the attempt. Psychiatric dysfunction represents a common NPSLE manifestation and may range from mild affective disorders to severe psychosis.6 7 Our patients with NPSLE made suicide attempts within two years of the onset of involvement of the CNS; all but one had favourable outcomes with more intense treatment. Similarly, five out of seven previously reported suicidal patients with SLE presented either with depression or schizophrenia; all three survivors had a favourable response to increased dose of steroids or immunosupressant drugs.8 To our knowledge none of our 300 patients have attempted suicide after treatment with large amounts of corticosteroids. Insomnia was a feature in all patients before the suicide attempts, and the presence of hypocomplementaemia and reducing dose of steroids possibly resulting in suboptimal control of the disease activity were implied as important suicidal risk factors.8 Futrell et al described six suicide attempts in 31 patients with NPSLE with major behavioural changes.9 Suicidal patients with SLE coupled with depression and aggressive behaviour have also been reported.10 11 Although a link between lupus psychosis and antiribosomal P antibodies has been claimed,12 assays to detect these antibodies are not readily available for identifying patients at risk in routine clinical practice. Interestingly anti-SSA/Ro was detected in three of our patients; this is twice the 30% prevalence of these antibodies in our patients with SLE overall (relative risk=3.66; D A Isenberg, unpublished observations). None of them had concomitant anti-SSB/La antibodies. The relevance of this finding is unknown. Patients with SLE are at greater risk of suicide, and vigilance to identify and treat symptoms and signs of depression is crucial. Although involvement of the CNS creates an additional risk we should not underestimate the importance of the psychosocial factors that coping with life threatening and unpredictable illness creates. ..................... Authors’ affiliations F B Karassa, M Magliano, D A Isenberg, Centre for Rheumatology, The Middlesex Hospital, University College London, UK Correspondence to: Professor D A Isenberg, The Middlesex Hospital University College, London, Arthur Stanley House, 40–50 Tottenham Street, London W1T 4NJ, UK; [email protected] Accepted 7 June 2002 REFERENCES 1 Ghosh TB, Victor BS. Suicide. In: Hales RE, Yudofsky SC, Talbott JA, eds. Textbook of Psychiatry. 3rd ed. Washington, DC: The American Psychiatric Press, 1999:1383–400. 2 Harris EC, Barraclough BM. Suicide as an outcome for medical disorders. Medicine 1994;73:281–96. 3 Tan EM, Cohen AS, Fries JF, Masi AT, McShane DJ, Rothfield NF, et al. The 1982 revised criteria for the classification of systemic lupus erythematosus. Arthritis Rheum 1982;25:1271–7. www.annrheumdis.com Downloaded from ard.bmj.com on June 10, 2013 - Published by group.bmj.com 60 Karassa, Magliano, Isenberg 4 Hay EM, Bacon PA, Gordon C, Isenberg DA, Maddison P, Snaith ML, et al. The BILAG index: a reliable and valid instrument for measuring clinical disease activity in systemic lupus erythematosus. Q J Med 1993;86:447–58. 5 ACR Ad Hoc committee on neuropsychiatric lupus nomenclature case definitions for neuropsychiatric syndrome in systemic lupus erythematosus. Arthritis Rheum 1999;42:559–608. 6 West SG. Neuropsychiatric lupus. Rheum Dis Clin North Am 1994;20:129–58. 7 Karassa FB, Ioannidis JP, Boki KA, Touloumi G, Argyropoulou MI, Strigaris KA, et al. Predictors of clinical outcome and radiologic progression in patients with neuropsychiatric manifestations of systemic lupus erythematosus. Am J Med 2000;109:628–34. 8 Matsukawa Y, Sawada S, Hayama T, Usui H, Horie T. Suicide in patients with systemic lupus erythematosus: a clinical analysis of seven suicidal patients. Lupus 1994;3:31–35. 9 Futrell N, Schultz LR, Millikan C. Central nervous system disease in patients with systemic lupus erythematosus. Neurology 1992;42:1649–57. 10 Goodwin JM, Goodwin JS, Kellner R. Psychiatric symptoms in disliked medical patients. JAMA 1979;241:1117–20. 11 MacNeil A, Grennan DM, Ward D, Dick WC. Psychiatric problems in systemic lupus erythematosus. Br J Psychiatry 1976;128:442–5. 12 Sterling G, West MD. Neuropsychiatric lupus. Rheum Dis Clin North Am 1994;20:129–56. Readers' favourite Top 10 Click on the Top 10 button on the homepage to see which are the best read articles each month '' '' www.annrheumdis.com www.annrheumdis.com Downloaded from ard.bmj.com on June 10, 2013 - Published by group.bmj.com Suicide attempts in patients with systemic lupus erythematosus F B Karassa, M Magliano and D A Isenberg Ann Rheum Dis 2003 62: 58-60 doi: 10.1136/ard.62.1.58 Updated information and services can be found at: http://ard.bmj.com/content/62/1/58.full.html These include: References This article cites 9 articles, 3 of which can be accessed free at: http://ard.bmj.com/content/62/1/58.full.html#ref-list-1 Article cited in: http://ard.bmj.com/content/62/1/58.full.html#related-urls Email alerting service Topic Collections Receive free email alerts when new articles cite this article. Sign up in the box at the top right corner of the online article. Articles on similar topics can be found in the following collections Connective tissue disease (3176 articles) Immunology (including allergy) (3756 articles) Systemic lupus erythematosus (446 articles) Notes To request permissions go to: http://group.bmj.com/group/rights-licensing/permissions To order reprints go to: http://journals.bmj.com/cgi/reprintform To subscribe to BMJ go to: http://group.bmj.com/subscribe/ Consumer Health Information www.fda.gov/consumer Beware of Fraudulent ‘Dietary Supplements’ F ederal regulators continue to warn consumers about tainted, dangerous products that are marketed as dietary supplements. These fraudulent products can cause serious injury or even death. The Food and Drug Administration (FDA) has found nearly 300 fraudulent products—promoted mainly for weight loss, sexual enhancement, and bodybuilding—that contain hidden or deceptively labeled ingredients, such as • t he ac t ive ing redients in F DAapproved drugs or their analogs (closely-related drugs) • other compounds, such as novel synthetic steroids, that do not qualify as dietary ingredients “These products are masquerading as dietary supplements—they may look like dietar y supplements but they are not legal dietary supplements,” says Michael Levy, director of FDA’s Division of New Drugs and Labeling Compliance. “Some of these products contain hidden prescription ingredients at levels much higher than those found in an approved drug product and are dangerous.” FDA has received numerous reports of harm associated with the use of these products, including stroke, liver injury, kidney failure, heart palpitations, and death. Advice for Consumers “We need consumers to be aware of these dangerous products and to learn how to identif y and avoid them,” says Lev y. Consumers should look for potential warning signs of tainted products marketed as dietary supplements, such as • products claiming to be alternatives to FDA-approved drugs or to have effects similar to prescription drugs • products claiming to be a legal alternative to anabolic steroids • products that are marketed primarily in a foreign language or those that are marketed through mass e-mails • sexual enhancement products promising rapid effects, such as working in minutes to hours, or long-lasting effects, such as working for 24 to 72 hours • product labels warning that you may test positive in performance enhancement drug tests Generally, if you are using or consid- 1 / FDA Consumer Health Infor mat ion / U. S. Food and Drug Administrat ion ering using any product marketed as a dietary supplement, FDA suggests that you • c heck with your health care professional or a registered dietician about any nutrients you may need in addition to your regular diet • ask your health care professional for help distinguishing between reliable and questionable information • ask yourself if it sounds too good to be true ° B e cautious if the claims for the product seem exaggerated or unrealistic. ° Watch out for extreme claims—for example, “quick and effective,” “cure-all,” “can treat or cure diseases,” or “totally safe.” ° Be skeptical about anecdotal information from personal “testimonials” about incredible benefits or results obtained from using a product. M A R C H 2 0 11 Consumer Health Information www.fda.gov/consumer Keep Up-to-Date on Tainted Products Get the latest news on tainted products by using FDA’s “widget” (www.fda.gov/Drugs/ResourcesForYou/Consumers/BuyingUsingMedicineSafely/MedicationHealthFraud/ucm242603.htm) and “RSS feed” (www.fda.gov/AboutFDA/ContactFDA/StayInformed/RSSFeeds/TDS/rss.xml). Both of these online tools contain alerts, health information, and FDA actions on tainted products marketed as dietary supplements. A widget is a portable application that displays featured content directly on a web page. Bloggers or owners of websites can embed this content into their sites. Once FDA’s widget is added, there’s no technical maintenance—FDA will automatically provide updates to content displayed on the widget. The RSS (Really Simple Syndication) feed, like the widget, includes updated content published on FDA’s website. RSS is usually used for news and blog websites and requires an RSS news reader (a special software program) to pick up the content in the feed. Organizations and bloggers can subscribe to the RSS feed to receive updates automatically and put together their own customized lists of news and information. ° S ee FDA’s website (www.fda.gov/ weightlossfraud) to help recognize fraudulent weight-loss products and claims. If you suspect a dietary supplement sold online may be illegal, FDA urges you to report that information online (www.fda.gov/Safety/ReportaProblem/ ucm059315.htm). In addition, you or your health care professional can also report an illness or injury you believe to be related to the use of a dietary supplement by phone at 1-800-FDA-1088 or online (www.fda.gov/Safety/ReportaProblem/ucm053074.htm). Dietary Supplements and FDA Dietary supplements, in general, are not FDA-approved. Under the law (Dietary Supplement Health and Education Act of 1994), dietary supplement firms do not need FDA approval prior to marketing their products. It is the company’s responsibility to make sure its products are safe and that any claims are true. Just because you see a supplement product on a store shelf does NOT mean it is safe or effective. When safety issues are suspected, FDA must inves- tigate and, when warranted, take steps to have the product removed from the market. However, it is much easier for a firm to get a product on the market than it is for FDA to take a product off the market. FDA has worked with industry to recall numerous products with potentially harmful ingredients including • more than 40 products marketed for weight loss • more than 70 products marketed for sexual enhancement • more than 80 products marketed for body building ucts on the market to identify those that contain potentially harmful hidden ingredients. Consumers must also be aware of these dangerous products and learn how to identify and avoid them using the warning signs described above. Find this and other Consumer Updates at www.fda.gov/ ForConsumers/ConsumerUpdates Sign up for free e-mail subscriptions at www.fda.gov/ consumer/consumerenews.html FDA last alerted the public to tainted products in December 2010, and will continue to issue consumer alerts and press announcements about these products. The agency has issued warning letters, seized products, and conducted criminal prosecutions. In December 2010, a woman pleaded guilty to an 18-count indictment charging her with the illegal importation and distribution of more than four million diet pills that contained a controlled substance, unapproved drugs, and a possible cancer-causing agent. Remember, FDA cannot test all prod- 2 / FDA Consumer Health Infor mat ion / U. S. Food and Drug Administrat ion M A R C H 2 0 11 ARTHRITIS & RHEUMATISM Vol. 46, No. 11, November 2002, pp 2924–2927 DOI 10.1002/art.10615 © 2002, American College of Rheumatology Dehydroepiandrosterone Treatment of Women With Mild-to-Moderate Systemic Lupus Erythematosus A Multicenter Randomized, Double-Blind, Placebo-Controlled Trial Deh-Ming Chang,1 Joung-Liang Lan,2 Hsiao-Yi Lin,3 and Shue-Fen Luo4 cant between the two groups (DHEA ⴚ5.5 versus placebo 5.4; P ⴝ 0.005). The number of patients with serious adverse events, most of which were related to SLE flare, was significantly lower in DHEA-treated patients compared with placebo-treated patients (P ⴝ 0.010). Expected hormonal effects, including increased testosterone levels and increased incidence of acne, were observed. No life-threatening reactions or serious safety issues were identified during this study. Conclusion. The overall results confirm that DHEA treatment was well-tolerated, significantly reduced the number of SLE flares, and improved patient’s global assessment of disease activity. Objective. To evaluate the efficacy and tolerability of dehydroepiandrosterone (DHEA) at a dosage of 200 mg/day in adult women with active systemic lupus erythematosus (SLE). Methods. In a multicenter randomized, doubleblind, placebo-controlled trial, 120 adult women with active SLE received oral DHEA (200 mg/day; n ⴝ 61) or placebo (n ⴝ 59) for 24 weeks. The primary end point was the mean change from baseline in the Systemic Lupus Activity Measure (SLAM) score at 24 weeks of therapy. Secondary end points included time to first flare, change in SLE Disease Activity Index (SLEDAI) score, and physician’s and patient’s global assessment scores at week 24. Results. The two groups were well balanced for baseline characteristics. Mean reductions in SLAM scores from baseline were similar and were not statistically significantly different between treatment groups (DHEA ⴚ2.6 ⴞ 3.4 versus placebo ⴚ2.0 ⴞ 3.8, mean ⴞ SD). The number of patients with flares was decreased by 16% in the DHEA group (18.3% of DHEA-treated patients versus 33.9% of placebo-treated patients; P ⴝ 0.044, based on time to first flare). The mean change in the patient’s global assessment was statistically signifi- Systemic lupus erythematosus (SLE) is a multisystem autoimmune inflammatory disease with diverse clinical and laboratory manifestations and with a variable course and prognosis. Although the etiology of SLE is unknown, hormonal influences may play a key role in disease development and progression. The adrenal steroid dehydroepiandrosterone (DHEA) is secreted primarily as its sulfated metabolite DHEAS. Although the biologic function of DHEA in humans has not been ascertained, it has mild intrinsic androgenic properties, and in peripheral tissues, both DHEA and DHEAS can be converted to various other androgens as well as aromatized to estrogenic steroids (1). The potential for using DHEA in the treatment of SLE was suggested by such observations as the female predominance of SLE, the low circulating levels of DHEA and DHEAS in patients with active disease (2), the immunomodulatory effects of DHEA (3), and the delayed onset of and reduced mortality from SLE in NZB ⫻ NZW mice that were fed DHEA (4). The present study was designed to evaluate the safety and efficacy of DHEA treatment in female pa- Supported in part by Genelabs Biotechnology Company, Ltd., and by a grant from the National Science Council (NSC90-2314-B016-069). 1 Deh-Ming Chang, MD: Tri-Service General Hospital, National Defense Medical Center, Taipei, Taiwan, Republic of China; 2 Joung-Liang Lan, MD: Veteran’s General Hospital, Taichung, Taiwan, Republic of China; 3Hsiao-Yi Lin, MD: Veteran’s General Hospital, Taipei, Taiwan, Republic of China; 4Shue-Fen Luo, MD: Chang-Gung Memorial Hospital, Taipei, Taiwan, Republic of China. Address correspondence and reprint requests to Deh-Ming Chang, MD, Deputy Director, Tri-Service General Hospital, 325 Cheng-Kung Road, Section 2, Neihu 114, Taipei, Taiwan, Republic of China. E-mail: [email protected]. Submitted for publication February 6, 2002; accepted in revised form July 26, 2002. 2924 DHEA TREATMENT IN WOMEN WITH SLE tients with mild-to-moderate SLE disease activity. Our findings are presented herein. PATIENTS AND METHODS Study design. This study was a randomized, doubleblind, placebo-controlled trial conducted at 4 medical centers in Taiwan using the same protocol. Adult Chinese women with SLE according to the American College of Rheumatology criteria (5) who were receiving a dosage of 0–10 mg/day of prednisone (or its equivalent) at study entry were enrolled. Patients had active SLE, which was originally defined as a Systemic Lupus Activity Measure (SLAM) score ⱖ7 (6). This was subsequently amended to also require a baseline SLE Disease Activity Index (SLEDAI) score ⬎2 (7). In patients treated with hydroxychloroquine, azathioprine, methotrexate, or cyclophosphamide, either alone or in combination, the regimen had to have been stable, with no changes in the dosage or drug combination, for at least 6 weeks prior to study entry. This regimen was to remain unchanged throughout the study. Patients who were receiving androgens, immunoglobulins, cyclosporin A, or immunosuppressive agents other than those noted above were excluded. After a 10-day screening and qualifying baseline period, patients were assigned by predetermined randomization code to receive DHEA at a dosage of 200 mg/day or placebo for 24 weeks. Scheduled evaluations at baseline and at weeks 4, 12, and 24 included a physical examination, routine laboratory determinations, the SLAM score, and patient’s and physician’s global assessments (using a 100-mm visual analog scale [VAS]). The SLEDAI score was measured at baseline and at weeks 12 and 24 only. Serum levels of sex hormones and DHEAS were measured at baseline and at the last visit. The protocol was approved by the Institutional Review Board at each center. All patients gave their written informed consent. Efficacy end point. The primary end point was the mean change in the SLAM score at 24 weeks of therapy compared with baseline. Secondary end points included SLE flare, change in SLEDAI score, and physician’s and patient’s VAS scores at 24 weeks. Our definition of disease flare was similar to that of the ongoing SELENA (Safety of Estrogens in Lupus Erythematosus: National Assessment) study (8), except that we included an increase in glucocorticoid dosage of ⱖ2.5 mg for at least 7 days for SLE-related reasons as a component. Safety variables. Adverse events were coded according to the COSTART system. The variables were summarized by treatment group and body system. Laboratory measurements. Laboratory assessments included a urinalysis, a Westergren erythrocyte sedimentation rate (ESR), and routine serum biochemistries. Anti–doublestranded DNA (anti-dsDNA) antibody, C3 and C4 complement, serum 17-estradiol, total testosterone, and DHEAS levels were also measured. Statistical analysis. All statistical tests were 2-sided and evaluated at the 0.05 level of significance. Continuous variables were analyzed using an analysis of variance model. Categorical variables were analyzed using chi-square test. 2925 Table 1. Efficacy variables in the study patients, by treatment group* SLAM score Baseline Mean change SLEDAI score Baseline Mean change Patient’s VAS score Baseline Mean change Physician’s VAS score Baseline Mean change DHEA-treated patients (n ⫽ 61) Placebo-treated patients (n ⫽ 59) P† 10.3 ⫾ 2.8 ⫺2.6 ⫾ 3.4 10.4 ⫾ 2.6 ⫺2.0 ⫾ 3.8 0.355 8.2 ⫾ 4.9 ⫺1.2 ⫾ 5.4 6.6 ⫾ 3.4 ⫺1.4 ⫾ 4.6 0.742 37.0 ⫾ 18.8 ⫺5.5 ⫾ 20.0 33.7 ⫾ 17.9 5.4 ⫾ 26.6 0.005 31.0 ⫾ 11.3 ⫺9.2 ⫾ 13.9 31.4 ⫾ 14.0 ⫺6.3 ⫾ 16.9 0.104 * Values are the mean ⫾ SD baseline scores and the mean ⫾ SD change in scores at the last visit in the intent-to-treat population. DHEA ⫽ dehydroepiandrosterone; SLAM ⫽ Systemic Lupus Activity Measure; SLEDAI ⫽ Systemic Lupus Erythematosus Disease Activity Index; VAS ⫽ visual analog scale. † P values were determined by analysis of variance, with treatment, center, and treatment by center interaction as factors. RESULTS Characteristics of the study patients. A total of 120 patients were randomized into the study and received treatment as follows: 61 patients received DHEA 200 mg/day and 59 patients received placebo. The two treatment groups were well balanced with regard to baseline characteristics. The patients were of similar age and menopause status, and their prednisone dosage/use, use of cytotoxic agents, use of antimalarials, and scores on the SLE activity instruments were similar at baseline. Patients were evaluated for 24 weeks or until early termination of the study drug. Fifty-eight patients in the DHEA group (95.1%) and 55 patients in the placebo group (93.2%) completed the study. The mean duration of exposure was approximately the same in both treatment groups (164 ⫾ 26.6 days in DHEA group and 163.7 ⫾ 23.5 in placebo group; P ⫽ 0.986); the median duration of exposure was identical (169.0 days). Efficacy of DHEA. The primary end point was the change in SLAM scores from baseline. No significant difference in SLAM scores between the two treatment groups was detected (P ⫽ 0.355) (Table 1). As shown in Table 2 and Figure 1, significantly fewer patients in the DHEA group had disease flares. The DHEA group showed significantly greater improvement in patient’s VAS scores compared with the placebo group. Patient’s VAS scores decreased by 5.5 from a baseline score of 37.0 in the DHEA group and 2926 CHANG ET AL Table 2. Frequency of disease flares in the study patients, by treatment group* First disease flare No. of patients % of patients DHEA-treated patients (n ⫽ 60) Placebo-treated patients (n ⫽ 59) 11 18.3 20 33.9 * There was a statistically significant difference between groups for the time to first disease flare (P ⫽ 0.044). DHEA ⫽ dehydroepiandrosterone. increased by 5.4 from a baseline score of 33.7 in the placebo group (P ⫽ 0.005) (Table 1). Safety of DHEA. DHEA was well tolerated in these study patients. Expected androgenic effects, including increased testosterone levels and increased incidence of acne, were observed. No life-threatening reactions or serious safety issues were identified during this study. Adverse events. Adverse events that were assessed by the investigators as being serious were reported in a significantly higher proportion of patients in the placebo group than in the DHEA group. One or more serious adverse events were reported for 7 of 61 patients treated with DHEA (11.5%) and for 18 of 59 patients treated with placebo (30.5%); the difference was statistically significant (P ⫽ 0.010 by chi-square test). In most cases, the types of serious adverse events reported were consistent with SLE flares or hospitalization for manifestations of SLE, rather than being adverse effects of the study drug. Findings of clinical laboratory evaluations. For all standard laboratory tests of safety, the two groups appeared to be well matched at baseline. There were no overall trends in the results of hematologic, biochemical, or lipid tests that would be suggestive of an adverse effect of DHEA treatment. Levels of triglycerides decreased in the DHEA group compared with the placebo group (P ⬍ 0.05). Estradiol levels decreased in both groups. The median decrease was slightly larger for the DHEA group (39.3 pg/ml versus 31.5 pg/ml in the placebo group). Mean and median testosterone levels increased in the DHEA group and decreased in the placebo group (46.6 and 39.5 pg/ml versus ⫺6.6 and ⫺6.5 pg/ml, respectively; P ⬍ 0.05). The mean and median levels of C3 and C4 serum complement decreased in patients in the DHEA group, whereas a small increase or no change was noted in patients in the placebo group (P ⬍ 0.05). Anti-dsDNA antibody titers decreased in both treatment groups, but the mean and median decreases were greater in the placebo group. In both treatment groups, the majority of patients had abnormally high anti-dsDNA titers at the baseline visit and at the final visit. The ESR was comparable in the two treatment groups at baseline. Small decreases in the median ESR values at each visit were observed in both treatment groups. Most patients in both treatment groups had DHEAS levels of 0–200 g/dl at baseline. At the assessments after baseline, ⬃60% of patients in the DHEA group had DHEAS levels ⬎1,000 g/dl. The levels in the remaining patients were distributed over each of the lower 200-g/dl incremental ranges. There was no evidence of elevated DHEAS levels in the placebo group at baseline or at subsequent visits. DISCUSSION Figure 1. Time to first flare in Chinese women with mild-to-moderate systemic lupus erythematosus treated with dehydroepiandrosterone (DHEA) versus placebo (P ⫽ 0.044). In this double-blind study evaluating the efficacy and safety of DHEA for the treatment of mild-tomoderate SLE in women, we found significant reductions in the time to disease flare and serious lupusrelated adverse events, as well as improvement in patient’s global assessment in the DHEA-treated group compared with the placebo-treated group. This is of particular interest since almost all patients were already receiving treatment with standard medications, including glucocorticoids and other immunosuppressive agents. While the planned primary analysis, change in SLAM score from baseline to last visit, did not demonstrate significant differences between the two treatment groups, it is important to recognize that this study was of relatively short duration (6 months), and there are as yet DHEA TREATMENT IN WOMEN WITH SLE no fully validated end points for therapeutic interventions in lupus trials. Given the multiple end points of this study, its findings should be confirmed in a trial of longer duration. Multiple mechanisms could be mediating these effects, including favorable changes in inflammatory cytokines such as interleukin-6 (IL-6), which is increased in patients with active SLE (9). DHEA has been reported to reduce the release of IL-6 from human mononuclear cells in vitro (3,10). Decreases in complement levels without SLE flare during DHEA treatment were observed in this study as well as in two other clinical studies (11,12). A presumed reduction in IL-6 production during DHEA administration might be associated with a reduction in the levels of C3, which is an acute-phase reactant (13). DHEA was well tolerated by the patients in this study, with no evidence of unexpected or serious adverse effects of the drug. Most of the serious adverse events reported in this study appeared to be related to SLE flares or to hospitalization for manifestations of SLE, rather than to adverse study drug effects. The proportion of patients experiencing serious adverse events was statistically significantly higher in the placebo group. This finding is consistent with the reduction in SLE flares observed in the efficacy analysis of this study. A double-blind study conducted at Stanford University suggested that DHEA at a dosage of 200 mg/day was well tolerated and may have steroid-sparing effects and reduce the number of flares in patients with mildto-moderate SLE (14). Furthermore, in two subsequent multicenter studies, DHEA treatment at a dosage of 200 mg/day allowed for a reduction in the prednisone dosage to near-physiologic levels in a significantly greater proportion of patients than did placebo (11), and it stabilized or improved the SLE activity and its symptoms and prevented bone loss (12). In summary, in this 24-week study of adult Chinese women with mild-to-moderate SLE, treatment with DHEA at a dosage of 200 mg once a day resulted in a stabilization of the overall lupus activity, with fewer flares and fewer hospitalizations and without serious or unexpected adverse effects. Concurrent use of DHEA will offer meaningful benefit, especially for steroiddependent lupus patients. Confirmation in a larger study of longer duration will be necessary to further define the role of DHEA in SLE. 2927 ACKNOWLEDGEMENT We deeply appreciate Dr. Peter H. Schur for his advice and revision of the manuscript. REFERENCES 1. Schmidt M, Kreutz M, Loffler G, Scholmerich J, Straub RH. Conversion of dehydroepiandrosterone to downstream steroid hormones in macrophages. J Endocrinol 2000;164:161–9. 2. Lahita RG, Bradlow HL, Ginzler E, Pang S, New M. Low plasma androgens in women with systemic lupus erythematosus. Arthritis Rheum 1987;30:241–8. 3. Straub RH, Scholmerich J, Zietz B. Replacement therapy with DHEA plus corticosteroids in patients with chronic inflammatory diseases: substitutes of adrenal and sex hormones. Z Rheumatol 2000;59 Suppl 2:II/108–18. 4. Lucas JA, Ahmed SA, Casey ML, MacDonald PC. Prevention of autoantibody formation and prolonged survival in New Zealand black/New Zealand white F1 mice fed dehydroisoandrosterone. J Clin Invest 1985;75:2091–93. 5. Tan EM, Cohen AS, Fries JF, Masi AT, McShane DJ, Rothfield NF, et al. The 1982 revised criteria for the classification of systemic lupus erythematosus. Arthritis Rheum 1982;25:1271–7. 6. Liang MH, Socher SA, Larson MG, Schur PH. Reliability and validity of six systems for the clinical assessment of disease activity in systemic lupus erythematosus. Arthritis Rheum 1989;32: 1107–18. 7. Bombardier C, Gladman DD, Urowitz MB, Caron D, Chang DH, and the Committee on Prognosis Studies in SLE. Derivation of the SLEDAI: a disease activity index for lupus patients. Arthritis Rheum 1992;35:630–40. 8. Petri M, Buyon J, Kim M. Classification and definition of major flares in SLE clinical trials. Lupus 1999;8:685–91. 9. Linker-Israeli M, Deans RJ, Wallace DJ, Prehn J, Ozeri-Chen T, Klinenberg JR. Elevated levels of endogenous IL-6 in systemic lupus erythematosus: a putative role in pathogenesis. J Immunol 1991;147:117–23. 10. Straub RH, Konecna L, Hrach S, Rothe G, Kreutz M, Scholmerich J, et al. Serum dehydroepiandrosterone (DHEA) and DHEA sulfate are negatively correlated with serum interleukin-6 (IL-6), and DHEA inhibits IL-6 secretion from mononuclear cells in man in vitro: possible link between endocrinosenescence and immunosenescence. J Clin Endocrinol Metab 1998;83:2012–17. 11. Petri MA, Lahita RG, Van Vollenhoven RF, Merrill JT, Schiff M, Ginzler EM, et al. Effects of prasterone on corticosteroid requirements of women with systemic lupus erythematosus: a doubleblind, randomized, placebo-controlled trial. Arthritis Rheum 2002; 46:1820–9. 12. Mease PJ, Merrill JT, Lahita RG, Petri MA, Ginzler EM, Katz RS, et al. GL701 (prasterone, dehydroepiandrosterone) improves systemic lupus erythematosus [abstract]. Arthritis Rheum 2000;43 Suppl 9:S271. 13. Zhao YX, Andoh A, Shimada M, Takaya H, Hata K, Fujiyama Y, et al. Secretion of complement components of the alternative pathway (C3 and factor B) by the human alveolar type II epithelial cell line A549. Int J Mol Med 2000;5:415–9. 14. Van Vollenhoven RF, Engleman EG, McGuire JL. Dehydroepiandrosterone in systemic lupus erythematosus: results of a doubleblind, placebo-controlled, randomized clinical trial. Arthritis Rheum 1995;38:1826–31. ARTHRITIS & RHEUMATISM Vol. 50, No. 9, September 2004, pp 2858–2868 DOI 10.1002/art.20427 © 2004, American College of Rheumatology Effects of Prasterone on Disease Activity and Symptoms in Women With Active Systemic Lupus Erythematosus Results of a Multicenter Randomized, Double-Blind, Placebo-Controlled Trial Michelle A. Petri,1 Philip J. Mease,2 Joan T. Merrill,3 Robert G. Lahita,4 Mark J. Iannini,5 David E. Yocum,6 Ellen M. Ginzler,7 Robert S. Katz,8 Oscar S. Gluck,† Mark C. Genovese,9 Ronald Van Vollenhoven,10 Kenneth C. Kalunian,11 Susan Manzi,12 Maria W. Greenwald,13 Jill P. Buyon,14 Nancy J. Olsen,15 Michael H. Schiff,16 Arthur F. Kavanaugh,11 Jacques R. Caldwell,17 Rosalind Ramsey-Goldman,18 E. William St.Clair,19 Allan L. Goldman,20 Rita M. Egan,21 Richard P. Polisson,22 Kevin G. Moder,23 Naomi F. Rothfield,24 Robert T. Spencer,25 Kathryn Hobbs,16 Barri J. Fessler,26 Leonard H. Calabrese,27 Larry W. Moreland,26 Stanley B. Cohen,28 Betty J. Quarles,29 Vibeke Strand,9 Marc Gurwith,29 and Kenneth E. Schwartz29 Objective. To determine whether prasterone administration results in improvement or stabilization of systemic lupus erythematosus (SLE) disease activity and its symptoms. Methods. Women with active SLE were treated with prasterone 200 mg/day plus standard SLE treatments or with placebo plus standard SLE treatments for up to 12 months in this randomized, double-blind investigation conducted at 27 centers. Standard SLE treatments included prednisone (<10 mg/day), antimalarials, and immunosuppressive agents; dosages were required to be stable for >6 weeks prior to enrollment and remain unchanged during protocol treatment. Re- Presented in part at the 64th Annual Scientific Meeting of the American College of Rheumatology, Philadelphia, PA, November 2000, and at the Annual Meeting of the British Society for Rheumatology, Manchester, UK, April 2003. Supported by Genelabs Technologies, Inc., Redwood City, CA. 1 Michelle A. Petri, MD, MPH: Johns Hopkins University Medical Center, Baltimore, Maryland; 2Philip J. Mease, MD: Seattle Rheumatology Associates, Seattle, Washington; 3Joan T. Merrill, MD: Oklahoma Medical Research Foundation, Oklahoma City; 4Robert G. Lahita, MD, PhD: Liberty Health, Jersey City, New Jersey; 5Mark J. Iannini, MD, MPH: Carondelet Medical Group, Tucson, Arizona; 6 David E. Yocum, MD: University of Arizona Health Sciences Center, Tucson; 7Ellen M. Ginzler, MD, MPH: SUNY Health Science Center at Brooklyn, Brooklyn, New York; 8Robert S. Katz, MD: Rheumatology Associates, Chicago, Illinois; 9Mark C. Genovese, MD, Vibeke Strand, MD: Stanford University School of Medicine, Stanford, California; 10Ronald Van Vollenhoven, MD, PhD: Karolinska Hospital, Stockholm, Sweden; 11Kenneth C. Kalunian, MD, Arthur F. Kavanaugh, MD: University of California, San Diego School of Medicine, San Diego; 12Susan Manzi, MD, MPH: University of Pittsburgh School of Medicine, Pittsburgh, Pennsylvania; 13Maria W. Greenwald, MD: Advances in Medicine, Rancho Mirage, California; 14Jill P. Buyon, MD: New York University School of Medicine, New York; 15Nancy J. Olsen, MD: Vanderbilt University School of Medicine, Nashville, Tennessee; 16Michael H. Schiff, MD, Kathryn Hobbs, MD: Denver Arthritis Clinic, Denver, Colorado; 17Jacques R. Caldwell, MD: Halifax Clinical Research Institute, Daytona Beach, Florida; 18Rosalind Ramsey-Goldman, MD, DrPH: Northwestern University Feinberg School of Medicine, Chicago, Illinois; 19E. William St.Clair, MD: Duke University Medical Center, Durham, North Carolina; 20Allan L. Goldman, MD: Rheumatic Disease Center, Milwaukee, Wisconsin; 21 Rita M. Egan, MD: Arthritis Center of Lexington, Lexington, Kentucky; 22Richard P. Polisson, MD, MHS: Massachusetts General Hospital, Boston; 23Kevin G. Moder, MD: Mayo Clinic Foundation, Rochester, Minnesota; 24Naomi F. Rothfield, MD: University of Connecticut Medical Center, Farmington; 25Robert T. Spencer, MD: Colorado Arthritis Center, Englewood; 26Barri J. Fessler, MD, Larry W. Moreland, MD: University of Alabama School of Medicine at Birmingham; 27Leonard H. Calabrese, DO: Cleveland Clinic Foundation, Cleveland, Ohio; 28Stanley B. Cohen, MD: St. Paul Medical Center, Dallas, Texas; 29Betty J. Quarles, BS, Marc Gurwith, MD, JD (current address: Vaxgen, Inc., San Bruno, California), Kenneth E. Schwartz, MD: Genelabs Technologies, Inc., Redwood City, California. † Dr. Gluck is deceased. Drs. Petri, Kalunian, Ramsey-Goldman, and Strand have served as consultants to Genelabs Technologies, Inc. Address correspondence and reprint requests to Michelle A. Petri, MD, MPH, Professor of Medicine, Division of Rheumatology, Department of Medicine, Johns Hopkins University Medical Center, 1830 East Monument Street, Suite 7500, Baltimore, MD 21205. E-mail: [email protected]. Submitted for publication August 15, 2003; accepted in revised form April 29, 2004. 2858 PRASTERONE TREATMENT IN SLE sponders were patients who experienced no clinical deterioration and had improvement or stabilization over the duration of the study in 2 disease activity measures (the SLE Disease Activity Index [SLEDAI] and the Systemic Lupus Activity Measure) and 2 quality of life measures (patient’s global assessment and the Krupp Fatigue Severity Scale). Results. A total of 381 women with SLE were enrolled. Among patients with clinically active disease at baseline (SLEDAI score >2), 86 of 147 in the prasterone group (58.5%) demonstrated improvement or stabilization without clinical deterioration, as compared with 65 of 146 in the placebo group (44.5%) (P ⴝ 0.017). Acne and hirsutism were reported in 33% and 16%, respectively, of the prasterone group and in 14% and 2%, respectively, of the placebo group (P < 0.05 for both comparisons). However, most cases of acne and hirsutism were mild and did not require withdrawal from therapy. Myalgias and oral stomatitis were reported less frequently in the prasterone group (22% and 15%, respectively) than in the placebo group (36% and 23%, respectively) (P < 0.05 for both comparisons). Serum levels of high-density lipoprotein cholesterol, triglycerides, and C3 complement significantly decreased, while levels of testosterone and, to a lesser extent, estradiol increased in the prasterone group. Conclusion. In adult women with active SLE, administration of prasterone at a dosage of 200 mg/day improved or stabilized signs and symptoms of disease and was generally well tolerated. Systemic lupus erythematosus (SLE) is a chronic, potentially fatal autoimmune disease that occurs 9 times more frequently in women than in men (1). Although the multifactorial etiology of this disease is poorly understood, abnormalities of both estrogen and androgen metabolism in SLE patients have been reported (2,3). Dehydroepiandrosterone (DHEA) is a naturally occurring steroid produced by the adrenal glands. It is secreted primarily as its metabolite, DHEA sulfate (DHEAS), which is the most abundant circulating adrenal steroid in humans (4). Both DHEA and DHEAS are subsequently converted into androgenic and estrogenic steroids in peripheral tissues (5,6). Decreases of ⬃50% in circulating levels of DHEA and DHEAS have been observed in patients with SLE (7,8). Previous studies in animal models of SLE have demonstrated improvement with androgen administration, including DHEA (9–14). In addition to serving as a precursor for other androgenic and estrogenic steroids (5), there is evidence that 2859 DHEA has an immunomodulatory role, including upregulation of interleukin-2 (IL-2) and down-regulation of IL-6 expression (9,15–17), both of which have been reported to be abnormal in SLE (18–20). Prasterone is the United States Adopted Names generic designation for dehydroepiandrosterone. In open-label and placebo-controlled studies, Van Vollenhoven et al (21,22) reported that SLE patients receiving oral prasterone 200 mg/day had improvement in a number of outcome variables, including reduction of steroid dosages, the number of disease flares, and global assessments of disease activity (21,22). In an initial phase II/III trial comparing placebo with 100 and 200 mg/day of prasterone, it was demonstrated that 200 mg/day of prasterone allowed a sustained reduction in the glucocorticoid dosage (23). In addition, delay in time to SLE flare has been reported for women treated with prasterone (24). The present study was conducted to determine whether prasterone administration results in improvement or stabilization in SLE disease activity and its symptoms. PATIENTS AND METHODS Study participants. This prospective randomized, double-blind, placebo-controlled trial conducted at 27 study sites evaluated female patients with active SLE. Patients were required to meet the American College of Rheumatology 1982 criteria for a diagnosis of SLE (25) and have active disease, as determined by 2 disease activity indices. Initially, active disease was defined as a Systemic Lupus Activity Measure (SLAM) score ⱖ7 at baseline (26). While the study was ongoing and blinded, this was amended to also require a Systemic Lupus Erythematosus Disease Activity Index (SLEDAI) score ⬎2 at baseline (27). Eligibility was determined at screening and qualifying visits, which occurred no more than 10 days apart. Patients in both treatment groups were allowed to continue taking standard SLE medications. Baseline medications that were allowed included oral glucocorticoids (ⱕ10 mg/day of prednisone or equivalent), hydroxychloroquine, and/or immunosuppressive agents, including methotrexate, azathioprine, cyclophosphamide, and mycophenolate mofetil. Interventions. Patients were assigned by predetermined randomization codes to receive either prasterone 200 mg/day or placebo as once-daily morning doses for up to 52 weeks. Capsules containing placebo were identical to those containing prasterone. Physicians and patients were instructed to maintain the dosages of prednisone and other baseline SLE medications at the baseline dosages during protocol participation. Outcomes. The primary end point was the proportion of patients who were “responders.” Responders were patients who showed improvement or stabilization in SLE disease activity and constitutional symptoms without clinical deterioration over the duration of the study. 2860 Responder status was designed prospectively, in conjunction with lupus experts and with significant input by the US Food and Drug Administration, to be a single composite end point that integrated 3 domains of SLE: disease activity, organ damage, and health-related quality of life (28). Responders were those who demonstrated improvement or stabilization in mean on-treatment scores for 2 disease activity measures (the SLEDAI and the SLAM) and 2 health-related quality of life assessments (patient’s global assessment and the Krupp Fatigue Severity Score [KFSS]) (29) without evidence of clinical deterioration (reflecting organ damage). A patient was deemed to have improved or stabilized in terms of each of the disease activity and health-related quality of life measures if the time-weighted mean of all on-treatment visit measurements for each of the instruments for that patient was less than the mean of 2 pretreatment values for each of the 4 parameters. “No change” was defined prospectively, while the study was ongoing and blinded. The definition of “no change” allowed for test–retest variability in these scoring instruments, which was defined as ⫾0.5 for the SLEDAI and KFSS, ⫾1.0 for the SLAM, and ⫾10 mm for the patient’s global assessment (30,31). The clinical deterioration component of the responder end point was prospectively defined to include serious drug toxicity attributable to the study drug or other lupus therapy if it occurred during treatment with the study drug or within 6 weeks after discontinuation of the study drug, serious new or progressive lupus-related conditions, or requirement for increased dosage or institution of new therapy with immunosuppressive or cytotoxic agents for treatment of lupus. The occurrence of clinical deterioration and its onset date was determined by Genelabs’ study monitors before the blinding was broken. The following conditions qualified as serious drug toxicity: new-onset diabetes mellitus, defined as diabetes requiring drug therapy for ⱖ 3 months; new gastric or duodenal ulcer not due to Helicobacter pylori and requiring hospitalization or transfusion; new-onset hypertension requiring drug therapy for ⱖ3 months; new myocardial infarction, as demonstrated by electrocardiographic or enzymatic criteria; new steroid myopathy; new elevation in serum transaminase levels (increases in aspartate aminotransferase or alanine aminotransferase levels to ⱖ8 times the upper limit of normal or a single measurement showing levels ⱖ3 times the upper limit of normal at multiple measurements over 3 months); or new fracture and/or vertebral collapse due to osteoporosis. The following conditions qualified as major new or progressive organ disease. These conditions were assessed by the treating physician as being attributable to lupus or its treatment and which occurred during treatment with the study drug or within 6 weeks after discontinuation of the study drug. Central nervous system conditions were cerebrovascular accident transverse myelitis, retinal vascular occlusion, new onset of psychosis of ⬎3 months’ duration, or new onset of seizures that were refractory to therapy for at least 3 months. Renal conditions were new onset of end-stage renal disease or loss of renal function that required dialysis for at least 3 months. Pulmonary conditions were new or worsened pulmonary hypertension and/or interstitial lung disease with reduction in diffusion capacity, mean pulmonary artery pressure, and/or dyspnea at rest (New York Heart Association class IV). PETRI ET AL Cardiovascular conditions were pericarditis that was refractory to treatment for ⬎3 months or that required pericardiectomy, cardiomyopathy that was refractory to therapy for ⬎3 months with hemodynamic compromise (decreased cardiac index, left ventricular ejection fraction, and/or dyspnea at rest), or refractory arrhythmia. Gastrointestinal conditions were ischemic bowel disease that required bowel resection. Vasculitic conditions were vasculitis that resulted in infarction (excluding vasculitis described under any other organ systems). Hematologic conditions were thrombocytopenia that resulted in clinically significant hemorrhage with sequelae that did not resolve for at least 3 months or persistent leukopenia (white blood cell count ⬍1,500/mm3) that resulted in recurrent infections without improvement in the incidence of recurrent infections for at least 3 months. The following qualified as unacceptable increases in immunosuppressive or cytotoxic therapy for lupus: any SLErelated increase in dosages of concomitant methotrexate or azathioprine, or institution of new therapy with cytotoxic or immunosuppressive agents (methotrexate, azathioprine, cyclophosphamide, or cyclosporine), at any time during treatment with the study drug or within 6 weeks after discontinuation of study drug; and except for stress doses, prescribed prednisone dosage increase to ⬎10 mg/day over the baseline dosage within the first 2 months of participation or, through the remainder of the study, prednisone dosage increase to ⬎5 mg/day over the daily baseline dose for ⬎2 consecutive months. Secondary analyses. Prospectively defined secondary analyses included time to lupus flare and mean changes in individual scores on the SLEDAI, SLAM, KFSS, and patient’s global assessment instruments. Time to lupus flare was not part of the initial protocol design. However, given the interest in lupus flares as a potential study outcome for future lupus protocols, it was proposed as a secondary outcome in this study. Time to first lupus flare was analyzed from data derived from chart reviews of all enrolled patients and was determined while the study was ongoing and blinded. SLE flare was defined according to the following 5 criteria: 1) new or worse central nervous system lupus, vasculitis, or myositis requiring scoring on the SLEDAI and not present at a previous visit; 2) thrombocytopenia (⬍60,000 platelets/mm3), a hemoglobin value ⬍7 gm/dl, or a decrease in the hemoglobin level of at least 3 gm/dl; 3) proteinuria with pyuria and/or hematuria treated with new use or increased dosage of glucocorticoids or immunosuppressive agents; 4) an increase in the glucocorticoid dose of ⱖ2.5 mg for at least 7 days for SLE-related reasons; or 5) new use or increase in dosage of immunosuppressive agents or antimalarials for at least 7 days for SLE-related reasons or hospitalization for new manifestation of SLE. Procedures. Scheduled evaluations at baseline and every 3 months included physical examinations, laboratory determinations, and scoring of the SLAM, the SLEDAI, patient’s and physician’s global assessments using 100-mm visual analog scales (VAS), and the KFSS. Laboratory assessments were performed every 3 months. Blood samples were drawn after an 8-hour fast but were not timed to prasterone administration. Assessments included anti–double-stranded DNA (anti-dsDNA) antibodies, C3 and C4 levels, IgG and IgM anticardiolipin antibodies, serum lipid levels (total cholesterol, HDL-cholesterol, calcu- PRASTERONE TREATMENT IN SLE 2861 Table 1. Baseline characteristics of the study patients, by treatment group* Intent-to-treat analysis group (all randomized patients) Age, mean years Caucasian, % Postmenopause, % Prednisone dose, mean (median) mg/day Medication use, % Prednisone Immunosuppressives Antimalarials Prednisone, immunosuppressives, or antimalarials Composite responder index components, mean (median) score SLEDAI SLAM Patient’s global assessment KFSS Laboratory values, mean (median) [no. tested] DHEAS, g/dl C3 complement, mg/dl C4 complement, mg/dl Anti-dsDNA antibody, IU/dl Active SLE group (baseline SLEDAI ⬎2) Placebo (n ⫽ 192) Prasterone (n ⫽ 189) Placebo (n ⫽ 146) Prasterone (n ⫽ 147) 43.8 71.4 47.9 3.7 (2.5) 44.4 77.2 43.9 3.5 (3.8) 43.6 67.8 46.6 4.1 (5.0) 43.8 74.8 42.9 3.6 (5.0) 53.7 15.1 60.9 79.7 54.5 18.0 54.0 82.0 58.2 17.8 59.6 80.8 56.5 21.1 48.3 79.6 5.8 (5.0) 12.0 (12.0) 55.4 (57.0) 5.6 (5.7) 6.5 (6.0) 12.2 (12.0) 55.2 (57.0) 5.5 (5.9) 7.34 (6.0) 12.46 (12.0) 55.17 (56.7) 5.56 (5.7) 8.04 (8.0) 12.69 (12.5) 57.08 (58.5) 5.61 (5.9) 103 (50) [n ⫽ 163] 102.9 (102.0) [n ⫽ 192] 17.9 (16.0) [n ⫽ 192] 23.45 (1.95) [n ⫽ 192] 107 (61) [n ⫽ 165] 104.3 (100.0) [n ⫽ 187] 18.2 (17.0) [n ⫽ 187] 36.08 (2.6) [n ⫽ 187] 91 (47) [n ⫽ 121] 99.3 (97.0) [n ⫽ 146] 17.0 (15.0) [n ⫽ 146] 29.4 (2.4) [n ⫽ 146] 105 (61) [n ⫽ 127] 99.1 (97.0) [n ⫽ 146] 17.2 (15.0) [n ⫽ 146] 43.5 (3.4) [n ⫽ 146] * Baseline values for some of the clinical laboratory tests were not obtained on all patients. SLE ⫽ systemic lupus erythematosus; SLEDAI ⫽ Systemic Lupus Erythematosus Disease Activity Index; SLAM ⫽ Systemic Lupus Activity Measure; KFSS ⫽ Krupp Fatigue Severity Scale; DHEAS ⫽ dehydroepiandrosterone sulfate; anti-dsDNA ⫽ anti–double-stranded DNA. lated LDL-cholesterol, and total triglycerides), serum chemistries, complete blood cell counts, urinalyses, and 24-hour urine collections for creatinine clearance and protein quantitations. Serum levels of 17-estradiol, testosterone, and DHEAS were measured at baseline and the last visit. To avoid unblinding, these results were not reported to the investigators or study monitors until completion of the trial. All blood and urine assays were conducted at a central laboratory (Covance Laboratories, Indianapolis, IN), with the exception of DHEAS levels, which were performed by radioimmunoassay at Genelabs Technologies. The protocol was conducted in accordance with the Declaration of Helsinki and was approved by the institutional review board at each center. All patients gave written informed consent. Statistical analysis. Given that this protocol utilized a responder end point that had never been used in a clinical trial, Table 2. Number (percentage) of patients completing the study and reasons for early withdrawal Completed study drug Discontinued study drug early Lack of efficacy Adverse event Other Placebo (n ⫽ 192) Prasterone (n ⫽ 189) 142 (74.0) 50 (26.0) 9 (4.7) 11 (5.7) 30 (15.6) 124 (65.6) 65 (34.4) 11 (5.8) 27 (14.3) 27 (14.3) there could be no a priori estimation of responder rates. Hence, the sample size of 300 randomized patients was based on practical, rather than statistical, calculations. The original protocol entry criterion required a SLAM score of ⱖ7 for the definition of active disease. There was no restriction on the SLEDAI score for patient entry. While the double-blind study was ongoing, the protocol was subsequently amended to incorporate a baseline SLEDAI score of ⬎2 as an additional entry requirement. This requirement was based upon the outcome of an earlier Genelabs study, which revealed that SLE patients with little or no disease activity (SLEDAI ⱕ2) are likely to exhibit a high response regardless of treatment (23). All randomized patients were included in the intentto-treat analysis of safety (n ⫽ 381). All patients who met criteria for active disease (SLEDAI ⬎2) at both the baseline and screening visits were included in the analysis of efficacy (n ⫽ 293). Patients without postbaseline assessments were designated, by default, as nonresponders. The primary efficacy variable, proportion of responders, was analyzed using a logistic regression model using treatment as a factor. For secondary analyses, betweentreatment comparisons of mean changes in disease activity indices (the SLEDAI and the SLAM), patient’s global assessment, and the KFSS, and laboratory values were analyzed utilizing one-way analysis of variance, with treatment as a factor. Between-treatment comparisons for the number of patients with specific adverse events or clinically important treatment-associated changes in laboratory values were per- 2862 PETRI ET AL Table 3. Percentages of responders and patients with at least 1 definite SLE flare* Patients with at least 1 SLE flare‡ P Responders† Patients with active SLE All patients Placebo Prasterone P Placebo Prasterone SLE flare Time to first flare 44.5 (65/146) 42.2 (81/192) 58.5 (86/147) 51.3 (97/189) 0.017 0.074 34.2 (50/146) 29.7 (57/192) 24.5 (36/147) 23.8 (45/189) 0.097 0.266 0.066 0.195 * Active SLE was defined as a baseline SLEDAI score ⬎2. Approximately 80% of patients in both treatment groups were receiving antimalarials, glucocorticoids, or other immunosuppressive agents at baseline. P values for the responders and for SLE flare were determined by logistic regression analysis using treatment as a factor. P values for time to first SLE flare were determined by log-rank test. Values are the percentage (number responding/number in group or the number with at least 1 SLE flare/number in group). See Table 1 for definitions. † A patient was classified as a responder if no clinical deterioration was observed and if the weighted average of measures of disease activity and health-related quality of life improved or did not deteriorate during treatment relative to baseline values (weighted average increase from baseline for the SLAM ⱕ1, for the SLEDAI ⱕ0.5, for the KFSS ⱕ0.5, and for the patient’s global assessment ⱕ10). ‡ An SLE flare was defined according to the following 5 criteria: 1) new or worse central nervous system lupus, vasculitis, or myositis requiring scoring on the SLEDAI and not present at a previous visit; 2) thrombocytopenia (⬍60,000 platelets/mm3), a hemoglobin value ⬍7 gm/dl, or a decrease in the hemoglobin level of at least 3 gm/dl; 3) proteinuria with pyuria and/or hematuria treated with new use or increased dosage of glucocorticoids or immunosuppressive agents; 4) an increase in the glucocorticoid dose of ⱖ2.5 mg for at least 7 days for SLE-related reasons; or 5) new use or increase in dosage of immunosuppressives or antimalarials for at least 7 days for SLE-related reasons or hospitalization for new manifestation of SLE. formed using chi-square test or Fisher’s exact test. All statistical tests were 2-sided, and P values less than or equal to 0.05 were considered significant. RESULTS Characteristics of the study patients. The trial was conducted at 27 office- or university-based rheumatology practices in the US, from February 1996 to June 1999. Three hundred eighty-one patients were randomized to receive treatment: 189 in the prasterone group and 198 in the placebo group. Treatment groups were well balanced at baseline with regard to age, menopause status, race, concomitant SLE medications, SLE scores, DHEAS levels, and other important laboratory values. Approximately 80% of patients in both groups were receiving standard SLE treatments at baseline, which included antimalarials, glucocorticoids, and/or other immunosuppressive agents. There were no statistically significant between-group differences in baseline characteristics for either the all-patient intent-to-treat analysis or the predefined patient group with active SLE (baseline SLEDAI ⬎2) (Table 1). Seventy-four percent of the placebo group and 65.6% of the prasterone group completed 1 year of treatment (Table 2). There were no meaningful differences in withdrawals across the 2 groups, except for withdrawals due to adverse events, for which 5.7% in the placebo group and 14.3% in the prasterone group withdrew (P ⫽ 0.005). The differences in withdrawals primarily reflected androgenic adverse events in the prasterone group, the majority of which were mild, since there were no differences in the patterns of withdrawals for other types of adverse events. Primary outcome measure, responder analysis. The overall responder rates among the intent-to-treat group were 42.2% (81 of 192 patients) in the placebo group and 51.3% (97 of 189 patients) in the prasterone group (P ⫽ 0.074) (Table 3). In the population with active disease (SLEDAI ⬎2), 44.5% (65 of 146 patients) in the placebo group and 58.5% (86 of 147 patients) in the prasterone group were responders (P ⫽ 0.017). In a post hoc analysis, significant differences between treatment groups persisted with increasing SLEDAI scores (Figure 1). Secondary outcome measures, time to SLE flare and mean changes in individual scoring instruments. Among patients with active disease at baseline, fewer patients in the prasterone treatment group experienced a first flare during the study (24.5% taking prasterone versus 34.2% taking placebo, P ⫽ 0.066), and a trend for prolongation in time to flare was seen among patients who received prasterone (P ⫽ 0.097) (Table 3). There were no statistically significant betweengroup differences in change from baseline in any of the individual components of the responder index (data not shown), but statistically significant differences in individual components of the responder analysis resulted in patients being classified as nonresponders (Table 4), suggesting a worsening of individual components of the composite responder index in more of the placebotreated patients than prasterone-treated patients. The greatest differences between the prasterone and placebo treatment groups were defined by the proportion of patients reporting a worsening in the patient’s global assessment (10.9% of the prasterone group versus 22.6% of the placebo group, P ⫽ 0.007) and in the SLEDAI PRASTERONE TREATMENT IN SLE Figure 1. Percentage of responders to treatment with prasterone or placebo, by baseline Systemic Lupus Erythematosus Disease Activity Index (SLEDAI) score. Values within the bars are the number responding/number in group. scores (only 9.5% of the prasterone group versus 17.8% of the placebo group, P ⫽ 0.039 (Table 4). Although not defined in the specified analysis plan, it was of interest to assess responders among the patients who were not receiving antimalarials, glucocorticoids, or other immunosuppressive agents at baseline (⬃20% of patients), given the high rate of background medication use in both treatment groups. Among patients not receiving these medications at baseline and who had active disease at study entry (i.e., baseline SLEDAI ⬎2), responder rates were 42.9% (12 of 28 patients) in the placebo group and 70.0% (21 of 30 patients) in the prasterone group (P ⫽ 0.037). Adverse events. Study drug administration was discontinued early in 65 (34%) of the 189 prasterone- 2863 treated patients and 50 (26%) of the 192 placebo-treated patients (P ⫽ 0.076). Early discontinuations were similar between treatment groups, with the exception of an increased number in the prasterone group withdrawing due to reported androgenic adverse events. Eleven patients (5.8%) with acne and/or hirsutism indicated these events as reasons for treatment discontinuation in the prasterone treatment group. Serious adverse events were reported in 14% (27 of 189 patients) in the prasterone group and 17% (33 of 192 patients) in the patients in placebo treatment groups, respectively. Fourteen of these events in the prasterone group and 16 in the placebo group resulted in treatment discontinuation. While there were no deaths in the prasterone treatment group, there were 5 deaths during or shortly after completion of treatment in the placebo group, including 2 suicides, 1 death due to pulmonary hypertension, 1 sudden death, and 1 death from non-Hodgkin’s lymphoma 6 weeks following protocol completion. Three patients were diagnosed as having cancer during the study, all of whom were in the placebo group: the patient with non-Hodgkin’s lymphoma noted previously, 1 patient with carcinoma of the breast, and 1 patient with carcinoma of the lung. Adverse events reported in 10% or more of the active and control treatment populations are shown in Table 5. Androgenic adverse events, including acne and hirsutism, were more commonly reported in patients receiving prasterone (42%) than in patients receiving placebo (18%) (P ⬍ 0.05). Most androgenic complaints were characterized as mild or moderate; none was severe. Adverse events such as myalgias, stomatitis (oral ulcers), alopecia, and fever were reported less frequently in patients receiving prasterone in comparison to placebo (Table 5). These differences were statistically sig- Table 4. Patients with a baseline SLEDAI ⬎2 who failed to meet individual response criteria, by treatment group* Criterion Clinical deterioration Worsening of composite responder index component scores SLEDAI score SLAM score Patient’s global assessment score KFSS score No. (%) of placebo group (n ⫽ 146) No. (%) of prasterone group (n ⫽ 147) P 13 (8.9) 15 (10.2) 0.705 26 (17.8) 15 (10.3) 33 (22.6) 21 (14.4) 14 (9.5) 10 (6.8) 16 (10.9) 16 (10.9) 0.039 0.288 0.007 0.367 * Patients could have failed to meet ⬎1 criterion. Approximately 80% of patients in both treatment groups were receiving antimalarials, glucocorticoids, or other immunosuppressive agents at baseline. P values were determined by chi-square test. See Table 1 for definitions. 2864 PETRI ET AL nificant for myalgias and oral ulcers, suggesting potential beneficial effects of prasterone treatment on some of the typical signs and symptoms of SLE. Treatment-associated changes in laboratory values. Total cholesterol, high-density lipoprotein (HDL) cholesterol, low-density lipoprotein (LDL) cholesterol, and total triglyceride levels decreased in the prasterone treatment group, although decreases in LDL cholesterol were minimal (Figure 2). Treatment-associated decreases in total cholesterol and HDL cholesterol were significantly greater in the prasterone group compared with the placebo group. Serum triglycerides were also statistically significantly decreased in the prasterone group compared with the placebo group, in which they were increased. Reductions in serum HDL cholesterol, total cholesterol, and triglyceride levels were evident in the prasterone treatment group by month 3, and the reductions were maintained with subsequent study drug administration (data not shown). HDL cholesterol levels decreased from normal levels at baseline in 133 and 148 patients in the prasterone and placebo groups, respectively, to below 40 mg/dl (the currently recommended lower limit for HDL cholesterol [32]) at the end of treatment in 38 patients receiving prasterone (26.6%) compared with 15 patients receiving placebo (10.1%) (P ⫽ 0.001 by chi-square test). Mean serum levels of C3 complement declined in the prasterone treatment group: –7% from baseline Table 5. Adverse events reported by ⱖ10% of patients in either treatment group* Adverse event No. (%) of placebo group (n ⫽ 192) No. (%) of prasterone group (n ⫽ 189) Rash Arthralgia Acne Asthenia Arthritis Headache Myalgia Flu syndrome Hirsutism Stomatitis (mucosal ulcers) Depression Alopecia Abdominal pain Fever Peripheral vascular disease Sinusitis Chest pain 62 (32.3) 71 (37.0) 27 (14.1) 51 (26.6) 42 (21.9) 56 (29.2) 69 (35.9) 42 (21.9) 3 (1.6) 44 (22.9) 30 (15.6) 39 (20.3) 30 (15.6) 28 (14.6) 20 (10.4) 20 (10.4) 20 (10.4) 75 (39.7) 68 (36.0) 63 (33.3)† 45 (23.8) 45 (23.8) 42 (22.2) 42 (22.2)† 39 (20.6) 31 (16.4)† 28 (14.8)† 28 (14.8) 28 (14.8) 27 (14.3) 22 (11.6) 19 (10.1) 17 (9.0) 14 (7.4) * Approximately 80% of the patients in both treatment groups were receiving antimalarials, glucocorticoids, or other immunosuppressive agents at baseline. † P ⬍ 0.05 by chi-square test. Figure 2. Mean baseline concentrations of lipids and mean change in lipid levels from baseline to the last visit during treatment. Values above the x-axis represent the placebo group on the left and the prasterone group on the right. ⴱ ⫽ P ⬍ 0.05 for within-treatment change from baseline. Tot-C ⫽ total cholesterol; HDL-C ⫽ highdensity lipoprotein cholesterol; LDL-C ⫽ low-density lipoprotein cholesterol; Tot-TG ⫽ total triglycerides. values compared with –2% in the placebo group (P ⫽ 0.015). This decline was not associated with renal deterioration or with institution of new immunosuppressive treatment. There were minor decreases in C4 complement levels in both treatment groups, but the differences between groups were not significant. Mean ⫾ SD changes in anti-dsDNA levels from the baseline visit to the last visit were 5.8 ⫾ 145.6 IU/ml (median 0.0) in the placebo group and 20.0 ⫾ 130.0 IU/ml (median 0.0) in the prasterone group; the differences between treatment groups were not statistically significant. Treatment-associated changes in sex hormone levels. As expected, serum DHEAS values increased to pharmacologic levels in the prasterone treatment group. The mean DHEAS concentrations at the last visit were 811 g/dl (median 607) in the prasterone treatment group. These levels were unchanged in the placebo treatment group 120 g/dl (median 50). Serum testosterone levels increased in prasterone-treated patients, especially among those who were postmenopausal (Table 6). In contrast, treatmentassociated changes in estrogenic hormones were less consistent. In premenopausal women, no meaningful changes in serum estradiol were evident in either the prasterone-treated patients or the placebo-treated patients (Table 6). Changes in estradiol levels in postmenopausal women were analyzed according to the presence or absence of hormone replacement therapy (HRT). Patients reported by investigators to be postmenopausal but with baseline estradiol levels ⱖ20 pg/ml were excluded from this analysis as being perimenopausal. Mean serum estradiol levels increased in postmeno- PRASTERONE TREATMENT IN SLE 2865 Table 6. Change in testosterone and estradiol levels, by menopause status* P Testosterone, mean (median) ng/dl Premenopausal patients Placebo (n ⫽ 63) Prasterone (n ⫽ 71) Postmenopausal patients Placebo (n ⫽ 68) Prasterone (n ⫽ 52) Estradiol, mean (median), pg/ml Premenopausal patients Placebo (n ⫽ 63) Prasterone (n ⫽ 71) Postmenopausal patients (no HRT)† Placebo (n ⫽ 14) Prasterone (n ⫽ 18) Postmenopausal patients taking HRT Placebo (n ⫽ 35) Prasterone (n ⫽ 30) Baseline Last visit Change Change from baseline Treatment comparison 20.5 (16.0) 23.8 (19.0) 19.3 (16.0) 58.9 (56.0) ⫺1.2 (⫺2.0) 35.0 (32.0) 0.5541 0.0001 0.0001 20.4 (17.0) 17.9 (12.5) 18.2 (12.5) 74.8 (54.0) ⫺2.1 (0.0) 57.0 (41.5) 0.1648 0.0001 0.0001 97.8 (74.2) 85.6 (63.9) 88.9 (62.8) 86.5 (65.2) ⫺8.9 (0.3) 1.0 (1.5) 0.5098 0.9367 0.5884 2.5 (1.4) 3.7 (1.9) 2.3 (1.4) 24.8 (22.2) ⫺0.1 (0.0) 21.1 (19.4) 0.8127 0.0003 0.0003 104.4 (64.7) 85.6 (79.4) 82.4 (66.5) 128.1 (105.1) ⫺22.0 (1.7) 42.4 (34.1) 0.2950 0.0170 0.0210 * Not all patients had measurements of estradiol or testosterone levels at both baseline and the end of treatment. Therefore, the total number of patients does not equal the total number randomized. † At baseline, estradiol levels were ⬍20 pg/ml, and the patients were not taking hormone replacement therapy (HRT). pausal patients receiving prasterone and HRT; however, the cotreatment with HRT makes the interpretation of these findings difficult. In postmenopausal patients who were not receiving HRT, prasterone led to increases in serum estradiol levels that were similar to the levels previously reported with low-dose HRT (33). There were no correlations between changes in sex hormone levels and responder outcomes (data not shown). DISCUSSION In this double-blind, randomized, placebocontrolled trial of prasterone treatment at 200 mg/day for up to 52 weeks, we found significant improvements in the patients taking prasterone. Significantly more patients in the prasterone group than in the placebo group experienced either improvement or stabilization of disease activity (P ⫽ 0.017). Given the complexity of SLE, it was important to assess the disease in its entirety, and this study was the first of its kind to utilize an innovative composite end point that was designed to integrate all 3 SLE domains— disease activity, organ damage, and health-related quality of life—into an overall “responder” end point. Patients categorized as “responders” had to exhibit simultaneous improvement or stabilization in each of 2 disease activity measures (SLEDAI and SLAM) and 2 quality of life measures (KFSS and patient’s global assessment), without clinical deterioration. To qualify for enrollment in this study, patients had to have stable disease activity at baseline, without recent changes in cotreatments, including glucocorticoids, antimalarials, and immunosuppressives. Cotreatments with these drugs were required to be held at a fixed dosage for the duration of the study The high response rate (45%) in the placebo treatment group should be interpreted in the context that this was not a true placebo-controlled trial, since most patients were cotreated with standard SLE therapies during the study. Thus, the statistically significant improvement in the prasterone group (59% taking prasterone versus 45% taking placebo were responders) is both statistically and clinically meaningful. Deterioration in the mean postbaseline measures in any 1 of the scoring instruments relative to baseline or clinical deterioration caused a patient to be designated as a “nonresponder.” Significantly more patients in the placebo group as compared with the prasterone group failed to achieve responder status based on the SLEDAI or patient’s global assessment values. The latter is particularly noteworthy, in that significant differences in patient’s global assessments, in favor of prasterone, have also been reported in 2 other studies comparing prasterone with placebo (22,24). As noted above, the protocol was amended to incorporate baseline SLEDAI scores of ⬎2 as an additional patient entry requirement while the double-blind study was ongoing. This requirement was based upon the outcome of an earlier Genelabs study, which revealed 2866 that patients with little or no disease activity (SLEDAI ⱕ2) are not the most appropriate candidates for clinical study, since patients with little or no disease activity are likely to exhibit high response rates (23). The importance of requiring minimum disease activity as a criterion for enrollment into SLE clinical trials is consistent with the approach taken in other clinical trials of other rheumatologic conditions. Patients enrolled in this study represented a wide spectrum of SLE disease activity. The differences between treatment groups persisted with increasing baseline disease activity. This observation is similar to the findings in an earlier study assessing steroid-sparing properties of prasterone versus placebo, in which the greatest difference between placebo and prasterone treatment occurred in the groups with baseline SLEDAI scores ⬎8 (23). The 2 instruments that provided the greatest sensitivity to responder analysis appeared to be the SLEDAI and the patient’s global assessment. There were no significant differences between treatment groups in the individual components of the responder analysis, which may reflect the fact that most of the patients were receiving cotreatment with standard SLE therapies. Furthermore, only patients who had had stable disease and no change in treatments for at least 6 weeks prior to entry into the study were eligible for enrollment, and as such, the population we studied primarily comprised those with active, yet stable disease. The responder analysis, however, required simultaneous stabilization or improvement across 4 variables (2 disease activity measurement instruments, 2 health-related quality of life measurements) and no clinical deterioration, while holding cotreatments constant. It is in this composite end point that significant differences occurred between treatment groups. The responder end point was designed to assess simultaneous improvement or stabilization across all 3 domains of lupus: disease activity, organ damage, and health-related quality of life. As such, it was designed to assess a treatment effect on overall lupus disease. While it would be desirable to determine how many patients “improved” or how many “stabilized,” there is no established definition as to what constitutes improvement versus stabilization. Furthermore, due to the stringent responder criteria in this trial, each of the scoring instruments and clinical deterioration was given equal weight in the outcome. So, to improve in only some scoring instruments while worsening in others would deem a patient a “nonresponder.” Thus, we believe that overall stabilization, which is in fact reflective of a combination of improvement in some instruments and PETRI ET AL no worsening in others, is also a successful outcome for lupus patients. Additionally, there were trends toward a lower number of patients with a first flare and a delay in time to disease flare among patients with active SLE who received treatment with prasterone. These findings are qualitatively similar to those reported in a population of Taiwanese women with SLE, almost all of whom were receiving cotreatment with glucocorticoids and/or immunosuppressives. In that study, there was a statistically significant delay in time to disease flare among patients treated with prasterone (24). Administration of prasterone appeared to be well tolerated in this randomized clinical trial. Reported adverse events were predictably related to known pharmacologic effects of androgenic steroids and were generally mild and primarily confined to acne and, to a lesser extent, some hirsutism. While prasterone is a precursor of both androgenic and estrogenic hormones, changes in estradiol levels in patients receiving prasterone were less consistent than changes in testosterone levels. In premenopausal patients, there were no differences in estradiol levels between treatment groups. In postmenopausal women receiving prasterone who were not also receiving HRT, there were modest increases in estradiol levels compared with placebo. During prasterone treatment, mean estradiol concentrations were similar to the mean serum estradiol concentrations observed during transdermal estradiol administration (33) and remained well under the pretreatment baseline estradiol levels observed in SLE patients who were receiving HRT at baseline. Reported adverse events related to estrogenic effects, such as menometrorrhagia, thrombotic events, or weight gain, were not increased in either premenopausal or postmenopausal women receiving prasterone, suggesting that the biologic effects of prasterone are primarily androgenic rather than estrogenic. This is in contrast to postmenopausal women, in whom unopposed estrogen therapy has been associated with a menorrhagia rate as high as 66% (34). Clinical laboratory findings associated with prasterone treatment in this randomized controlled trial also reflected androgenic activity, including declines in HDL cholesterol and triglyceride levels. These findings have also been observed in 2 other controlled studies with prasterone (23,24). Reductions in triglyceride and HDL cholesterol levels with administration of androgenic hormones have been reported to be a manifestation of increased hepatic lipase activity, which results in enhanced clearance of PRASTERONE TREATMENT IN SLE HDL particles (35–37). Thus, the decreases in HDL cholesterol and triglyceride levels may represent increased reverse cholesterol transport (i.e., removal of cholesterol from peripheral tissues via enhanced HDL clearance) rather than decreased production of HDL (38). However, since lupus is associated with increased cardiovascular morbidity and mortality (39) and since long-term studies will be needed to further characterize these effects, it may be prudent to follow the National Cholesterol Education Program guidelines (32) while monitoring lipids in patients who are receiving prasterone. Although the mechanism that results in decreased serum levels of complement C3 levels is incompletely defined, in vitro incubation of human peripheral blood mononuclear cells and bone marrow cells with DHEA has been demonstrated to reduce the production of IL-6 (16,17). Since IL-6 levels are elevated in active SLE (20,40) and can stimulate hepatic secretion of C3 as an acute-phase reactant (41), decreased levels of C3 during prasterone treatment may reflect either a direct or an indirect effect on hepatic C3 production. Decreased serum C3 complement levels were observed during administration of prasterone 200 mg/day to normal premenopausal women who were participating in a preclinical pharmacokinetic/pharmacodynamic study (Genelabs, Inc.: unpublished observations), which is consistent with a physiologic effect of prasterone on hepatic complement production. Serum complement levels also decline modestly without evidence of autoimmunity during testosterone replacement therapy in patients with Klinefelter’s syndrome (42). It is important to note this clinical trial enrolled only adult women with SLE. There are no data from randomized controlled studies of prasterone administration in men or in children with SLE. A previous openlabel clinical trial in a small number of patients in which administration of a synthetic, more-potent androgenic steroid was examined suggested worsening of disease in men with SLE (43). Finally, current therapeutic options are limited for patients with mild-to-moderate active SLE. The available drugs (e.g., nonsteroidal antiinflammatory drugs, antimalarials, glucocorticoids) can manage the disease temporarily in many patients; however, control of the underlying inflammatory disease is often incomplete, and many patients continue to have residual signs and symptoms, with fluctuations in disease activity and with disease flares. In these situations, it is often a major therapeutic step for the physician and patient to contemplate initiation of additional immunosuppressive 2867 agents or large doses of glucocorticoids, which also do not necessarily provide the hoped-for efficacy and are associated with significant side effects. Prasterone could bring benefits to patients who cannot or do not wish to take additional therapies of immunosuppressive agents or large doses of glucocorticoids. Prasterone is not intended, however, to be a replacement for glucocorticoids or immunosuppressive treatments that are needed during acute flares of lupus. In summary, prasterone treatment improved or stabilized overall SLE disease activity in women with mild-to-moderate SLE. The most common adverse events associated with prasterone treatment were androgenic in nature and included acne and hirsutism, which were generally mild and treatable. ACKNOWLEDGMENTS The authors greatly appreciate the advice of, and careful study monitoring by, Karen Colbert and Bettina Sporkenbach. ACRO, Inc. (Morris Plains, NJ) were the statistical consultants for the study. REFERENCES 1. Wallace D. The clinical presentation of systemic lupus erythematosus. In: Wallace DJ, Hahn BH, Quismorio FP Jr, Klinenberg JR, editors. Dubois’ lupus erythematosus. 5th ed. Baltimore: William & Wilkins; 1997. p. 627–33. 2. Lahita RG, Bradlow HL, Kunkel HG, Fishman J. Increased 16 ␣-hydroxylation of estradiol in systemic lupus erythematosus. J Clin Endocrinol Metab 1981;53:174–8. 3. Lahita RG, Kunkel HG, Bradlow HL. Increased oxidation of testosterone in systemic lupus erythematosus. Arthritis Rheum 1983;26:1517–21. 4. Hornsby PJ. Biosynthesis of DHEAS by the human adrenal cortex and its age-related decline. Ann N Y Acad Sci 1995;774:29–46. 5. Labrie F, Belanger A, Simard J, Luu-The V, Labrie C. DHEA and peripheral androgen and estrogen formation: intracinology. Ann N Y Acad Sci 1995;774:16–28. 6. Baulieu E, Corpechot C, Dray F, Emiliozzi R, Lebeau MC, Mauvaus-Jarvis P, et al. An adrenal secreted androgen dehydroisoandrosterone sulfate: its metabolism and a tentative generalization on the metabolism of other steroid conjugates in man. Recent Prog Horm Res 1965;21:411–500. 7. Lahita RG, Bradlow HL, Ginzler E, Pang S, New M. Low plasma androgens in women with systemic lupus erythematosus. Arthritis Rheum 1987;30:241–8. 8. Hedman M, Nilsson E, de la Torre B. Low sulpho-conjugated steroid hormone levels in systemic lupus erythematosus. Clin Exp Rheumatol 1989;7:583–8. 9. Suzuki T, Suzuki N, Daynes RA, Engleman EG. Dehydroepiandrosterone enhances IL-2 production and cytotoxic effector function of human T cells. Clin Immunol Immunopathol 1991;61(2 Pt 1):202–11. 10. Roubinian JR, Papoian R, Talal N. Androgenic hormones modulate autoantibody responses and improve survival in murine lupus. J Clin Invest 1977;59:1066–70. 11. Araneo BA, Woods ML, Daynes RA. Reversal of the immunosenescent phenotype by dehydroepiandrosterone: hormone treat- 2868 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. ment provides an adjuvant effect on the immunization of aged mice with recombinant hepatitis B surface antigen. J Infect Dis 1993;167:830–40. Roubinian J, Talal N, Siiteri PK, Sadakian JA. Sex hormone modulation of autoimmunity in NZB/NZW mice. Arthritis Rheum 1979;22:1162–9. Melez KA, Boegel WA, Steinberg AD. Therapeutic studies in New Zealand mice. VII. Successful androgen treatment of NZB/NZW F1 females of different ages. Arthritis Rheum 1980;23:41–7. Lucas JA, Ahmed SA, Casey ML, MacDonald PC. Prevention of autoantibody formation and prolonged survival in New Zealand black/New Zealand white F1 mice fed dehydroisoandrosterone. J Clin Invest 1985;75:2091–3. Daynes RA, Dudley DJ, Araneo BA. Regulation of murine lymphokine production in vivo. II. Dehydroepiandrosterone is a natural enhancer of interleukin 2 synthesis by helper T cells. Eur J Immunol 1990;20:793–802. Straub RH, Konecna L, Hrach S, Rothe G, Kreutz M, Scholmerich J, et al. Serum dehydroepiandrosterone (DHEA) and DHEA sulfate are negatively correlated with serum interleukin-6 (IL-6), and DHEA inhibits IL-6 secretion from mononuclear cells in man in vitro: possible link between endocrinosenescence and immunosenescence. J Clin Endocrinol Metab 1998;83:2012–7. Gordon CM, LeBoff MS, Glowacki J. Adrenal and gonadal steroids inhibit IL-6 secretion by human marrow cells. Cytokine 2001;16:178–86. Alcocer-Varela J, Alarcon-Segovia D. Decreased production of and response to interleukin-2 by cultured lymphocytes from patients with systemic lupus erythematosus. J Clin Invest 1982;69: 1388–92. Linker-Israeli M, Bakke AC, Kitridou RC, Gendler S, Gillis S, Horwitz DA. Defective production of interleukin 1 and interleukin 2 in patients with systemic lupus erythematosus. J Immunol 1983;130:2651–5. Linker-Israeli M, Deans RJ, Wallace DJ, Prehn J, Ozeri-Chen T, Klinenberg JR. Elevated levels of endogenous IL-6 in systemic lupus erythematosus: a putative role in pathogenesis. J Immunol 1991;147:117–23. Van Vollenhoven RF, Engleman EG, McGuire JL. An open study of dehydroepiandrosterone in systemic lupus erythematosus. Arthritis Rheum 1994;37:1305–10. Van Vollenhoven RF, Engleman EG, McGuire JL. Dehydroepiandrosterone in systemic lupus erythematosus: results of a doubleblind, placebo-controlled, randomized clinical trial. Arthritis Rheum 1995;38:1826–31. Petri MA, Lahita RG, Van Vollenhoven RF, Merrill JT, Schiff M, Ginzler EM, et al, for the GL701 Study Group. Effects of prasterone on corticosteroid requirements of women with systemic lupus erythematosus: a double-blind, randomized, placebo-controlled trial. Arthritis Rheum 2002;46:1820–9. Chang DM, Lan JL, Lin HY, Luo SF. Dehydroepiandrosterone treatment of women with mild-to-moderate systemic lupus erythematosus: a multicenter randomized, double-blind, placebocontrolled trial. Arthritis Rheum 2002;46:2924–7. Tan EM, Cohen AS, Fries JF, Masi AT, McShane DJ, Rothfield NF, et al. The 1982 revised criteria for the classification of systemic lupus erythematosus. Arthritis Rheum 1982;25:1271–7. Liang MH, Socher SA, Larson MG, Schur PH. Reliability and validity of six systems for the clinical assessment of disease activity in systemic lupus erythematosus. Arthritis Rheum 1989;32: 1107–18. Bombardier C, Gladman DD, Urowitz MB, Caron D, Chang DH, and the Committee on Prognosis Studies in SLE. Derivation of the SLEDAI: a disease activity index for lupus patients. Arthritis Rheum 1992;35:630–40. Gladman DD, Urowitz MB, Ong A, Gough J, MacKinnon A. Lack PETRI ET AL 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. 40. 41. 42. 43. of correlation among the 3 outcomes describing SLE: disease activity, damage and quality of life. Clin Exp Rheumatol 1996;14: 305–8. Krupp LB, LaRocca NG, Muir-Nash J, Steinberg AD. The fatigue severity scale: application to patients with multiple sclerosis and systemic lupus erythematosus. Arch Neurol 1989;46:1121–3. Petri M, Hellmann D, Hochberg M. Validity and reliability of lupus activity measures in the routine clinic setting. J Rheumatol 1992;19:53–9. DeLoach LJ, Higgins MS, Caplan AB, Stiff JL. The visual analog scale in the immediate postoperative period: intrasubject variability and correlation with a numeric scale. Anesth Analg 1998;86: 102–6. Expert Panel on Detection, Evaluation, and Treatment of High Blood Cholesterol in Adults. Executive summary of the Third Report of The National Cholesterol Education Program (NCEP) Expert Panel on Detection, Evaluation, and Treatment of High Blood Cholesterol in Adults (Adult Treatment Panel III). JAMA 2001;285:2486–97. Chetkowski RJ, Meldrum DR, Steingold KA, Randle D, Lu JK, Eggena P, et al. Biologic effects of transdermal estradiol. N Engl J Med 1986;314:1615–20. The Writing Group for the Postmenopausal Estrogen/Progestin Interventions (PEPI) Trial. Effects of hormone replacement therapy on endometrial histology in postmenopausal women. JAMA 1996;275:370–5. Haffner SM, Kushwaha RS, Foster DM, Applebaum-Bowden D, Hazzard WR. Studies on the metabolic mechanism of reduced high density lipoproteins during anabolic steroid therapy. Metabolism 1983;32:413–20. Kantor MA, Bianchini A, Bernier D, Sady SP, Thompson PD. Androgens reduce HDL2-cholesterol and increase hepatic triglyceride lipase activity. Med Sci Sports Exerc 1985;17:462–5. Hazzard WR, Haffner SM, Kushwaha RS, Applebaum-Bowden D, Foster DM. Preliminary report: kinetic studies on the modulation of high-density lipoprotein, apolipoprotein, and subfraction metabolism by sex steroids in a postmenopausal woman. Metabolism 1984;33:779–84. Wu FC, Von Eckardstein A. Androgens and coronary artery disease. Endocr Rev 2003;24:183–217. Manzi S, Meilahn EN, Rairie JE, Conte CG, Medsger TA Jr, Jansen-McWilliams L, et al. Age-specific incidence rates of myocardial infarction and angina in women with systemic lupus erythematosus: comparison with the Framingham Study. Am J Epidemiol 1997;145:408–15. Zietz B, Reber T, Oertel M, Gluck T, Scholmerich J, Straub RH. Altered function of the hypothalamic stress axes in patients with moderately active systemic lupus erythematosus. II. Dissociation between androstenedione, cortisol, or dehydroepiandrosterone and interleukin 6 or tumor necrosis factor. J Rheumatol 2000;27: 911–8. Falus A, Rokita H, Walcz E, Brozik M, Hidvegi T, Meretey K. Hormonal regulation of complement biosynthesis in human cell lines. II. Upregulation of the biosynthesis of complement components C3, factor B and C1 inhibitor by interleukin-6 and interleukin-1 in human hepatoma cell line. Mol Immunol 1990;27: 197–201. Yesilova Z, Ozata M, Kocar IH, Turan M, Pekel A, Sengul A, et al. The effects of gonadotropin treatment on the immunological features of male patients with idiopathic hypogonadotropic hypogonadism. J Clin Endocrinol Metab 2000;85:66–70. Lahita RG, Cheng CY, Monder C, Bardin CW. Experience with 19-nortestosterone in the therapy of systemic lupus erythematosus: worsened disease after treatment with 19-nortestosterone in men and lack of improvement in women. J Rheumatol 1992;19:547–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arch 12, 2001 FROM: Claudia B. Karwoski, Pharm.D. Postmarketing Safety Evaluator Team Leader Division of Drug Risk Evaluation I, HFD-430 THROUGH: Julie Beitz, M.D., Director signed 3/13/01 Division of Drug Risk Evaluation I, HFD-430 TO: Jonca Bull, M.D. Acting Director Division of Antiinflammatory, Analgesic, and Ophthalmic Drug Products, HFD-550 SUBJECT: OPDRA Postmarketing Safety Review (PID 000665) Drug: Prasterone NDA 21-239 (Dehydroepiandrosterone-DHEA) Reaction: Summary of Spontaneous Postmarketing Case Reports EXECUTIVE SUMMARY This document provides an overview of postmarketing adverse events reported in association with the use of Dehydroepiandrosterone (DHEA). These cases were retrieved from the Adverse Event Reporting System (AERS), CFSAN’s postmarketing database, and the medical literature. There were 65 postmarketing adverse event cases possibly associated with the use of DHEA. Other than the single report of worsening metastatic prostate cancer1 previously described in the review by Parivash Nourjah, Ph.D, entitled Epidemiologic evidence of DHEA in the etiology of neoplasia, there were no additional reports of neoplasia found in the any of the above databases or the medical literature. Forty-two of the 65 cases fall into the following body systems: urologic/renal (5), reproductive/endocrine (5), cardiovascular (9), gastrointestinal (8), central nervous system (7), dermatological (7), and hematological (2). There were also five individuals with psychiatric adverse events and 17 cases with general symptoms or miscellaneous events that could not easily be categorized into a body system. Four of the 65 cases were published in the medical literature.1-4 Approximately 40% of the cases were concerning. The adverse events involving the urologic/renal, cardiovascular, and gastrointestinal body systems as well as the psychiatric adverse events were particularly concerning because they had the highest number of hospitalizations (> 50%). However, because the overall numbers of cases in each of these body systems were small and in many cases confounded by concomitant or co-suspect medication, we identified no clear safety signals with this product. INTRODUCTION Dehydroepiandrosterone (DHEA) is an endogenous hormone secreted by the adrenal cortex. It has been widely available in the US as a dietary supplement and promoted for its anti-aging effects as well as other uses. Prasterone (the pharmaceutical generic designation for DHEA) is currently under review in the Division of Anti-inflammatory, Analgesic, and Ophthalmic Drug Products (DAAODP), for the treatment of mild to moderate systemic lupus erythematosis (SLE) in women. This serves as a companion document to the review by Parivash Nourjah, Ph.D, entitled Epidemiologic evidence of DHEA in the etiology of neoplasia which focused on a review of the literature for any published epidemiologic studies that examined cancer risk associated with exogenous DHEA administration. The primary objective in this review was to determine if there were any case reports in our postmarketing databases or the medical literature of neoplasia in association with the use of DHEA. Our secondary objective was to provide an overview of postmarketing adverse events reported in association with the use of DHEA REVIEW OF SPONTANEOUS POSTMARKETING REPORTS Selection of Cases We searched AERS on February 13, 2001 for all reports with dehydroepiandrosterone and prasterone. We also requested a query of CFSAN’s adverse event reporting database for case reports with DHEA. Four additional case reports were found in the medical literature. All searches resulted in a total of 64 unique reports involving 68 consumers or patients. Three AERS reports were excluded because the drug products did not appear to contain DHEA. Below is an overall summary and summary by body system of the 65 cases. Summary of Cases Of the 65 cases identified in the AERS database, CFSAN ARMS database, and the medical literature, there was only one report of neoplasia1 . This was summarized in Dr. Nourjah’s review and is described in the urologic/renal section below. Forty-two of the 65 cases fall into the following body systems: urological/renal (5), reproductive/endocrine (5), cardiovascular (9), gastrointestinal (8), central nervous system (7), dermatological (7), and hematological (2). There were also five individuals with psychiatric adverse events and 17 cases with general symptoms or miscellaneous events that could not easily be categorized into a body system. Four of cases were published in the medical literature. 2 Approximately 40% of the cases were concerning. The adverse events involving the urologic/renal, cardiovascular, and gastrointestinal body systems as well as the psychiatric adverse events were particularly concerning because they had the highest number of hospitalizations (> 50%). The concerning cases are briefly summarized below but may be described in greater detail under the specific body system summaries. • • • • Urological/renal system -Literature case of worsening metastatic prostate cancer (1), increased symptoms of prostatism in patients with BPH (2), and renal failure (1). Cardiovascular system - Literature case of cardiac arrhythmia with a positive rechallenge (1), other arrhythmia’s (4), MI (1), DVT (1), and hypertensive urgency (1). Gastrointestinal system– liver failure (1) and hepatitis (3) Psychiatric events – two patients with mania and one patient with psychosis required hospitalization. The overall numbers of cases in each of these body systems were small and in many cases confounded by concomitant or co-suspect medication. 1. Urological and Renal Events There are five cases involving the urologic or renal system. The cases involved all males. The patient’s ages were 5, 34, 68, and 71 years old (not reported-1). The events include resurgence of prostate carcinoma (1), worsening symptoms of prostatism (2), renal failure (1), and dysuria (1). The following additional information was noted in the cases. DHEA daily dose: Time to onset: Outcome: Indications for use: Dechallenge: Rechallenge: Event year: Reporter: 25mg-2, 50mg-1, up to 700mg-1 (not reported-1) 2 to 180 days Emergency room treatment/hospitalization-2, required intervention-3 Short stature-1 Increase muscle strength-1 Low hemoglobin (anemia)-1 Not reported-2 Positive-3 Positive-0 1995-1, 1996-2, 1997-2 Health care professional-3, Consumer-2 The literature case report (described in Dr. Nourjah’s review) involves a 68-year-old male with metastatic prostate cancer who was treated with escalating doses of DHEA (200 to 700mg per day) presumably for the treatment of anemia unresponsive to erythropoetin. His blood cells increased during DHEA eliminating his need for transfusions. However, the patient began to develop facial numbness, increase in prostate size, and difficulty voiding. His PSA levels increased to greater than 10,000 ng/mL (2726 ng/mL prior to DHEA). DHEA was discontinued and DES was initiated with improvement in symptoms and decrease in PSA. Although, he exhibited a positive 3 dechallenge after discontinuation of DHEA, his improvement may have been due to treatment with DES.1 There were two patients with a history of BPH who developed worsening symptoms. One case described increased symptoms of prostatism (not specified) after several months of DHEA. This patient was on Cardura and Dilacor at the time. The second case described difficulty urinating after taking DHEA for two weeks. The renal failure case was reported by the patient’s mother and was not well described. She reported that her 34-year-old son took seven different dietary supplement products (including DHEA) for about one month and developed renal failure. He was hospitalized and partial renal function returned. No additional information was provided. The last case involves a 5-year-old who started bedwetting (coded as dysuria) two days after taking DHEA 50mg per day for central core disease. He was taking many other concomitant dietary products including enzymes, vitamins and atomadine. All products were discontinued and his event abated. 2. Reproductive and Endocrine Events There are five cases involving reproductive or endocrine events in patients ranging in age from 39 to 50 years old (mean-44.7, median-45). The cases involved three males and two females. The events include gynecomastia (1), resumption of menstruation (1), increased estrogen levels and hot flashes (1), hyperglycemia (1), and painful intercourse and hematuria (1). The following additional information was noted in the cases. DHEA daily dose: Time to onset: Outcome: Indications for use: Dechallenge: Rechallenge: Event year: Reporter: 25mg – 3 (not reported-2) 7 days - 1, 30 days - 2, several months -1 (not reported-1) No serious outcomes Menopausal symptoms-1 Immune system booster-1 Aging-1 Not reported-2 Positive-4 Positive-1 1996-3, 1999-1 (not reported-1) Health care professional-4, Consumer-1 None of the cases involved a serious outcome but four sought medical care from a physician. All cases are summarized below for your review. The first three were possibly related to the use of DHEA. Underlying disease and use of another product that was more temporally associated with the event confounded the last two cases. AERS image # 1923242, CFSAN 11859, 1996 A 39-year-old male developed bilateral breast enlargement during use of DHEA 25mg per day for 1 to 1.5 months. They were described as very inflamed, bright red, and very 4 tender. He reported no relevant medical history or concomitant medications. The event reportedly abated after discontinuation of the DHEA. AERS image # 2055734, CFSAN 12028, 1996 A 42-year-old female stated that she had not menstruated since February 1996. In December 1996, seven days after initiating DHEA 25mg per day, she started a full menstrual cycle. AERS image # 2000126, 1997 A male consumer (age unknown) began using DHEA 10mg and then increased to 25mg after 2-3 weeks. Less than 1 month later, he experienced extreme pain during intercourse and observed large amounts of blood in both semen and urine. Urologists ruled out both cancer and STD as causes. He discontinued using the product and one week later his symptoms disappeared. CFSAN 13543, 1999 A 48-year-old female complained of hot flashes. Was taking Rejuvex (for several months) and DHEA (duration unknown). She was status post hysterectomy with one ovary and was not receiving hormone replacement therapy. FSH, LH, and estradiol levels measured were measured and estradiol levels were noted to be markedly elevated 2777 pg/ml. Both products were discontinued for 2 months with levels normalizing (estradiol 54 pg/ml). Rejuvex was restarted and within two weeks the estradiol level was 498 pg/ml. Rejuvex contains several vitamins and ground up bovine endocrine organs. AERS image # 1927333, CFSAN 12220, 1997 A 50-year-old Ethiopian male presented with fatigue, polyuria, and polydipsia and was found to have a blood sugar of 600. He was receiving DHEA 50mg per day for an unknown duration. His DHEA was discontinued and he was started on Glucotrol. With diet management and Glucotrol his blood glucose decreased to low normal and Glucotrol was discontinued. On follow up the reporter mentioned that the patient was subsequently diagnosed with late onset type I diabetes. 3. Cardiovascular Events There are nine cases involving cardiovascular events in patients ranging in age from 23 to 72 years old (mean-44.7, median-45). The cases involved seven males and two females. The events include cardiac arrhythmias in five patients (unspecified-3, PVC’s-1, and SVT-1). The remaining four patients experienced chest pain and palpitations (1), myocardial infarction (1), deep vein thrombosis (1), and hypertensive urgency (1). The following additional information was noted in the cases. DHEA dose: Time to onset: Outcome: Indications for use: 25mg-3, 50mg-2, 100mg-1 (not reported-3) range of 1 to 120 days; mean-49, median 30 (not reported-2) Death-1, hospitalization-3, emergency room-4, required intervention (unspecified)-1 Build muscle mass-1 5 Dechallenge: Rechallenge: Event year: Reporter: Maintain general health-1 Treat decreased adrenal function expected with increased age-1 Not reported-6 Positive-6 Positive-1 1996-1, 1997-4, 1998-2, 1999-1 (not reported-1) Health care professional-8, Consumer-1 Possible cofounders were noted in three cases including the case resulting in death. The death involved a 37-year-old male who was found dead at home. The cause of death was not reported, however the medical examiner inquired whether any of eight dietary supplements could be responsible for a cardiac arrhythmia. One case involved a 72-yearold male who developed a DVT approximately one month after he initiated use of DHEA and DMSO. Both products were listed as suspect. Another case involved a 41-year-old male with a history of increased heart rate who was admitted to the ER for unspecified cardiac arrhythmia 2.5 months after starting DHEA and creatine. The remaining cases reported both a negative cardiac history and no concomitant medication (3) or they did not provide medical history information (3). Several interesting cases are summarized below for your review. Literature Case Report, 1998 A 55-year-old male presented to an ER with palpitations two weeks after initiating DHEA 50mg. Benign premature atrial contractions (PAC) and some premature ventricular contractions (PVC) were noted. Work-up including thyroid-stimulating hormone levels, cardiac echocardiogram, potassium levels, and exercise stress test results were unremarkable. Past medical history was not provided other than his use of Redux for the previous 12 months, which had been discontinued two weeks before initiating DHEA. He was discharged on propranolol and continued use of DHEA for three months. Three to four months later, he reinitiated DHEA (presumably off beta-blocker) and within 36 hours arrhythmias recurred and PAC and PVC was noted on a Holter Monitor. The arrhythmias were controlled with atenolol and DHEA was discontinued.2 AERS Image # 3030083-5-00, direct report, 1997 A 45-year-old male was admitted for an acute MI that occurred during exercise. He received a thrombolytic agent with resolution. Cardiac catherization for recurrent pain showed “fairly normal coronary arteries with only mild irregularities with occluding thrombus in the right coronary artery”. His only reported cardiac risk factor was moderately elevated cholesterol. His cholesterol was 230, HDL 49, and LDL 160. Baseline values were not provided. CFSAN # 12219, direct report, 1997 A 23-year-old male initiated use of DHEA to build up muscle tone. He was reported to have taken up to 20 tablets per day for 3 to 4 months. His mother (nurse) noticed that he had put on over 40 pounds of weight and decided to check his blood pressure, which was found to be in the range of 240/140. His blood pressure was confirmed in the ER. He was also noted to have elevated liver functions tests (LFT). . He was treated for hypertension. 6 Two weeks following discontinuation of DHEA his LFTs appeared to be returning to normal however his blood pressure remained labile. 4. Gastrointestinal System Events There are eight cases involving gastrointestinal system adverse events in patients ranging in age from 21 to 63 years old (mean-41.6, median-43, not reported-3). The cases involved four males and four females. Serious events occurred in five individuals and include liver failure (1), hepatitis (3), abdominal pain requiring exploratory laparotomy, and possible GI bleed (1). Two patients experienced less severe reactions, which include unspecified stomach problems (1) and gas (1). The following additional information was noted in the cases. DHEA daily dose: Time to onset: Outcome: Indications for use: Dechallenge: Rechallenge: Event year: Reporter: 25mg-1, 50mg-1, 200mg-1 (not reported-5) 14 days – 1, 60 days – 1, 11 months - 1 (not reported-5) Hospitalization – 3 (not reported-5) SLE-1 Build muscle-1 Aging-2 Not reported-4 Positive-3 Positive-0 1996-1, 1997-1, 1998-2 (not reported-4) Health care professional-5, Consumer-3 There was one study report of a 36-year-old female with SLE who was hospitalized three times for recurrent abdominal pain. She had been enrolled in a clinical trial for SLE for ~10 months and was receiving DHEA 200mg/day. On her third admission she underwent exploratory laparotomy. The findings were not provided. The report mentioned that she had a history of previous abdominal surgery with possible adhesions. There were three consumer reports. Two did not appear to be serious and only reported gas and “stomach problems. The third consumer claimed that she experienced vomiting with blood and blood per rectum for five days. She did not mention seeking medical treatment. There were four liver related events. One physician reported two of the cases. He reported a 43-year-old female and a 45-year-old male who developed hepatitis while taking an unknown dose of DHEA. Neither of the reports were well documented other than stating that neither patient had a relevant medical history nor were they taking concomitant OTC medications. In both of the other two cases, concomitant medications might have played a role. These cases are described below for your review. AERS image # 3193812-6-00 , 1998 A 21-year-old male experienced cold symptoms for 1-2 weeks and began taking acetaminophen 1-2 q4-6h prn (6-10gm). He was a wrestler and was taking DHEA 50mg 7 per day for approximately 2-3 months prior to the event. He had 8 beers/5 shots x 3 days w/APAP. Within two weeks he developed RUQ pain, dark urine, jaundice, and was admitted with hepatic failure. Underwent liver transplant. Although acetaminophen possibly in conjunction with alcohol are suspect, the role of DHEA cannot be dismissed. CFSAN # 13200, 1998 A 63-year-old male was diagnosed with cholestatic hepatitis while taking an unknown dose of DHEA and Pantothenic Acid 8gm/day. This was discovered during blood donation. He presented with elevated ammonia, transaminases, bilirubin, and PT/INR. All viral hepatitis screening was negative. He was hospitalized for two days neurologically intact. No additional information was provided. The pantothenic dose was > 1000 times the recommended daily allowance for adults. 5. Central Nervous System Events There are seven cases involving central nervous system events in patients ranging in age from 49 to 59 years old (mean-54.2, median-56, not reported-2). The cases involved four males and three females. Serious events occurred in three individuals and include transient ischemic attack (1), seizure (1), and sensory peripheral neuropathy (1). The remaining four patients experienced less severe reactions which include headaches (2), numbness (1), and sleepiness (1). The following additional information was noted in the cases. DHEA dose: Time to onset: Outcome: Indications for use: Dechallenge: Rechallenge: Event year: Reporter: 25mg-3, 50mg-1, 100mg-1 (not reported-2) range of 3 to 90 days; mean-35, median-7 (not reported-2) Hospitalization-1, disability-1, saw physician-3, (not reported-2) Maintain general health-1 Muscle pain-1 Entered study (Hormone Replacement Program)-1 Not reported-4 Positive-3 Positive-2 1997-3, 1998-1, 1999-1, 2000-1 (not reported-1) Health care professional-2, Consumer-5 The four cases involving headache, numbness, and sleepiness did not appear to be serious. In one case a mother reported an event (described in Psychiatric Adverse Event section of this document) in her son but also mentioned that she experienced migraine headaches while taking DHEA. One patient experienced numbness, coldness, and tingling of her face, scalp, and neck. Her neurological exam however was found to be normal. There were three serious cases involving seizure, TIA, and Sensory Peripheral Polyneuropathy. The case involving seizure exhibited a positive rechallenge and did not appear to be confounded by past medical history or concomitant medication. Consumers reported two cases and in one case the event appeared to be more temporally related to 8 the concomitant use of another product. These cases are summarized below for your review. AERS image # 20411530, CFSAN # 12603, 1997 A 51-year-old male reported having a TIA approximately two weeks after starting DHEA 25mg per day. He was diagnosed and hospitalized for three days. According to report, he underwent numerous tests which were negative (CT, MRI, ECG, and EEG) CFSAN # 13160, 1998 A 56-year-old male had taken DHEA for three months and experienced two seizures during that time. He discontinued use for several months and then restarted and experienced a seizure after seven days. His past medical history and concomitant medications were not reported. An EEG, MRI and exam were found to be normal. AERS image # 3551903-1-00, 2000 A 49-year-old male reported enrolling in a Hormone Replacement Program offered by the[ ]. As part of the program, he began taking DHEA 50mg per day, desiccated thyroid (Armour, 1gm per day), melatonin, B complex, testosterone cream, and human growth hormone (HGH) injections (4IU per week). After one month, he started to experience numbness in both feet. He discontinued use of the HGH for a few weeks and the problem disappeared. He restarted the injections and the numbness and pain came back. A second discontinuation did not result in resolution of his symptoms. He was diagnosed with Sensory Peripheral Polyneuropathy and reported that he was partially disabled (difficulty walking, pain interrupts sleep). 6. Dermatological Events There are seven cases involving dermatological reactions in patients ranging in age from 29 to 83 years old (mean-58.2, median-62, not reported-1). The cases involved four males and three females. The events include rash in four patients (unspecified-3, macular erythematous eruption-1). The remaining three patients experienced alopecia (2), and acne with pustules (1). The following additional information was noted in the cases. DHEA dose: Time to onset: Outcome: Indications for use: Dechallenge: Rechallenge: Event year: Reporter: 25mg-1, 50mg-3 (not reported-3) range of 4 to 55 days; mean-14.4, median 14 (not reported-2) Required (unspecified) intervention-1, saw physician-1 (not reported-5) Aging-1 Hormone deficiency-1 Impotence-1 Not reported-4 Positive-3 Positive-0 1995-1, 1997-3 (not reported-3) Health care professional-4, Consumer-3 9 None of these cases reported a serious outcome as a result of the events. One case is summarized below for your review. AERS image # 1933056, CFSAN # 12099, 1997 An 83-year-old male developed a macular erythematous eruption from the mid-thigh to his toes varying in diameter from 1mm to 1cm approximately seven weeks after starting DHEA. They were non-tender with no subcutaneous hemorrhage. The rest of the physical exam was normal. He was on concomitant Nicotine patches intermittently for 18 months. The rash reportedly began to fade after the DHEA was discontinued. 7. Hematological Events There were two individuals that experienced hematological events. One case involves a 50-year-old male that presented with fever, cough, malaise, and aching approximately six weeks after starting DHEA 50mg per day. A complete blood count revealed a platelet count of 38K. DHEA was discontinued and a repeat CBC two and three weeks later was 69K and 122K, respectively. The patient did not appear to require hospitalization. He had a history of chronic low platelets secondary to a splenectomy. He also reported receiving a flu shot 1week prior to symptoms. The second case involves a 46-year-old male who started taking DHEA 50mg BID on 4/14/99 and Celebrex 100mg BID on 4/26/99. On 5/3/99, he presented to his physician with bruising all over his chest, arms, and legs. He had not sustained any trauma. Celebrex was discontinued but it is unclear if DHEA was continued. No further information was provided. 8. Psychiatric Events There are five individuals who experienced psychiatric events while receiving DHEA. Two of these cases were reported in the medical literature. The cases involved individuals ranging in age from 20 to 68 years old (mean 36.6, median-51). The cases involved three males and one female (not reported-1). The events include mania (2), manic depression (1), psychosis (1), and panic attacks (1). The following additional information was noted in the cases. DHEA daily dose: Time to onset: Outcome: Indications for use: Dechallenge: Event year: Reporter: 25mg-1, 50mg-1, 150mg-1, 200-300mg-1 (not reported-1) range of 40 to 120 days; (not reported-1) Hospitalization-3 General health-1 Impotence-1 To increase energy-1 Not reported-2 Positive-2 1996-1, 1998-1, 1999-1 (not reported-2) Health care professional-3, Consumer-2 10 All cases were confounded by either concomitant medication or other dietary products (3) and/or past psychiatric history (3). In one, the individual was taking five different dietary supplements including ephedrine and ephedra. A second was taking concomitant beef liver extract and a multivitamin. Another report listed Celexa as a co-suspect agent. Past psychiatry histories include history of panic attacks, history of manic depression, and history of daily alcohol consumption (possible alcoholism). Both literature reports is described below for your review. Literature Case Report, 1999 A 68-year-old male with no documented psychiatric history was admitted to an inpatient psychiatric hospital after his family members noting increasingly odd behavior. Symptoms included agitation, delusional thinking, decreased sleep and appetite, and spending sprees which started approximately three months prior to admission. He had begun taking DHEA six months prior to admission at dose of 100mg daily. This dose was increased to 200-300mg per day. He had a history of daily alcohol use as much as one case of beer. On admission his use was said to be ~ two beers per day. Drug and urine screens were negative. He was treated with valproic acid and his symptoms improved. He was discharged seven days later.3 Literature Case Report, 1999 A 51-year-old male with no prior psychiatric history was involuntarily hospitalized because of grandiose delusions, expansive and irritable mood, and extreme psychomotor agitation. He had begun taking DHEA 50mg per day several months earlier to increase his energy level. He was also taking beef liver extract and a multivitamin. The severity of his psychosis necessitated the appointment of a temporary personal guardian. He was treated during his hospitalization with a combination of haloperidol and divaproex. He responded well and his symptoms disappeared after several weeks. 4 9. General Symptoms or Miscellaneous Adverse Events There are 17 individuals who experienced general symptoms or miscellaneous events that could not easily be categorized into one organ system. The cases involved individuals ranging in age from 28 to 84 years old (mean-49.5, median-47, not reported-4). The cases involved nine males and six females (not reported-2). The following additional information was noted in the cases. DHEA dose: Time to onset: Outcome: Indications for use: Dechallenge: 25mg-3, 35mg-1, 50mg-5, overdose-1 (not reported-7) range of 1 day to 1.5 years; mean-98, median 5 (not reported-4) Hospitalization/ER-3, life-threatening-1, saw physician-3, required unspecified intervention-2 (not reported-8) Aging/to stay young-4 Maintain general health-2 Headache-1 Hormone supplement-1 Not reported-9 Positive-12, negative-1 11 Rechallenge: Event year: Reporter: Positive-1 1996-4, 1997-6, 1998-1 (not reported-6) Health care professional-10, Consumer-7 Overall most cases were not well documented. One interesting case involves a 41-yearold female who reports taking DHEA 25mg sublingually. After 2 weeks she developed a benign submandibular tumor. She stopped taking the product for 1 week and the tumor reduced in size. She took the product again orally and the tumor returned. There were four patients that reported requiring hospitalization, emergency room treatment, and/or reported the event as life-threatening. One involved a female (who spoke little English) who may have taken an entire bottle of DHEA for a headache. She was hospitalized with a low-grade temperature and a low blood pressure (100/50). One patient reportedly developed an anaphylactic reaction after taking one dose of DHEA 50mg. She was given epinephrine and Benadryl with good results. An elderly male listed numerous subjective “serious” adverse events to a single dose of DHEA that he reported as life threatening and requiring hospitalization. His physician noted that he has a history of reporting drug reactions. The reactions include weakness, fatigue, ataxia, insomnia, decreased appetite, SOB, rapid heart rate, and sensation of doom. The last involves a 60year-old male with severe HTN who became hypokalemic and syncopal after four days of DHEA. This was reported life threatening, however no additional information was provided. The remaining cases listed numerous adverse events that in most cases did not appear to be serious and generally resulted only in discontinuation of DHEA and/or other products. These events include weakness, insomnia, headache, CP, indigestion, constipation, tremors, dizziness, fainting spells, depression, muscle cramps, nightmares, guilt feelings, shortness of breath, weight gain, swelling of neck, malaise, memory loss, arm numbness, venous distension, chest heaviness, tinnitus, possible drug interaction, feet tingling, tachycardia, and hyperactivity. CONCLUSIONS There were 65 postmarketing adverse event cases possibly associated with the use of DHEA. Other than the single report of worsening metastatic prostate cancer previously described in the review by Parivash Nourjah, Ph.D, entitled Epidemiologic evidence of DHEA in the etiology of neoplasia, there were no additional reports of neoplasia found in the any of the above databases or the medical literature. Forty-two of the 65 cases fall into the following body systems: urologic/renal (5), reproductive/endocrine (5), cardiovascular (9), gastrointestinal (8), central nervous system (7), dermatological (7), and hematological (2). There were also five individuals with psychiatric adverse events and 17 cases with general symptoms or miscellaneous events that could not easily be categorized into a body system. Four cases were published in the medical literature. 12 Approximately 40% of the cases were concerning. The urologic/renal, cardiovascular, gastrointestinal, and psychiatric adverse events were particularly concerning because they had the highest number of hospitalizations (> 50%). However, because the overall numbers of cases in each of these body systems were small and in many cases confounded by concomitant or co-suspect medication, we identified no clear safety signals with this product. REFERENCES 1. 2. 3. 4. Jones J.A., Nguyen A., Straub M, Leidich R, Veech R.L., and Wolf S. Use of DHEA in patient with advanced prostate cancer: a case report and review. Urology 1997; 50:784-8. Sahelian R, Borken S. Dehydroepiandrosterone and cardiac arrhythmia. Ann Intern Med 1998; 129(7): 588. Markowitz JS, Carson WH, Jackson CW. Possible dihydroepiandrosteroneinduced mania. Biol Psychiatry 1999; 45(2): 241-2. Kline MD, Jaggers ED. Mania onset while using dehydroepiandrosterone. Am J Psychiatry 1999; 156(6): 971. Signed _3/12/01______________________ Claudia B. Karwoski, Pharm.D. 13 Scientific Verdict Still Out PERHAPS NO drug better illustrates the problem with the US Dietary Supplement Health and Education Act of 1994 than does the adrenal hormone dehy-$ droepiandrosterone (DHEA). Although mounting evidence suggests that DHEA may have a broad range of clinical uses, the long-term effects of the substance are unknown. But that hasn't prevented the creation of a large and growing market for what many are calling a miraculous "Fountain of Youth." DHEA has become the latest drug of choice for talk shows and reports in the print and broadcast media, where it is being touted as an "antidote for aging" and a "superhormone" that can help burn fat, build muscle mass, boost libido, strengthen the immune system, prevent heart disease, cancer, and non\p=m-\insulin-$ dependent diabetes, retard memory loss, help in the treatment of systemic lupus erythematosus, and prevent or slow the progression of Alzheimer and Parkinson diseases. All this, despite the fact that not one of these benefits has yet been demonstrated in a large randomized placebocontrolled clinical trial. What's more, some animal and epidemiologie studies suggest that higher serum levels of the hormone may be associated with in¬ creased risk for ovarian and perhaps prostate or other types of cancers. Fulfilling the intent of many of its sup¬ porters, the US Dietary Supplement Health and Education Act of 1994 has partially short-circuited the nation's drug developing and testing system. The law allows a wide variety of substances to be sold for human consumption without ap¬ proval from the Food and Drug Admin¬ istration (FDA), as long as they are sold as "dietary supplements" and the prod¬ uct labeling includes no "drug intent." "This whole thing has gotten out of hand," says Arthur Schwartz, PhD, pro¬ fessor of microbiology, Fels Institute for Cancer Research and Molecular Biology, Temple University School of Medicine, Philadelphia, Pa. "There's no evidence that this hormone is found in any food— unless, of course, you consider primate adrenal glands food. So why is it being sold as a food supplement? This is as crazy as health food stores being allowed to sell cortisone supplements." Schwartz, a pioneer in DHEA research, has begun to speak out against the media hype, in part because his name and re- on search are being used deceptively to sell DHEA to the public, he says. For ex¬ ample, the Web page on the Internet for Life Plus Vitamins promotes its own brand of DHEA with the following claim: "Dr. A. Schwartz, a researcher at Temple Uni¬ versity, has now proven beyond question, DHEA's effectiveness in weight control." "That's totally false," says Schwartz, who has been studying the metabolic effects of DHEA since the 1970s. "No human data exist whatsoever that show DHEA can help a person lose weight. Rodent studies show some type of antiobesity effect, but its mechanism is still not known." What is known is that mice and rats are not humans; circulating DHEA se¬ rum levels in rodents are about 5 orders of magnitude lower than levels in hu¬ mans and other primates, he says. To produce weight loss, rodents must be given high doses of hormones that are known to be androgenic in humans. The low doses that many people are now taking as supplements (25 to 50 mg/d, which is sufficient to raise serum levels in the elderly to levels normally found in young adults) probably are not andro¬ genic, he adds, but they probably are not very effective either. According to Schwartz, the health food industry, with the help of some physi¬ cians, is exposing large numbers of people to a drug whose long-term ef¬ fects are unknown. In addition, virtu¬ ally nothing is known about DHEA's interactions with other drugs. 'Call of the Hucksters' Schwartz's concerns are shared by many of his colleagues who took part in the international conference, Dehydroepiandrosterone (DHEA) and Aging, in Washington, DC, June 17-19, 1995. Al¬ though speakers at the conference, which was sponsored by the New York Acad¬ emy of Sciences, spoke optimistically about the many potential clinical uses for DHEA, they also urged caution in promoting or prescribing the drug to the public until much more is known about the hormone's long-term effects. In his introduction to Dehydroepiandrosterone (DHEA) and Aging: An¬ nals of the New York Academy of Sci¬ ences (1995;774:ix-xi), an editor of the Annals volume and conference orga¬ nizer, John E. Nestler, MD, Division of Endocrinology and Metabolism, Medi- DHEA cal College of Virginia, Richmond, told how DHEA for many years had the repu¬ tation of a "snake oil" because of the overzealous way some scientists had been promoting it. "One can almost hear the hucksters calling out: 'Come get your DHEA, come get your Fountain of Youth. Cures all" that ails you. Helps you live forever,' Nestler wrote. "DHEA was reputed to remedy almost any bodily ill, even though evidence for the beneficial effects of DHEA in humans was virtually nonex¬ istent and its cellular or molecular mechanism(s) of action remained a mystery. Be¬ cause ofthis nefarious reputation, DHEA research was regarded by many as a du¬ bious, or at best, avant garde adventure." According to Nestler, some physicians unjustifiably dispensing DHEA "in a are cavalier fashion for almost any indica¬ tion. Although the results of human DHEA studies appear promising and tan¬ talizing, as evidenced by the reports in this volume of the Annals, they need to be confirmed in large-scale and properly controlled studies. A beneficial effect of DHEA administration in humans has not yet been firmly established, and we know virtually nothing about the side-effect profile of chronic DHEA administration. Without confirmed beneficial actions in humans and a better understanding of associated risks, it does not seem rea¬ sonable to dispense DHEA." However, many in addition to physi¬ cians now are prescribing and dispens¬ ing DHEA. Advertisements in newspa¬ pers and magazines and on the Internet are promoting and offering the "anti¬ dote to aging" directly to the public. "If you are searching for the Fountain of Youth, DHEA is a must" says one such article recently posted to the Internet newsgroup, misc.health.alternative. The article promotes a "colloidal" form of DHEA called "LiquidLightning MetaD-10" and claims that DHEA's "cogni¬ tion-enhancing benefits for Alzheimer's and Parkinson's patients have been proven in clinical studies." Other advertisements are recruiting people to join in multilevel marketing of DHEA with promises of a "faster, surer way to wealth." One company's DHEA Internet web page is illustrated with 4 photographs across the page: a table full of fruits and vegetables, captioned "The Problem" (the "nutrient" DHEA is not found in foods); a bottle of one of the ... Downloaded from jama.ama-assn.org at Overlook Hospital Library on March 28, 2011 company's nutritional supplements, captioned "The Solution;" a white-smocked man holding a bottle of the supplements, captioned "The Creator;" and a fist full of $20 bills, captioned "The Opportu¬ nity." The usual retail price for a month's supply of DHEA in 25-mg to 50-mg daily doses is approximately $15. What Is DHEA? The hormone is made in exceptionally large quantities as the sulfated form (DHEAS) by the adrenal cortex only in primates and a few nonprimate species. Only humans and apes show the curious life pattern of having very high prenatal serum levels of DHEA and DHEAS that drop to virtually none after birth, then rise sharply at puberty and reach very high levels during young adulthood, and finally drop progressively until only neg¬ ligible levels are left in old age. While the average serum level of DHEAS in men 25 to 34 years of age ranges around 6.44±2.29 µ ß/ , it falls to 1.15±0.52 µ 1ß/ in men age 75 to 84 years, and DHEA serum levels fall from 15.91 ±6.05 nmol/L to 5.36+1.68 nmol/L (Dehyroepiandrosterone (DHEA) and Aging: Annals of the New York Acad¬ emy of Sciences. 1995:774:121-127). The decline rate for both DHEA and DHEAS is relatively constant at about 2% per year. Most studies show that the levels in young women are 10% to 30% lower than in young men, but the sex differ¬ ences appear to decline with age. The hormone is a universal precursor of a number of androgenic and estrogenie products that are made by periph¬ eral tissues to supply local requirements, says Fernand Labrie, MD, PhD. Labrie, at Le Centre Hospitalier de l'Université Laval (Quebec), CHUL Research Cen¬ ter, has introduced the term "intracrinology" to describe how individual tis¬ sues use a series of DHE A-metabolizing enzymes to transform the precursor hor¬ mone into much more physiologically ac¬ tive sex steroids. Speaking at the New York Academy of Sciences conference, Labrie estimated that "30% to 50% of total androgens in men are synthesized in peripheral intracrine tissues from inactive adrenal pre¬ cursors, whereas in women, peripheral estrogen formation is even more impor¬ tant. Intracrinology represents an eco¬ nomical system which requires minimal amounts of hormone to exert maximal function. In classic endocrine systems, large amounts of hormones are needed with only a small fraction used for regu¬ lation while the rest is degraded." A recent groundswell in human DHEA-related research suggests that the hormone may have a wide variety of therapeutic applications, says Nestler: "Given the diverse nature of DHEA's putative biologic actions, it seems likely that several independent mechanisms for DHEA action may be operative." Among the research reported at the conference was a pilot study that sug¬ gests DHEA may improve mood, en¬ ergy, libido, and, in some cases, memory performance in the elderly. In the openlabel study, 3 men and 3 women 51 to 72 years of age, who had major depression as defined by the American Psychiatric Association's Diagnostic and Statisti¬ cal Manual of Mental Disorders, Third Edition, and low basal serum levels of DHEA, were given 30 mg to 90 mg of DHEA a day orally for 4 weeks, said Owen M. Wolkowitz, MD, Department of Psychiatry, University of California, San Francisco. He and colleagues evalu¬ ated patients weekly using the 21-item Hamilton Depression Rating Scale, Beck Depression Inventory, Symptom Check¬ list 90, and Bunny-Hamburg Global De¬ pression Rating, along with a test of verbal memory. All of the depression evaluations showed significant improve¬ ment during treatment, which returned to baseline after the treatment was gradually withdrawn. One of the 6 pa¬ tients was treated for 5 additional months with an increase in DHEA dos¬ age after 4 months. Improvement in her depression was found to be dose related. "These preliminary results raise the possibility that age- and/or illness-asso¬ ciated decreases in circulating DHEA and DHEAS levels in depressed patients may be pathophysiologically relevant and are amenable to pharmacologie treatment," Wolkowitz reports. Larger, double-blind, placebo-controlled trials are under way. Research by Etienne-Emile Baulieu, MD, INSERM, Le Kremlin-Bicetre, France, and colleagues presented at the conference suggests that DHEA is a neuroactive neurosteroid that has multiple pharmacologie effects on the nervous sys¬ tem. These investigators are calling for trials aimed at offsetting the profound decrease in DHEA serum levels in the elderly. "The nervous system is one of the most important potential targets of the prospective trials under consider¬ ation," Baulieu said. "Experimental data on the control of mood changes and re¬ inforcement of memory storage, com¬ bined with clinical evidence of DHEA activity on the nervous system in vivo in humans, based on electroencephalographic data, are very encouraging." Boosting the Immune System Evidence that DHEA may be an ef¬ fective vaccine adjuvant for elderly pa¬ tients was presented by Barbara A. Araneo, PhD, University of Utah School of Medicine Department of Pathology, Salt Lake City, and colleagues. Attempts to vaccinate elderly patients with antigens to which they have never been exposed often result in failure to elicit the desired immune response. In contrast, immune responses are usually induced more reliably when the anti¬ gens have been previously encountered. This suggests that immunologie memory remains intact during the aging process, Araneo and colleagues said. The researchers reported the results of 2 double-blind, randomized, placebocontrolled clinical studies that tested the adjuvant potential of DHEAS. In one study, elderly volunteers were vacci¬ nated with tetanus toxoid (to elicit an antigen recall response). In the other, the volunteers received the 1994-1995 licensed trivalent influenza vaccine (to elicit a primary response). The tetanus study involved 66 men over age 65 years, of whom 36 received placebo and 30 received DHEAS. The hormone appeared to have no significant adjuvant effect or a detrimental effect on the outcome of tetanus immunization. In the influenza vaccine study, 67 el¬ derly men and women were given placebo or 50 mg of DHEAS orally for 2 consecu¬ tive days starting on the day of vaccina¬ tion. Serum samples were collected the day before the first drug dose and 28 days and 90 days after vaccination. The re¬ searchers found that significantly more of the volunteers who had a 4-fold increase in influenza hemagglutination inhibition (HAI) titers after vaccination had been given DHEAS compared with those given placebo, and the overall increase in HAI titers was highest in the DHE AS-treated group. They conclude that further studies should justify the use of DHEAS as an adjuvant for antigens that represent pri¬ mary responses in the elderly. Preventing Heart Disease? Some epidemiologie studies have found association between low DHEA se¬ levels and heart disease and some have not. At the conference, Elizabeth Barrett-Connor, MD, and Deborah Goodman-Gruen, MD, Department of Family and Preventive Medicine, University of California, San Diego, School of Medi¬ cine, La Jolla, updated what they say is the only prospective community-based study of the association of natural DHEAS serum levels and fatal cardio¬ vascular disease outcomes in men and women. The 19-year follow-up study of 1029 men aged 30 to 82 years and 942 women aged 50 to 88 years showed a statistically significant, modestly reduced risk of death from cardiovascular disease (relative risk [RR]=0.85) in men who had higher DHEAS serum levels, but a nonan rum Downloaded from jama.ama-assn.org at Overlook Hospital Library on March 28, 2011 significant increased risk of fatal cardio¬ vascular disease (RR=1.11) in women with higher levels. David M. Herrington, MD, MHS, Di¬ vision of Cardiology, Bowman Gray School of Medicine, Winston-Salem, NC, reported on 2 studies that looked at DHEA and DHEAS plasma levels in patients undergoing elective coronary angiography and in a group of cardiac transplant patients at risk for acceler¬ ated cardiac allograft vasculopathy. Tis¬ sue culture, animal studies, and epide¬ miologie studies suggest that DHEA may inhibit atherosclerosis through its potent antiproliferative effects. The re¬ sults of his study support those find¬ ings: their data "suggest that low plasma levels of DHEA may facilitate, and high levels may retard, the development of coronary atherosclerosis and coronary allograft vasculopathy," Herrington says. "These observations are consistent with our understanding of coronary athero¬ sclerosis as a complex multifactorial dis¬ ease process in which DHEA may play a small but important role." The findings of a clinical study by Robert L. Jesse, MD, Division of Car¬ diology, Medical College of Virginia, Richmond, suggest that DHEA inhibits platelet aggregation. In a study of 10 healthy men aged 23 to 35 years, 5 were given placebo and 5 received 300 mg of DHEA 3 times a day for 14 days. The rate of platelet aggregation did not change in any of the placebo group, but was prolonged in 4 of the 5 in the DHE Atreated group. In 1 of the 4, platelet aggregation was inhibited completely. None of the men reported any adverse effects while taking DHEA and none was able to tell if he was taking DHEA or the placebo. "Inhibition of platelet activity by DHEA may contribute to the putative antiatherogenic and cardioprotective effects of DHEA," Jesse concludes. Insulin Sensitivity and Lupus Some researchers believe that DHEA may protect against non-insulin-depen¬ dent diabetes. In a 3-week, randomized, double-blind, placebo-controlled trial of 15 postmenopausal women, Gordon Wright Bates, Jr, MD, then at the De¬ partment of Obstetrics and Gynecology, University of Tennessee, Memphis, and colleagues at Baylor College of Medicine, Houston, Tex, found that insulin sensi¬ tivity was significantly (P=.04) enhanced in women given 50 mg of DHEA a day compared with women receiving placebo. "Whether this effect is reproducible in larger studies remains to be determined. If DHEA supplementation in aged sub¬ jects enhances insulin sensitivity, DHEA replacement may help attenuate age-re- lated increases in insulin resistance," the investigators conclude. Other possible therapeutic uses of DHEA have been reported elsewhere. For example, a study found that the hor¬ mone may help patients with systemic lupus erythematosus (Arthritis Rheum. 1994;37:1305-1310). Not surprisingly, such reports have whetted the interest of re¬ searchers in studying—and the appetite of the public for buying—this latest "in" drug. In a commentary (Lancet. 1995; 345:1193-1194), Joe Herbert, MD, Cam¬ bridge Centre for Brain Repair, Univer¬ sity of Cambridge in England, says, "Enough is known or suspected to war¬ rant investigation of DHEA(S) as an effective, worthwhile, and relatively riskfree replacement therapy in advancing age. This can only be done by a controlled prospective trial of DHEA treatment; no amount of correlational evidence, how¬ ever carefully collected, is enough." The FDA's Position "The FDA hasn't formally reviewed the data concerning DHEA," said Rob¬ ert Moore, PhD, senior regulatory sci¬ entist in the agency's Office of Special Nutritionals, Washington, DC, in an in¬ terview. "We would advise physicians to recognize that this substance isn't an approved drug for any indication." The FDA in 1985 responded to the first wave of Fountain of Youth fever over DHEA by prohibiting over-the-counter sales of the drug. That ban was ended by passage of the health food industrybacked Dietary Supplement Health and Education Act of 1994. The law shifted the burden onto the FDA to prove that a nutritional supplement is harmful be¬ fore the agency could regulate its sale. As a result, many powerful and poten¬ tially dangerous drugs can now be mar¬ keted as nutritional supplements with¬ out proof of safety or efficacy. "Physicians need to routinely ask their patients about the food supplements they are taking," says Moore. "That's the only way we can find out if there are ad¬ verse reactions to the supplements." Without being asked, people who think of supplements as "natural"—and there¬ fore harmless—are not going to men¬ tion taking them to their physicians. Phy¬ sicians should report all suspect adverse reactions to any dietary supplement to the FDA's MEDWatch program by call¬ ing (800) FDA-1088. Other Caveats Some evidence exists that justifies con¬ cern about the safety of DHEA supple¬ ments. According to Nestler, there has been at least one published report of tran¬ sient hepatitis associated with DHEA use by a woman. Large doses of DHEA can be converted to potent androgens, such can masculinize While the effects of DHEA on the development or promotion of pros¬ tate cancer are unknown, there is evi¬ dence to suggest that DHEA may in¬ crease some women's risk for ovarian cancer. In a nested, case-control prospec¬ tive study of serum samples collected from more than 20 000 residents of Washing¬ ton County, Maryland, Kathy J. Helzlsouer, MD, Department of Oncology, Johns Hopkins University School of Medi¬ cine, Baltimore, Md, found that the risk of ovarian cancer was associated with in¬ creased levels of DHEA and DHEAS as testosterone, which women. (JAMA. 1995;274:1926-1930). If people are going to take DHEA, they should do so as part of a clinical trial so that its risks and benefits can be followed, says Temple's Schwartz. At the very least, no one should take this drug without his or her physician's knowledge. It would be unwise for people younger than 30 years to take DHEA because the supplements might suppress the body's natural pro¬ duction of the hormone. If used at all, it should be used as a replacement therapy in older people whose serum DHEA lev¬ els have declined substantially. Some experts recommend that DHEA serum level be measured before a per¬ son takes supplements. Patients also should be informed that they are not going to boost their DHEA levels with Mexican yam (Dioscorea mexicana) or wild yam (Dioscorea villosa) products that are being touted as containing natu¬ ral precursors for the body's production of the hormone, says Schwartz. John Renner, MD, clinical professor of family medicine, University of Missouri, Kansas City, School of Medicine and president of Consumer Health Informa¬ tion Research Institute, also recommends that people not take DHEA on their own. Recalling that impurities in tryptophan— the superstar food supplement of a few years ago—led to a number of deaths and hundreds of cases of eosinophiliamyalgia syndrome, Renner notes that there is still no governmental regulation of the potency and purity of so-called nutritional supplements. "If people do take it, then I recom¬ mend that they keep track of the batch number by saving the original bottle along with the last 5 pills and that they store it in a cool dark place," Renner says. Asked how long the samples should be kept, he said, "Until the legal statute of liability runs out." He also recom¬ mends against buying from a mail order establishment or from any fly-by-night operation. "Buy it from a large health food chain that can afford to be sued in case of adverse reactions," he says. \p=m-\byAndrew A. Skolnick Downloaded from jama.ama-assn.org at Overlook Hospital Library on March 28, 2011 HIGHLIGHTS OF PRESCRIBING INFORMATION These highlights do not include all the information needed to use PRASTERA® safely and effectively. See full prescribing information for PRASTERA®. PRASTERA® prasterone oral softgels 200mg are for oral use only. INDICATIONS AND USAGE PRASTERA® prasterone 200 mg oral softgels is a medical food indicated in female patients with mild to moderate, active (SLEDAI >2) systemic lupus erythematosus (SLE) to restore serum 5-dehydroandrosterone sulfate to levels typical of women without SLE. In Phase III clinical trials in female patients with mild to moderate active SLE, prasterone 200 mg was associated with reduced risk of auto-immune flare. (§§1, 6.2, 6.4, 6.5) DOSAGE AND ADMINISTRATION The recommended dose is one (1) softgel daily. (§2) DOSAGE FORMS AND STRENGTHS 200mg oral softgel capsules supplied in a convenience package with ibuprofen oral tablets 300mg. (§3) • • • • • • • • • • CONTRAINDICATIONS Known hypersensitivity to any of its ingredients. (§4) Undiagnosed abnormal genital bleeding. (§4) Known, suspected or history of breast cancer. (§4, §6.5) History of, or known, deep vein thrombosis, pulmonary embolism, arterial thromboembolic disease (e.g., stroke, myocardial infarction). (§4) Hypercholesterolemia or ischemic heart disease. (§4, §7.2.4) Hepatic or renal impairment (pharmacokinetic data lacking). (§4, §7.2) Breast-feeding or known or suspected pregnancy. (§4) History of psychiatric disorder. (§4, §8) • • PRASTERA® may in certain patients elevate serum levels of 5-dehydroepiandrosterone, testosterone or estrogen above the normal range for healthy, non-afflicted women of similar age. Periodic measurement of serum hormones is prudent. (§7.2.1) Hypertension may occur with prasterone treatment. Monitor blood pressure closely. (§6.3.2) ADVERSE REACTIONS The most common adverse event with PRASTERA® is acne. This is generally treatable with topical anti-acne medication. (§6.1) Another common adverse reaction is hirsutism. Both acne and hirsutism are reversible on cessation of prasterone. (§6.1) To report SUSPECTED ADVERSE REACTIONS, contact QPharma Pharmacy Fulfillment Services, Inc. at 1888_742-7620 or FDA (1-800-FDA-1088 or www.fda.gov/medwatch) or your doctor. • • • DRUG INTERACTIONS PRASTERA® may interact with certain psychiatric drugs. (§8) Concomitant administration of PRASTERA® with endogenous testosterone or estrogens, or dietary supplements containing DHEA or dehydroepiandrosterone, is not generally recommended unless serum sex hormone levels are monitored, because of the potential to elevate levels above the ranges considered normal in healthy individuals. (§§7.1, 7.2.1, 8, 10, 16.3) USE IN SPECIFIC POPULATIONS Not recommended for use in nursing nor pregnant women, pediatric patients, or men (safety data is lacking). (§9) See § 16 for PATIENT COUNSELING INFORMATION. Revised: 05/2013 WARNINGS AND PRECAUTIONS PRASTERA® is not intended for use in nursing or pregnant women, children nor males (safety data is lacking). (§§4, 9) PRASTERA® use may be prohibited by certain athletic anti-doping regulations. (§9.5) TABLE OF CONTENTS 1 INDICATIONS AND USAGE 2 DOSAGE AND ADMINISTRATION 2.1 GENERAL INSTRUCTIONS 2.2 SPECIAL PRECAUTIONS 3 DOSAGE FORMS AND STRENGTHS 4 5 6 CONTRAINDICATIONS 4.1 ALLERGY WARNING WARNINGS AND PRECAUTIONS ADVERSE REACTIONS 6.1 INCREASED RISK OF ACNE AND HIRSUTISM 6.2 REDUCED RISK OF MYALGIA AND OTHER FLARE SYMPTOMS 6.3 OTHER COMMON ADVERSE EVENTS 6.3.1 Hypertension 6.4 REDUCED RISK OF DEATH 6.5 REDUCED RISK OF BREAST CANCER 6.6 OTHER SERIOUS ADVERSE EVENTS 7 SAFETY 7.1 RELATIONSHIP OF DOSE TO SAFETY 7.2 CLINICAL LABORATORY EVALUATION 7.2.1 Serum Hormone Levels 7.2.2 Serum Creatinine 7.2.3 Serum Complement 7.2.4 Serum Lipids 7.2.5 Liver Function 7.2.6 Renal Function 7.2.7 Proteinuria 7.2.8 Hematuria 7.3 POST-MARKETING EXPERIENCE 8 DRUG INTERACTIONS 9 USE IN SPECIFIC POPULATIONS 9.1 MALES 9.2 PATIENTS WITH ACTIVE SLE DISEASE 9.3 PREGNANCY 9.4 PEDIATRIC USE 9.5 ATHLETIC ANTI-DOPING 10 OVERDOSE 11 DESCRIPTION 12 CLINICAL PHARMACOLOGY 12.1 PHARMACODYNAMICS 12.2 PHARMACOKINETICS 12.2.1 Time To Peak Concentration 12.2.2 Absorption 12.2.3 Distribution 12.2.4 Metabolism 12.2.5 Excretion 13 12.2.6 Special Populations PRE-CLINICAL TOXICOLOGY 14 CLINICAL STUDIES 14.1 REDUCTION IN RISK OF FLARE 14.1.1 Clinical Study GLB96-01 14.1.2 Clinical Study GL95-02 14.2 REDUCTION IN RISK OF DEATH 14.2.1 Clinical Study GL94-01 15 HOW SUPPLIED / DOSAGE AND HANDLING 16 PATIENT COUNSELING INFORMATION 16.1 PATIENT / CAREGIVER INSTRUCTIONS 16.2 BENEFITS 16.3 OTHER MEDICATIONS 16.4 ADVERSE REACTIONS 16.5 PREGNANCY 17 MEDICATION GUIDE FULL PRESCRIBING INFORMATION 1 INDICATIONS AND USAGE Oral prasterone (200mg per day) in female patients with active systemic lupus erythematosus (SLE) has in several blinded, placebo-controlled randomized clinical studies been associated with a reduced risk of auto-immune flare, §§6.2, 14.1.1, and a reduced risk of death from any cause, §§6.4, 14.2. Patients with SLE may have depressed serum levels of 5-dehydroepiandrosterone sulfate (5-DHEAS). Oral prasterone has been shown to restore SLE patients’ serum 5-DHEAS levels. Prastera® oral softgels are intended for use in patients for whom medical evaluation shows a depressed serum level of DHEA and thus a distinctive need for exogenous DHEA. Prastera® oral prasterone softgels are intended to be used under medical supervision, for a patient receiving active and ongoing medical supervision, wherein the patient obtains medical care on a recurring basis for, among other things, instructions on the use of this product. Prastera® oral prasterone softgels are intended for the dietary management of SLE by meeting the distinctive nutritional requirement of women with mild-to-moderate active SLE. Prastera® oral prasterone softgels are intended for oral intake only. Prastera® does not cure, treat, mitigate or prevent SLE. To the contrary, patients taking Prastera® will continue to have SLE, and thus may require other appropriate therapy. 2 DOSAGE AND ADMINISTRATION 2.1 General Instructions The recommended dose is one 200mg Prastera® oral prasterone softgel daily, with or without food. 2.2 Special Precautions None. 3 DOSAGE FORMS AND STRENGTHS Prastera® oral prasterone is provided as oral softgels. Each softgel contains 200mg of prasterone (>99% pure). Inactive ingredients: olive oil NF, gelatin NF, beeswax NF, lecithin NF, titanium dioxide USP. 4 CONTRAINDICATIONS Prastera® oral softgels should not be used in patients with any of the following conditions: a) Known hypersensitivity to prasterone (or the dietary supplement DHEA), testosterone, estrogens or any component of Prastera® oral prasterone softgels. §4.1. b) Undiagnosed abnormal genital bleeding. c) Known, suspected, or history of breast cancer. §6.5. d) Active deep vein thrombosis, pulmonary embolism or history of these conditions. e) Active arterial thromboembolic disease (for example, stroke and myocardial infarction), or a history of these conditions. §6.3.2. f) Patients with hypercholesterolemia, §7.2.4, or ischemic heart disease. g) Liver disease or renal impairment (pharmacokinetic data lacking). h) Known or suspected pregnancy; breast-feeding (safety data lacking). i) Patients with or a history of psychiatric disorders (risk of exacerbation). The risk of mania may be increased during concomitant use with antidepressants (tricyclic or SSRIs) and/or alcohol, or with high prasterone doses, or in patients with a history of mood disorders. 4.1 Allergy Warning Prastera® oral prasterone softgels contain no milk, eggs, fish, crustacean shellfish, tree nuts, wheat, peanuts or soy bean. 5 WARNINGS AND PRECAUTIONS PRASTERA® is not intended for use in children, nor males, nor women who are breastfeeding, pregnant, or who expect to become pregnant. §9. Monitoring of blood pressure, serum lipids, serum sex hormones is prudent. See Clinical Laboratory Evaluation, §§7.2.1, 7.2.4. 6 ADVERSE REACTIONS The most-frequent adverse reactions observed in placebo-controlled, blinded clinical studies GL94-01, GL95-01, GL95-02 and GLB96-01 are as follows: 6.1 Increased Risk of Acne and Hirsutism Acne was the most frequently reported adverse event. Acne was reported less frequently by African American patients, in approximately 26%, compared to approximately 36% in Caucasian patients. The second most-frequent adverse event was hirsutism. In study GLB96-01 involving patients of Chinese extraction, hirsutism was not reported; this may indicate a decreased racial susceptibility to hirsutism. Acne and hirsutism were both reversible on cessation of prasterone therapy. In addition, both were more likely to be reported early in treatment; patients who had not developed these within the first 6 months of exposure are less likely to develop them later. 6.2 Reduced Risk of Myalgia and Other Flare Symptoms Placebo-treated patients had higher incidences of myalgia, joint disorder, anorexia, nasal ulcers and LE skin rash than did prasterone-treated patients. These differences may be due to the decreased risk of flare observed in prasterone-treated patients. §14.1. 6.3 Other Common Adverse Events No adverse events increase in frequency with longer duration of treatment. The Table displays all adverse events reported in a frequency of 10% or greater from either the 200 mg dose group or the placebo group for the pooled double-blind phases of Studies GL94-01 and GL95-02. Because the number of patients who received prasterone 100 mg was substantially fewer, adverse events for this group are only presented for those adverse events which were reported in > 10% of either placebo or prasterone 200 mg patients. ADVERSE EVENTS WITH FREQUENCY >10%* (pooled GL94-01 and GL95-02 results) COSTART TERM Rash Acne Arthralgia Asthenia Headache Arthritis Myalgia Pain Abdomen Flu Syndrome Stomatitis Ulcer Hirsutism Fever Depression Alopecia Infection Sinusitis Placebo N=256 77 (30.1%) 39 (15.2%) 95 (37.1%) 70 (27.3%) 76 (29.7%) 58 (22.7%) 79 (30.9%) 34 (13.3%) 46 (18.0%) 50 (19.5%) 6 (2.3%) 39 (15.2%) 33 (12.9%) 48 (18.8%) 37 (14.5%) 33 (12.9%) 100mg N=63 14 (22.2%) 28 (44.4%) 15 (23.8%) 23 (36.5%) 17 (27.0%) 17 (27.0%) 14 (22.2%) 8 (12.7%) 1 (1.6%) 15 (23.8%) 7 (11.1%) 9 (14.3%) 5 (7.9%) 7 (11.1%) 18 (28.6%) 4 (6.3%) 200mg N=253 93 (36.8%) 91 (36.0%) ** 88 (34.8%) 68 (26.9%) 60 (23.7%) 57 (22.5%) 55 (21.7%) ** 41 (16.2%) 40 (15.8%) 38 (15.0%) 36 (14.2%) ** 36 (14.2%) 35 (13.8%) 35 (13.8%) 26 (10.3%) 22 (8.7%) Pain Chest 27 (10.5%) 5 (7.9%) 22 (8.7%) *Frequency > 10% in either prasterone 200 mg or placebo patients. ** P< 0.05, Placebo vs. prasterone 200 mg. For adverse events occurring in < 10% of patients, the following showed an absolute difference of at least 3% between placebo or prasterone 200 mg, or, if less than 3% difference, the difference was significant (p < 0.05): ADVERSE EVENTS WITH FREQUENCY <10% AND AT LEAST A 3% OR A SIGNIFICANT DIFFERENCE (pooled GL94-01 and GL95-02 results) COSTART TERM Less Frequent in Prasterone Anorexia Nasal Septum Disorder (nasal ulcers) Rash Lupus Erythematosus Joint Disorder More Frequent in Prasterone Creatinine Increase Hypertension Hematuria Insignificant Difference Back Pain Pharyngitis Dyspnea Lymphadenopathy Placebo N=256 prasterone 200 mg N=253 10 (3.9%) 14 (5.5%) 13 (5.1%) 14 (5.5%) 2 (0.8%) ** 5 (2.0%) ** 4 (1.6%) ** 4 (1.6%) ** 0 (0.0%) 7 (2.7%) 1 (0.4%) 6 (2.4%)** 20 (7.9%) ** 9 (3.6%) ** 16 (6.3%) 14 (5.5%) 22 (8.6%) 21 (8.2%) 24 (9.5%) 6 (2.4%) 11 (4.3%) 12 (4.7%) ** P< 0.05, Placebo vs. prasterone 200 mg. The pattern of adverse events in clinical study GLB96-01 showed a similar, but not identical pattern. Acne was the most common adverse event; this may reflect the fact that almost all patients were also receiving corticosteroids. This may also reflect racial differences in sensitivity to prasterone. By contrast, hirsutism was not reported at all in GLB96-01. ADVERSE EVENTS REPORTED BY AT LEAST 10% OF EITHER TREATMENT GROUP (GBL96-01) Arthralgia Acne * Pharyngitis Myalgia Placebo N= 59 37 ( 62.7%) 17 ( 28.8%) 32 ( 54.2%) 24 ( 40.7%) Treatment N= 61 39 ( 63.9%) 36 ( 59.0%)* 34 ( 55.7%) 28 ( 45.9%) Headache * Pain Abdomen Asthenia Cough Increase Dizziness Pain Chest Dyspnea Rash Fever Alopecia Pain Diarrhea Rhinitis Stomatitis Ulcer Pain Back Edema Injury Accident Insomnia Pruritus Infection* Dry Eye Vomit Peripheral Edema Rash Lupus Erythematosus Conjunctivitis Nausea 37 ( 62.7%) 25 ( 42.4%) 19 ( 32.2%) 18 ( 30.5%) 19 ( 32.2%) 11 ( 18.6%) 8 ( 13.6%) 16 (27.1%) 17 ( 28.8%) 8 ( 13.6%) 8 ( 13.6%) 11 ( 18.6%) 13 ( 22.0%) 17 ( 28.8%) 10 ( 16.9%) 6 ( 10.2%) 6 ( 10.2%) 7 ( 11.9%) 7 ( 11.9%) 15 ( 25.4%) 10 ( 16.9%) 8 ( 13.6%) 8 ( 13.6%) 7 ( 11.9%) 7 ( 11.9%) 9 ( 15.3%) 26 ( 42.6%)* 23 ( 37.7%) 18 ( 29.5%) 18 ( 29.5%) 15 ( 24.6%) 14 ( 23.0%) 14 ( 23.0%) 14 ( 23.0%) 13 ( 21.3%) 13 ( 21.3%) 11 ( 18.0%) 11 ( 18.0%) 11 ( 18.0%) 10 ( 16.4%) 9 ( 14.8%) 9 ( 14.8%) 8 ( 13.1%) 8 ( 13.1%) 8 ( 13.1%) 6 ( 9.8%)* 6 ( 9.8%) 5 ( 8.2%) 5 ( 8.2%) 5 ( 8.2%) 5 ( 8.2%) 4 ( 6.6%) *P-value<0.05, Treatment vs. Placebo, chi-square test Of adverse events reported by at least 10% of patients, acne was the only event significantly more frequent in the treatment group. Headache and infection were more frequent in the placebo group. Of the adverse events reported with an incidence of less than 10%, the only statistically significant difference was for seborrhea (0 placebo vs. 5 treatment patients). 6.3.1 Hypertension Hypertension was reported as an adverse event more frequently in the prasterone 200 mg group than placebo. When measures of increased (changed) blood pressure were included, there appeared to be no difference between the groups. Whether prasterone increases hypertension is thus not clear. 6.4 Reduced Risk of Death In the GL94-01, GL95-01 and GL95-02 placebo-controlled clinical studies (pooled data), the placebo group experienced 6 deaths in 77 patients, a risk of death of 7.8%. In contrast, the prasterone group (pooled treatment and cross-over) experienced 8 deaths in 495 patients, a risk of death of 1.6%. The risk of death from any cause was therefore five times higher in the placebo group. 6.5 Reduced Risk of Breast Cancer In the GL94-01, GL95-01 and GL95-02 placebo-controlled clinical studies (pooled data), incidence of breast cancer was 1 in 336 patient-years (0.29%) for placebo and 3 in 1573 patientyears (0.19%) for prasterone (pooled treatment and cross-over). Prasterone was thus associated with reducing the risk of breast cancer by one third. For patients over 44 years of age, the difference between placebo and prasterone groups was more pronounced. For women at least 45 years of age, the rate of breast cancer was 1 in 24 patient-years (4.2%) for placebo and 3 in 206 patient-years (1.5%) for prasterone treatment and cross-over patients. Prasterone was thus associated with reducing the risk of breast cancer by two thirds. 6.6 Other Serious Adverse Events Adverse events that were assessed as “severe” occurred in similar frequencies in both treatment and placebo groups, with asthenia being the most common adverse event reported as severe in both placebo and treated patients. Although the patient numbers are small, abdominal pain reported as a severe adverse event occurred in 6 treated 200 mg patients, 2 treated 100mg patients, and no placebo patients. Serious adverse events occurred in 39 200 mg, 7 100 mg, and 47 placebo patients participating in GL94-01 and GL95-02. However, only 3 serious adverse events were considered possibly related, 2 in the placebo group (one suicide and one patient with menomettrorhagia) and one in 200 mg (a patient with an acute psychosis). In the Taiwan study, serious adverse events were reported in a significantly higher proportion of patients in the placebo group than in the treatment group. In most cases, the types of serious adverse events reported were consistent with SLE flares or hospitalization for manifestations of SLE, rather than adverse effects of the study drug. SEVERE ADVERSE EVENTS OCCURRING IN AT LEAST 2 PATIENTS* (GL94-01 and GL95-02) COSTART TERM Asthenia Headache Arthralgia Pain Abdomen Rash Arthritis Dyspnea Depression Diabetes Mellitus Emotional Lability Infection Myalgia Pain Pain Chest Paresthesia Pleural Disorder Vasculitis Joint Disorder Peripheral Edema Sepsis Cyst Thinking Abnormal Placebo N=256 22 (8.6%) 11 (4.3%) 6 (2.3%) 0 (0%) 5 (2.0%) 2 (0.8%) 1 (0.4%) 4 (1.6%) 0 (0%) 0 (0%) 0 (0%) 5 (2.0%) 1 (0.4%) 4 (1.6%) 1 (0.4%) 1 (0.4%) 0 (0%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) prasterone 100 mg N=63 4 (6.3%) 1 (1.6%) 3 (4.8%) 2 (3.2%) 1 (1.6%) 3 (4.8%) 0 (0%) 1 (1.6%) 0 (0%) 0 (0%) 4 (6.3%) 1 (1.6%) 0 (0%) 1 (1.6%) 0 (0%) 0 (0%) 1 (1.6%) 0 (0%) 2 (3.2%) 0 (0%) 0 (0%) 0 (0%) prasterone 200 mg N=253 22 (8.7%) 8( 3.2%) 6 (2.4%) 6 (2.4%) 6 (2.4%) 5 (2.0%) 4 (1.6%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 2 (0.8%) 1 (0.4%) 0 (0%) 0 (0%) 0 (0%) 0 (0%) *Frequency at least 2 patients in either prasterone 200 mg or placebo 7 SAFETY 7.1 Relationship Of Dose To Safety Neither adverse events nor laboratory values showed a dose relationship. 7.2 Clinical Laboratory Evaluation 7.2.1 Serum Hormone Levels In the placebo-controlled trials, testosterone was increased in a dose related manner in SLE patients, both pre- and post-menopausal, receiving prasterone; and androgenic adverse events such as acne and hirsutism showed an increased frequency, as did lipid changes usually associated with administration of androgens. In non-pregnant women, the most serious risks associated with increased levels of testosterone would be virilization, i.e., evidence of irreversible androgenic changes such as deepening of the voice, androgenic alopecia, or clitoral hypertrophy. Such events were not reported in the prasterone clinical trials. However, the longterm risks of the increased testosterone levels caused by prasterone are not yet known. 7.2.2 Serum Creatinine In the pooled data from GL94-01 and GL95-02, 0 of 256 patients in the placebo group had creatinine increase reported as an adverse event, while 6 of 253 patients (2.4%) in the prasterone 200 mg group had this adverse event, p=0.015, placebo vs. prasterone 200 mg. Although there was an imbalance in the few patients with creatinine increase reported as an adverse event, overall serum creatinine (as judged by a mean or median increase in serum creatinine) did not increase in any of the groups, and also there was no difference in change in creatinine between groups. Taken as a whole, these findings suggest renal dysfunction, as identified by increased serum creatinine, was quite uncommon, and generally not related to the findings of increased proteinuria, new onset hematuria or decreased C3. 7.2.3 Serum Complement Prasterone caused an increased number of patients (in comparison to placebo) to have a decrease in C3, the decline in C3 was not associated with renal dysfunction, suggesting the effect may be mediated by a reduction in complement synthesis rather than an enhancement of consumption. The medical literature suggests that a decline in serum complement may be a direct effect of suppression of complement production by androgens. 7.2.4 Serum Lipids Decreases in lipids, particularly HDL-C and triglycerides, were consistently seen in studies of prasterone. The reduction was most evident for HDL-C and triglycerides, less so for total cholesterol and minimal for LDL cholesterol. These findings suggest that administration of prasterone consistently causes an early, but not progressive, decrease in serum lipids, primarily HDL-C and triglycerides. Reduction in HDL-C observed with prasterone may not necessarily signify an increased risk of atherosclerosis. However, it would be prudent to follow NCEP guidelines while monitoring lipids in patients receiving prasterone. 7.2.5 Liver Function There were no changes of potential significance in liver function tests (ALT, AST, alkaline phosphatase, or total bilirubin) within and between the treatment groups. Equally, serum calcium, phosphorus, uric acid, total protein and albumin showed no clinically relevant differences between treatment groups, or changes from baseline. In the Taiwan study, there were no clinically significant differences in liver function tests though the placebo group demonstrated increases in SGOT and SGPT. 7.2.6 Renal Function BUN and creatinine levels did not change during study and were similar within or between treatment groups. Mean changes in 24-hour urine protein excretion increased in all treatment groups, but to a greater extent in prasterone patients. However, a few patients with very high values impacted 24-hour urine protein; and median changes were only slightly higher in the prasterone groups. In the Taiwan study, there were no differences between treatment groups. Creatinine showed a mean increase from baseline of 0.2 mg/dl (an increase of 2.8%) in the prasterone treatment group. However, the mean was influenced by one patient with an increase of 6.1 mg/dl and the group median change was 0.0 mg/dl. No patient in the prasterone treatment group had a shift from a normal baseline value to a high value at final visit. 7.2.7 Proteinuria There was a higher mean change from baseline for 24 urinary protein with prasterone: the mean change was 44.9 mg/24 hours for placebo, and 329.4 mg/24 hours for the prasterone 200 mg group, respectively. Less than 5% of patients with pre-existing proteinuria in the treatment group demonstrated a meaningful increase in proteinuria. 7.2.8 Hematuria There does not appear to be a difference between placebo and prasterone for new hematuria accompanied by SLE renal involvement, as manifested by changes in urinary protein excretion, increased creatinine, or new therapy for renal SLE. 7.3 Post-Marketing Experience The following adverse reactions have been reported with unregulated dietary supplements containing DHEA or dehydroepiandrosterone. These reactions have been reported voluntarily from populations of uncertain size, the identity, purity and strength of the product used was not always known, and none these patients were taking concomitant prednisone or other first-line SLE therapy. It is therefore not always possible to reliably establish a causal relation to prasterone exposure. Cardiovascular Effects: Benign premature atrial contractions and occasional premature ventricular contractions occurred in a 55-year-old man after administration of DHEA; DHEA was discontinued and arrhythmias controlled by beta-blockers.1 Hepatic Effects: No significant changes in transaminases or other hepatic function tests were seen during long-term use (e.g., 6 months).2,3 One case of hepatitis has been reported in a patient with high pre-treatment anti-nuclear antibody (ANA) titers; causality is uncertain.4 Psychiatric Effects: Manic reactions during DHEA use (50 to 500 mg daily) have been described.5,6 Risk factors for development of mania / psychosis are considered to be higher doses, combined use with antidepressants (tricyclics or selective serotonin-reuptake inhibitors) or alcohol or benzodiazepines, young patients (20 to 30 years, due to peaking endogenous dehydroepiandrosterone levels), and cytochrome P450 polymorphisms (poor metabolizers). 8 DRUG INTERACTIONS There is no known pharmacokinetic effect (bioavailability, pharmacokinetics, or pharmacodynamics) of prasterone on prednisone or hydroxychloroquine, with the possible exception of increasing the magnitude of a decrease in triglycerides seen with hydroxyquinoline. Informal reports indicate that prasterone may theoretically interact with one or more of the following drugs: carbamazepine, phenothiazines (e.g., acetophenazine, chlorpromazine, chlorprothixene, ethopropazine, fluphenazine, mesordiazine, methdilazine, perazine, perphenazine, pipotiazine, prochlorperazine, promazine, promethazine, propiomazine, thioridazine, trifluoperazine, triflupromazine), citalopram; escitalopram; clozapine, conjugated estrogens; estherified estrogens; estradiol; estradiol cypionate; estropipate; ethinyl estradiol, fluoxetine, fluvoxamine; haloperidol, lithium, loxapine, molindone, olanzapine, paroxetine, quetiapine, risperodone, sertraline, testosterone, triazolam and valproic acid. For further information on potential interactions with these drugs, please see The Cochrane Review monograph for prasterone. 9 USE IN SPECIFIC POPULATIONS 9.1 Males The placebo-controlled, double-blind clinical studies involved women. Use in men at this time is not recommended because data is lacking. 9.2 Patients with Active SLE Disease In the GL94-01 and GL95-02 clinical studies, the difference in responder rates between placebo and prasterone increased with increasing baseline SLEDAI. 9.3 Pregnancy Safety and effectiveness in nursing and pregnant women has not been established. Use is not recommended. 9.4 Pediatric Use Safety and effectiveness in pediatric patients have not been established. Use in pediatric patients is not recommended. 9.5 Athletic Anti-Doping Prasterone use is prohibited by certain athletic anti-doping regulations. 10 OVERDOSE Oral prasterone of up to 1.6 grams per day has not provoked overdose in post-menopausal women.7 In case of suspected overdose, Prastera® softgels should be discontinued and the patient should be treated symptomatically. 11 DESCRIPTION PRASTERA® prasterone oral softgels are oblong, bi-colored white and blue, liquidfilled soft gelatin capsules for oral administration. Each PRASTERA® prasterone oral O softgel contains 200mg prasterone (>98% pure), in an olive oil NF vehicle. Prasterone is chemically identical to the naturally-occurring prohormone 5-dehydroepiandrosterone secreted by the adrenal cortex, gonads and brain tissue. It is designated chemically as (3S,8R,9S,10R,13S,14S)-3-hydroxy-10,13-dimethyl3,4,7,8,9,10,11,12,13,14,15,16 –dodecahydro-1H- HO cyclopenta[a]phenanthren-17(2H)-one. Its molecular weight is 288.424 g/mol. Its molecular formula is C19H28O2. 12 CLINICAL PHARMACOLOGY H H H Prastera® oral prasterone softgels are an oral dosage form of prasterone (pharmaceutical grade), chemically identical to prasterone of native human origin, in a lipophilic vehicle. 12.1 Pharmacodynamics Oral prasterone has been shown to increase serum levels of 5-DHEAS. The precise mechanism by which normal serum levels of 5-DHEAS may act to reduce the risk of autoimmune flare and death is not known. 12.2 Pharmacokinetics 12.2.1 Time To Peak Concentration Oral prasterone reaches a peak serum concentration at 1.5 to 2 hours after administration.8,9 In healthy young women (mean age, 30 years) receiving prasterone 200 mg daily (given with prednisone), mean peak plasma levels on day 29 of prasterone and 5-DHEAS were 1.3 mcg/dL (13 ng/mL) and 942 mcg/dL (9.4 mcg/mL), and occurred in 2 hours and 2.4 hours, respectively, after administration.10 In elderly women (mean, 69 years) and elderly men (mean, 69 years), mean peak plasma concentrations (times to peak levels) after a single 200-mg micronized oral dose were 27 ng/mL (1.4 hours) and 22 ng/mL (1.3 hours) in elderly women and men, respectively. After a single 200 mg dose, mean serum levels of 5-DHEAS increased 5-fold in men (to 7 mcg/mL) and 21-fold in women (to 7.5 mcg/mL) relative to baseline healthy levels; the time to peak serum levels of 5-DHEAS were shorter in women than men (2.1 versus 3.3 hours).11 12.2.2 Absorption During two weeks of daily administration (200 mg), plasma levels (and times to peak levels) of both 5-dehydroepiandrosterone and its sulfated metabolite did not change significantly in either women or men, indicating a lack of accumulation.12 12.2.3 Distribution Approximately 10% to 20% of prasterone is bound to serum protein; approximately 80% to 90% of 5-DHEAS is bound to protein.13 5-DHEAS penetrates the blood-brain barrier; cerebrospinal fluid levels of 5-DHEAS range from 0.2% to 5% of corresponding plasma levels.14, 15 12.2.4 Metabolism Oral prasterone is sulfated to 5-DHEAS ester in the intestine and liver by sulfotransferases.16 Prasterone and 5-DHEAS are converted in peripheral tissues to androstenedione,17 androsterone sulfate,18 estradiol, estriol and estrone,19 dihydrotestosterone,20 7-oxo-prasterone,21 and testosterone.22 It remains controversial whether the pharmacologic effects of 5-DHEAS are direct, or due solely to its conversion to other metabolites.23 12.2.5 Excretion Prasterone (200mg dose) elimination half-life: young women, 11 hours; elderly men, 7 24 hours. In elderly women, the elimination half-life progressively declined, from about 12 hours (day 1), to 9 hours (day 8), to 7 hours (day 15).25 5-DHEAS half-life: young women, 12 hours; elderly men, 20-25 hours; elderly women, 24-27 hours.26 12.2.6 Special Populations The pharmacokinetics of Prastera® oral prasterone softgels have not been assessed in low body weight or obese patients. There is insufficient information available from placebocontrolled clinical trials to compare prasterone pharmacokinetics in different racial groups, nor for patients with renal or hepatic impairment. 13 PRE-CLINICAL TOXICOLOGY The non-clinical literature indicates that prasterone may be either chemo-protective or carcinogenic, depending on the model. Prasterone may thus be inhibitory or stimulatory to hormone-senentive tumors. The literature, however, suggests that prasterone is less potent than its androgenic and estrogenic metabolites. Similarly to androgenic and extrogenic compounds, it is expected to be difficult to define the carcinogenic potential of prasterone.27 14 CLINICAL STUDIES The placebo-controlled studies (GL94-01, GL95-01, GL95-02 and GLB96-01) had very different study designs and efficacy endpoints. Pooling of efficacy data is thus not meaningful. Consequently, results are presented by individual study. 14.1 Reduction In Risk Of Flare 14.1.1 Clinical Study GLB96-01 GLB96-01 was a six month, multi-center, randomized, parallel group, double-blind, placebo-controlled study of prasterone (200mg daily) in predominately (+84%) prePrasterone menopausal (mean age = 32 years) Asian women with active SLE (97% had baseline SLEDAI score > 2). The treatment group (n = 60) had a somewhat higher baseline SLEDAI (Mean (Median) baseline SLEDAI = 8.2 (8.0)). The placebo group (n = 59) a somewhat lower baseline SLEDAI (Mean (Median) baseline SLEDAI = 6.6 (6.0)). In this study, the Time to first flare (p = 0.044) treatment group had fewer patients with at least one definite flare. The number of patients with definite flares in the treatment group was 46.0% less than in the placebo group (18.3% vs. 33.9%, p = 0.044 based on survival analysis using Cox model). The Time to First Definite Flare Survival Curve for GBL96-01 is shown here. The percent of patients without a definite flare began to diverge after 28 days of treatment, and widened progressively. There was a statistically-significant decrease in the number of patients who experienced at least one flare as compared to the placebo group 14.1.2 Clinical Study GL95-02 Study GL95-02 was a 12 month, multi-center, randomized, parallel group, double-blind, placebo-controlled study of prasterone (200mg daily) in women (n = 346) with active SLE (SLAM score >7 excluding ESR, SLEDAI score >2) receiving <10 mg/day prednisone (or its equivalent of other cortico-steroids). A secondary efficacy variable (flare) was defined as a modified SELENA definition flare. Three hundred eighty one (381) patients were randomized, of whom 346 were in the perprotocol population. For all patients, 47/176 (27%) of placebo and 37/170 (22%) of prasterone patients experienced a definite flare. Time to First Definite Flare Survival Curve in ITT Population (Study 95-02) is shown in the survival curve. For the subset of patients with a baseline SLEDAI>2, treated patients had a 23.7% decrease in the risk of experiencing at least one definite flare, compared to placebo. During the study period, 41/133 (31%) of placebo patients and 31/132 (23.5%) of prasterone patients experienced a definite flare. See bar chart. Thus, for patients with a baseline SLEDAI>2, treated patients had a 23.7% decrease in the risk of experiencing at least one definite flare, compared to placebo (p=0.201, log-rank test for time to first definite flare). % of Patients With Definite Flare (Baseline SLEDAI >2) Placebo, 31% Prast erone, 24% 14.2 Reduction In Risk of Death In the GL95-02 study (discussed above), five placebo patients died, and no prasteronetreated patients died. These data show a statistically significant and clinically meaningful reduction in risk of death by any cause. In the GL94-01, GL95-01 and GL95-02 clinical trials (pooled data), the prasterone treated group (including prasterone-treated crossover patients) experienced 8 deaths among 495 patients, or a risk of death of 1.62%. In contrast, the placebo group experienced 6 deaths among 77 patients, or a risk of death of 7.80%. 14.2.1 Clinical Study GL94-01 Study GL94-01 compared the proportion of patients achieving sustained reduction of daily corticosteroid dose, without worsening of signs and symptoms of SLE (“Responders”), in placebo (n = 64) and prasterone 200 mg (n = 64) groups for about 7 months. For all randomized patients, 26/64 (41%) placebo and 35/64 (55%) prasterone 200 mg patients responded: a strong trend in favor of prasterone (p = 0.110). For patients with baseline SLEDAI >2, 13/45 (29%) placebo and 23/45 (51%) prasterone 200mg patients responded (p = 0.031). 15 HOW SUPPLIED / DOSAGE AND HANDLING Prastera® (prasterone, pharmaceutical grade) softgels 200mg are oblong, bi-colored blue and white soft, liquid filled gelatin capsules, NDC 55607-798-21. Store at not more than 25° C (77° F). Excursions are permitted to 15° C to 30° C (59° F to 86° F). See United States Pharmacopoeia, Controlled Room Temperature. Protect from excessive moisture or humidity. Dispense in a tight, light-resistant container as defined in USP/NF, using a child-resistant closure system, accompanied by a Patient Insert and in a convenience pack together with clindamycin phosphate topical pledgets. Keep out of reach of children. Manufactured for: Health Science Funding, LLC 55 Madison Avenue, 4th floor Morristown, NJ 07960 [email protected] 16 PATIENT COUNSELING INFORMATION See Medication Guide (§17) for specific patient instructions. 16.1 Patient / Caregiver Instructions Inform patients of the following information before initiating therapy with PRASTERA® and periodically during the course of on-going therapy. Encourage patients to read the Medication Guide that accompanies each prescription dispensed, prior to using PRASTERA®. 16.2 Benefits Oral prasterone 200 mg / day reduced the risk of auto-immune flare, §§6.2, 14.1, and significantly reduced the risk of death, §§6.4, 14.2, in placebo-controlled, randomized, blinded clinical studies (GL94-01, GL95-01, GL95-02 and GLB96-01) in female patients with Systemic Lupus Erythematosus. Results observed in clinical trials may not, however, reflect the rates observed in practice. PRASTERA® does not cure, mitigate, treat or prevent the patient’s underlying SLE. To the contrary, the patient will continue to have SLE. The patient therefore should continue to be monitored by a physician and should continue other therapy (e.g., prednisone, NSAID) as believed appropriate. Oral prasterone reduced the risk of auto-immune flare and death. See above. PRASTERA® may not, however, make the patient feel significantly different on a day-to-day basis. This does not mean PRASTERA® is not working; it may take at least six months of continuous therapy to achieve a statistically-significant reduction in risk of flare and death. §14. 16.3 Other Medications PRASTERA® is a synthetic form of 5-dehydroepiandrosterone. PRASTERA® should not be combined with dietary supplements containing “DHEA” or “dehydroepiandrosterone.” PRASTERA® is a precursor to testosterone and estrogens. If PRASTERA® is used in conjunction with testosterone or estrogens, levels of serum testosterone and estrogens should be monitored closely to assure levels do not exceed the range seen in healthy women of similar age. 16.4 Adverse Reactions PRASTERA® may cause acne. Your Prastera® includes a topical anti-acne drug should you need it. Prasterone-associated acne is reversible on cessation of prasterone therapy. PRASTERA® may cause hirsutism, reversible on cessation of prasterone therapy. PRASTERA® may cause hypertension, §6.3.2, and/or changes in serum lipids, §7.2.4, or serum hormone levels, §7.2.1. These should be monitored, and are reversible on cessation of prasterone therapy. 16.5 Pregnancy Instruct patients who are nursing, pregnant or intending to become pregnant, not to use PRASTERA®. 17 MEDICATION GUIDE ! " " # $ % & ' ( ( # ( ( ( # ) # $ # ( # # ( # # # ' " ( " ) # $ (# ( ) * " " + " " ( " # # , ! ( ) # -./ - ( 0 0 ) # " # # 1234 *5536+# & 7 6 " # 6. # 8 *9::+;;1 8:99# ' < / 22= = C 6 #> #?@:5AB: D 1:81/ 6 # 4 6 # # 4 # 4 # ( ( / 1 Sahelian R & Borken S: Dehydroepiandrosterone and cardiac arrhythmia. Ann Intern Med 1998; 129(7):588. Morales AJ, Haubrich RH, Hwang JY, et al: The effect of six months treatment with a 100 mg daily dose of dehydroepiandrosterone (DHEA) on circulating sex steroids, body composition and muscle strength in age- advanced men and women. Clin Endocrinol 1998; 49:421-432. 3 Villareal DT, Holloszy JO, & Kohrt WM: Effects of DHEA replacement on bone mineral density and body composition in elderly women and men. Clin Endocrinol 2000a; 53:561-568. 4 Buster JE, Casson PR, Straughn AB, et al: Postmenopausal steroid replacement with micronized dehydroepiandrosterone: preliminary oral bioavailability and dose proportionality studies. Am J Obstet Gynecol 1992; 166(4):1 163-1170. 5 Dean CE: Prasterone (DHEA) and mania. Ann Pharmacother 2000b; 34(12):1419-1 422. 6 Pies R: Adverse neuropsychiatric reactions to herbal and over-the-counter "antidepressants". J Clin Psychiatry 2000; 61(11 ):81 5-820. 7 Mortola, J.F. et al., The Effects of Oral Dehydroepiandrosterone Supplementation in Early and Late Menopause, Gynecol. Endocrinol. vol. 14 pp. 342-63 (2000). 8 Arlt W, Justl H-G, Callies F, et al: Oral dehydroepiandrosterone for adrenal androgen replacement: pharmacokinetics and peripheral conversion to androgens and estrogens in young healthy females after dexamethasone suppression. J Clin Endocrinol Metab 1998; 83:1928-1 934. 9 Meno-Tetang GML, Blum RA, Schwartz KE, et al: Effects of oral prasterone (dehydroepiandrosterone) on single-dose pharmacokinetics of oral prednisone and cortisol suppression in normal women. J Clin Pharmacol 2001; 41(1 1):1 195-1 205. 10 Meno-Tetang GML, Blum RA, Schwartz KE, et al: Effects of oral prasterone (dehydroepiandrosterone) on single-dose pharmacokinetics of oral prednisone and cortisol suppression in normal women. J Clin Pharmacol 2001; 41(1 1):1 195-1 205. 11 Frye RF, Kroboth PD, Kroboth FJ, et al: Sex differences in the pharmacokinetics of dehydroepiandrosterone (DHEA) after single- and multiple- dose administration in healthy older adults. J Clin Pharmacol 2000b; 40(6):596- 605. 12 Frye RF, Kroboth PD, Kroboth FJ, et al: Sex differences in the pharmacokinetics of dehydroepiandrosterone (DHEA) after single- and multiple- dose administration in healthy older adults. J Clin Pharmacol 2000b; 40(6):596- 605. 13 Longcope C: Dehydroepiandrosterone metabolism. J Endocrinol 1996; 1 50(suppl):S1 25-S1 27. 14 Barrett-Connor E, von Muhlen D, Laughlin GA, et al: Endogenous levels of dehydroepiandrosterone sulfate, but not other sex hormones, are associated with depressed mood in older women: the Rancho Bernardo study. J Am Geriatr Soc 1999; 47:685-691. 15 Friess E, Schiffelholz T, Steckler T, et al: Dehydroepiandrosterone - a neurosteroid. Eur J Clin Invest 2000; 30(Suppl 3):46-50. 16 Sulcova J, Hill M, Hampl R, et al: Effects of transdermal application of DHEA on the levels of steroids, gonadotropins and lipids in men. Physiol Res 2000; 49(6):685-693. 17 Haning RV Jr, Flood CA, Hackett RJ, et al: Metabolic clearance rate of dehydroepiandrosterone sulfate, its metabolism to testosterone, and its intrafollicular metabolism to dehydroepiandrosterone, androstenedione, testosterone, and dihydrotestosterone in vivo. J Clin Endocrinol Metab 1991; 72(5):1 088-1095; Morales AJ, Haubrich RH, Hwang JY, et al: The effect of six months treatment with a 100 mg daily dose of dehydroepiandrosterone (DHEA) on circulating sex steroids, body composition and muscle strength in age- advanced men and women. Clin Endocrinol 1998; 49:421-432. 18 Bird CE, Murphy J, Boroomand K, et al: Dehydroepiandrosterone: kinetics of metabolism in normal men and women. J Clin Endocrinol Metab 1978; 47(4):81 8-822. 19 Schwarz HP: Conversion of dehydroepiandrosterone sulfate (DHEA-S) to estrogens and testosterone in young non-pregnant women. Horm Metab Res 1990; 22(5):309-310. 20 Arlt W, Justl H-G, Callies F, et al: Oral dehydroepiandrosterone for adrenal androgen replacement: pharmacokinetics and peripheral conversion to androgens and estrogens in young healthy females after dexamethasone suppression. J Clin Endocrinol Metab 1998; 83:1928-1 934. 21 Davidson M, Marwah A, Sawchuk RJ, et al: Safety and pharmacokinetic study with escalating doses of 3acetyl-7-oxo-dehyd roepiand rosterone in healthy male volunteers. Clin Invest Med 2000; 23(5):300-310. 2 22 Arlt W, Justl H-G, Callies F, et al: Oral dehydroepiandrosterone for adrenal androgen replacement: pharmacokinetics and peripheral conversion to androgens and estrogens in young healthy females after dexamethasone suppression. J Clin Endocrinol Metab 1998; 83:1928-1 934. 23 Davidson M, Marwah A, Sawchuk RJ, et al: Safety and pharmacokinetic study with escalating doses of 3acetyl-7-oxo-dehyd roepiand rosterone in healthy male volunteers. Clin Invest Med 2000; 23(5):300-310. 24 Frye RF, Kroboth PD, Kroboth FJ, et al: Sex differences in the pharmacokinetics of dehydroepiandrosterone (DHEA) after single- and multiple- dose administration in healthy older adults. J Clin Pharmacol 2000b; 40(6):596- 605. 25 Frye RF, Kroboth PD, Kroboth FJ, et al: Sex differences in the pharmacokinetics of dehydroepiandrosterone (DHEA) after single- and multiple- dose administration in healthy older adults. J Clin Pharmacol 2000b; 40(6):596- 605. 26 Frye RF, Kroboth PD, Kroboth FJ, et al: Sex differences in the pharmacokinetics of dehydroepiandrosterone (DHEA) after single- and multiple- dose administration in healthy older adults. J Clin Pharmacol 2000b; 40(6):596- 605. 27 Wilson, Susan D., Non-Clinical Evaluation of GL701 [prasterone]: NDA 21-239 (April 19, 2001). 13 September 2012 Dr. Benson SILVERMAN, M.D. Director – Infant Formula & Medical Foods (Dept DHK3) CPK- 1 Bldg., Room 4C-095 5100 Paint Branch Road College Park, MD 20740 [email protected] BY ELECTRONIC MAIL Re: Medical Food Package Insert Review Dear Dr. Silverman, Almost two years ago, you generously took your time to discuss with me the regulation of medical foods. I’d like to ask you for some further guidance. We’re readying the commercial launch of a new medical food. We’re simply taking a product already freely on sale, and restricting it to prescription access to assure a physician stays involved. We have several placebo-controlled, double-blinded randomized clinical studies supporting efficacy. (These studies were done to support an NDA, but the Sponsor ran out of money. We thus have perhaps the most thorough efficacy and toxicology package in the history of medical foods.) => Might I ask you to look at our proposed package insert (enclosed) and let me know if you would like any required changes? I enclose a copy of our draft insert, together with copies of several of the supporting clinical studies. If you like, I can also send pharmacology, toxicology, etc., but I sense the enclosed information may be adequate for the current inquiry. !"# $!%"! &' ' ' ( ) *( ( & +* , 13 September 2012 Page 2 Many thanks in advance for your help, and please let me know if you need anything further! Kind regards, HEALTH SCIENCE FUNDING, LLC /s/ Mark Pohl, Tel. + 1 (973) 984-0076 [email protected] Enclosures: PRASTERA® package insert (13 Sept 2012 draft) Chang et al. (2002) Petri et al. (2002) Petri et al. (2004) 5 November 2012 Dr. Benson SILVERMAN, M.D. Director – Infant Formula & Medical Foods (Dept DHK3) CPK- 1 Bldg., Room 4C-095 5100 Paint Branch Road College Park, MD 20740 Re: Medical Food Package Insert Review Dear Dr. Silverman, Many thanks for your letter of Oct. 17th. From it, I understand that your office does not generally do pre-marketing reviews, but in this case you have done me the courtesy of taking the extra effort to review our proposed insert nonetheless. Many thanks for your help. Might I ask for a bit more help? Your letter mentions “serious questions and concerns.” Might I ask what those questions and concerns are? With that information, I can perhaps provide acceptable answers and fixes for you. Many thanks in advance for your help, and I look forward to hearing from you soon, HEALTH SCIENCE FUNDING, LLC /s/ Mark Pohl, Tel. + 1 (973) 984-0076 [email protected] !"# $!%"! &' ' ' 27 November 2012 Dr. Benson SILVERMAN, M.D. Director – Infant Formula & Medical Foods (Dept DHK3) CPK- 1 Bldg., Room 4C-095 5100 Paint Branch Road College Park, MD 20740 Re: Medical Food Package Insert Review Dear Dr. Silverman, I trust this note finds you well. Having received no response to my letter of 05 November (copy enclosed), I sense that you have thought through my proposed product and its accompanying labeling, and now see how it all comports with the statute. We're thus planning to launch commercially as soon as stability testing is complete. Thus, with my apologies in advance for any inconvenience, if you have any lingering concerns, objections or questions, you'll need to let me know exactly what they are (email is fine, [email protected]) not later than close of business (Washington, D.C. time) on Friday Dec. 7th, 2012. If I don’t hear from you by then, I’ll assume the agency has no objections. Many thanks in advance for your help, and I look forward to hearing from you soon, HEALTH SCIENCE FUNDING, LLC /s/ Mark Pohl, Tel. + 1 (973) 984-0076 [email protected] !"# $!%"! & ' ' ' 11 December 2012, 15:09 Ms. Shawne Sugs-Anderson from the FDA Medical Foods staff (202) 402-1459, calling in response to a letter dated Nov. 27th that we just received about the ... intended launch of product that contains DHEA. We definitely have some concerns regarding the product. Primarily, the assumption that because this product contains an ingredient that is commonly used as a dietary supplement that somehow that automatically allows it to be used in medical food, and that couldn't be farther from the truth. The other issue is that we acknowledge that the ingredient proposed to be used on included in the product could or may be effective in managing the symptoms of certain individuals with SLE, we are not aware of any distinctive nutritional requirements that have been established by medical or scientific evaluation for SLE. Many products, naturally occurring as well as formulated, will provide benefits to individuals affected affected by multiple diseases and conditions. However, efficacy alone does not qualify a product to be marketed as a Medical Food. First and foremost, the product must meet the burden of the statutory definition of medical food. Based on the materials you provided, along with other publicly-accessible studies and resources, this product does not appear to meet that standard. So please by all means get back in touch with us. Bye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nspections, Compliance, Enforcement, and Criminal Investigations Pan American Laboratories, LLC Department of Health and Human Services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inks on this page: 3 ) J$ * J0 8 - *3 8 $ 8 *$ 3 4 5 * 4 2006 > Ganeden Biotech Inc. 08-Dec-06 1 of 3 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2006/uc... Inspections, Compliance, Enforcement, and Criminal Investigations Ganeden Biotech Inc. 08-Dec-06 Department of Health and Human Services !"# + $ %"&'!( ')*!! , -. "#'/ !*( &!)) 0-. "#'/ !*( &! # 1$&)) 2 8 "*#"3 ; < 3 42 5 67 9 $: 4 $ ')% $ %%#&%( %)'% ; 3 2 5- : ')$&)) '#$&)) , $ : + ,<$ + ,<$ +; : . , +; 3 +; +; 92 < $ $ ,? ? 222 =2 > , @ $ : $ /, = + ,<$ +; ,<$ 2 < . /> +; + ,<$ +; 8 $ , , ,< 2 < =3 +; + , , , $< 2 2 A , $ , , < 5 , , $ < + , 2 , < < A B &# , , < < < ! > + + , ,<$ ,<$ ,<$ # $ @ ' ) ./ . '/ $2 , < < + 2 &# < , $ < #)# * / . 1/ ./ C> 2 , A < 2 A , < < "" +; +; +; 3 $ = : + + ,<$ ,<$ +; , +; + ,<$ +; 8 =3 + : +; ,<$ 5/21/2012 11:16 AM 2006 > Ganeden Biotech Inc. 08-Dec-06 2 of 3 +; : '%'. / . #/ C http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2006/uc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inks on this page: # ,? ? 222 < 9 : F ; , 5/21/2012 11:16 AM 2006 > Ganeden Biotech Inc. 08-Dec-06 3 of 3 + , http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2006/uc... < H #)*)'F 2 , , $; &)**' #( 111( : F ( . #( 111( % '( ''&/ 6 8 < <: < 6 < , : F2 6 + 6 : , ? , 3 : < Links on this page: # ,? ? 222 5/21/2012 11:16 AM 2007 > Efficas, Inc. 28-Sep-07 1 of 3 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2007/uc... Inspections, Compliance, Enforcement, and Criminal Investigations Efficas, Inc. 28-Sep-07 Department of Health and Human Services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fficas, Inc. 28-Sep-07 2 of 3 3 6 F9 ' "1I & F4 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2007/uc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inks on this page: ) 6. < < ::: & 3 * 5/21/2012 11:15 AM 2007 > Efficas, Inc. 28-Sep-07 3 of 3 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2007/uc... +' / 6 2 6 3 ( )!M!,/ : 6 6 !MM, )0 %%%0 ' / +0 4 )0 %%%0 #@,0 @,, 5 $ H 3 - 3' & &3 $ 3 6 ' /: $ 2 $ ' 6 < G ' 6 +& & 3 & Links on this page: ) 6. < < ::: & 5/21/2012 11:15 AM 2009 > Nestle Healthcare Nutrition, 12/3/09 1 of 4 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2009/uc... Inspections, Compliance, Enforcement, and Criminal Investigations Nestle Healthcare Nutrition, 12/3/09 Department of Health and Human Services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estle Healthcare Nutrition, 12/3/09 2 of 4 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2009/uc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estle Healthcare Nutrition, 12/3/09 3 of 4 4 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2009/uc... 3 4 4 2 / 2 # 4 44 $ (-; ; / !" 3 ;/ %), !%!, *! ) / ;; L/ . ; 4 ( /B / 2 ( 2 /( ; 4 -; ; ( ;9 ; ()% (4 / 2 3 ;/ 2 ( ; 2 /0 , A &1 ( 7 . ;/ ( /4 /( 55 ' J -; ; ; ; 44 4 ;/ $ + 4 -; ; MMMMMMMMMMMMMMMMMM )A ' A *AA(A *!!0 $ ( / ! ?*A 0 1 0 *1 E ' % %60 = 1 0 &1 01 E ' A *!! % % )A !(%66%1 E )A )A ' ' N ; 3 /+ B / L A *!! A *!! Links on this page: / 7 -3 $ 4 . 4 / J % 6 *$ 2 4 4 ( %, &&&, 3 $ -, 9 66* 0 %, &&&, "A*, A** 1 5/21/2012 11:14 AM 2009 > Nestle Healthcare Nutrition, 12/3/09 4 of 4 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2009/uc... N / ' ' /3 ; ;/ 9 / 4 3 $2 9 . 9 3 4 5 G 3 4 -; ; / ; Links on this page: 5/21/2012 11:14 AM 2004 > Garden of Life, Inc. 11-May-04 1 of 6 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2004/uc... Inspections, Compliance, Enforcement, and Criminal Investigations Garden of Life, Inc. 11-May-04 Department of Health and Human Services' logoDepartment of Health and Human Services !! " #$ % & '()*++ ( " + # )(* ), )('(+ *)(- ( *( ),+ ,. #(**() #/ !0/ $& " ) . && !!0 ' 2#2 !!, 3 ! 4 " ' '(1 4 $$0!%/ &5!& 6 7 8 7 $ !!0 9 1 ; 2 => 2 79 ' < # 9 9 2 9 29 2 9 &0057 9 2 ; + : & ;;; 2 99 2 9 ? !&< = < &= < 4= 2 9 2 !& < = < &= < 4= 2 * -/ A < 1 A 4 @ ; < 2 =2 9 9 2 2 6 = 6 6 /B C 2 # /B " 9 / A 2 2 /B 9 2 * 9 ; 9 2 2 2 2 2 2 2 ; C * 2 C ' D ' ; (E C 9 /B ' D ; 2 9 9 : 2 2 2 6 5/21/2012 11:10 AM 2004 > Garden of Life, Inc. 11-May-04 2 of 6 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2004/uc... *2 6 * 2 9 6B 9 2 2 2 * 6B + B ? 4 ; 2 9 9 + 2 9 B ; 9 2 99 2 2 C 9 C 6 *2 6 B ; 2 / ' C B ' / > 9 ; / : / 2 2 / 2 9 9; 2 2 9 F 9 ; B ? 9 ' 2 2 9 / 2 9 = < 9 C C 9 2 D ' 2 2 / / 2 B 2 3 ? ' 9 2 C (E 9 2 2 1 # 2(E 9 9 C *: < = ' C ' 1 / / 9 ; E 9 9 B ?@ 9 ; 2 2 G ; 16 *2 6 B ' / 2 B 9 9 # B ' 9 # #' ) ; C C 99 2 2 C 2#26 2 B ) ; 22 2#2 ) 9 2 9 C 6B 29 2 9 2 2 * 9 9 ; / 9 9 2 2 ; CB ) 9 C 6B 2#2 : ( 9 9 9 2 2 92 2 2 2 9 2; C 6B ( # HB * 2 9 ; 2 9 2 2 9 2 CB ; 2 9 C 9 2 9 9 : 6 2 9 >+/ > +2 6 */ 2 6 B>+ ; 2 *: (E 9 2 9 9 * 2 9 2 F 9; 2 9 ; 6B ' 9 9 / ; 2 >+ 9 9 9 2 C ' 5/21/2012 11:10 AM 2004 > Garden of Life, Inc. 11-May-04 3 of 6 ) 9 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2004/uc... (2 2 C 2+ 2 I C B ' + '1J/ + 2 2 # 2 ; 9 9 9 9 9 ' /B 9 K : ' D ; 2 C *9 + +/B 2 9 / A /2 62 ' ' D ' ; (E 2 /2 2 /B 9 9 K C E ; 2 2 ; H )"/ &!6 *2 6 B / 3 * 6B + B ' # 2 / 4 / +' C 2 2 C 8!C ; 9 9 + ) 9 9 2 9 6 9 #9 6 2 B 2 < 9 2 = 2 B " 9 + 9 9 'C : 9 9 ; 2 H : *+ (,* ; * C B 4 9 * 2 2 : 9 6 9 . 2 2 + 3 2 : 4 2 2 E 9 *9 +. C 2 2 9 2 9 D #9 F B 2 " 9 D : 2 9 " : . D > / 9 9 9 2 99 : ,; 9 F 2 ! 2 99 < , ; * &!& 5$< = =* 2 2 2 2 ? @4 9 2 !& < 9= ; = 99 2 ( < 2 2 + 2 !& < = < &= < 4= 2 ; : ; ; 2 2 2 9 99 2 ) 9 A 2 ; 96 L L 2 99 2 99 = 2 L 2 2 B ?& L 2 L N L 2!!!&!O L 2 C ' P$0$<= < O= < 4= @ M < 9 2 &' ) P D " 1" & 9 9 2 1" ' $O! < = < $= ; 9 2 ; * ; 9 2 2 1" 2 2 9 ; M 2 2 9 2 " 1" * 2 ; # 2 2 9 9 2 2 9 2 F 2 9 2 2 M ? & ' ) &!& 5< K = < 8= <= @> 2 2 2 )"/ &! 2 2 9 2 2 2; 9 )"/ &!1" 2 1" 5/21/2012 11:10 AM 2004 > Garden of Life, Inc. 11-May-04 4 of 6 2 1" 2 http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/2004/uc... # " 9 2 1" 2 9 2 9 M 2 ; 9 M 9 ; 4 M " 2 2 ; 2 1" 99 9 + * 9 9 9 " 2 2 2 2 2 2 1 2 2 9 2 2 9 )"/ &!1" 9 , 2 )"/ &!1" 0!$< M= < &= 2 & ' ) &!& 5 K 1" 2 E 2 9 2 1" >+1" 2 (E 9 # 2 2 2 ; 6 6 )"/ &!1" B )"/ &!1" : ; 9 29 2 2 2 2 2 2 E9 " J B " 2 9 2 ) I + C 2 C ' >+1" B * 2 ' 2 2 ; 9 1 9 9 ; 2 F ; : 99 2 !& < 9= 2 2 2 ; 2 99 * < 9 # 9 * > 2 F 2 * 2 ; 9 2 9 2 = 2 22 : 9 ;;; K + 9 9 ; 9 9 ; 2 2 9 2 ; ; 22 2 7 ; 22 < & =; : 2 ; : $! !!0 9 9 2 2 " ' ; + : *+ (,* * 9 9 ' !! " LL ( : 9 2 ; 9 + 2 ; 9 I > 9 2 2 9 : ; !&< = < &= < 4= 2 9 : 9 2 2 9 ; 2 2 ; 2 2 2 : 99 F : 9 ' 22 ; ! / 9 9 ;;; 6 F >+ / 1"D C * * 2 9 9 2 ; 2; 9 + 9 9 ; 12 2 $%& ) 5/21/2012 11:10 AM Warning Letters > Physician Therapeutics, LLC 4/8/10 Page 1 of 4 Inspections, Compliance, Enforcement, and Criminal Investigations Physician Therapeutics, LLC 4/8/10 "8 < # ' 0**1 1 "+ 1 # #* * + # # , ? +* $- 0 1 @' $; .; ! * /$ $ ; $ 0 A/$ $ ; . Department of Health and Human Services $ * ! % &' + "# ( , * "# ) $ -- -). / 0 "1 2 + # # # * 3* # # 14 5 1 * , " # # + # # # 1 "+ *1" # # # ", # " 1 2 1 "+ # # 6 *' 1 #* 7" 1" 1 # 0 1 0**1 "+ 1 * # #3 # # 4& 1 * , * #* *8# 11" +0 9 #* *,,* *" , * # #1* *# 2 + 12# ", # " * * * 1 "+ *1" # # # *" , 1 # 8"# ! 1 "+ *1" # "1 8"# *# #1# */ 2 :! ! : *1* 4 = # > : ( 8 >* ;. *' *' . *' 63 < 1 * *1* 63 ! > 63 . + >* 1 . + + # # 4 = * ;. + 1 1( & 1* 4 = http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm208680.htm 6/10/2013 Warning Letters > Physician Therapeutics, LLC 4/8/10 : ( 8*5 # :! > : *' 63 0"*5 # *' * :! 63 ! 1 >* *' >* : # 1 :! ,1 3 3 ? # + * *1* ). #1 + . + 1( & 1* 4 = 1 63 ! * # ; 3 (8 : Page 2 of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http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm208680.htm 6/10/2013 Warning Letters > Physician Therapeutics, LLC 4/8/10 Page 3 of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http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm208680.htm 6/10/2013 Warning Letters > Physician Therapeutics, LLC 4/8/10 Page 4 of 4 Links on this page: http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm208680.htm 6/10/2013 Warning Letter to Metagenics, Inc. 1 of 3 http://www.casewatch.org/fdawarning/prod/2003/metagenics.shtml Search Home Your Guide to Health-Related Legal Matters Department of Health and Human Services Public Health Service Food and Drug Administration Los Angeles District 19701 Fairchild Irvine, California 92612-2506 Telephone (949) 608-2900 CERTIFIED MAIL Return Receipt Requested October 1, 2003 WARNING LETTER W/L 53-03 Jeffrey J. Katke, CEO Metagenics, Inc. 100 Avenida La Pata San Clemente, California 92673 Dear Mr. Katke: Investigators from the U.S. Food and Drug Administration (FDA) performed an inspection of your facility from May 6, 2003, to May 19,2003. During the inspection, the investigators collected labels from your products UltraClear®, UltraMeal®, UltraInflamX™, and UltraGlycemX™. FDA reviewed the labels for these products and found that the labels cause the products to violate the Federal Food, Drug, and Cosmetic Act (the Act) in several respects. The products are labeled as “medical foods,” and are represented on the labels as intended for use with a variety of medical conditions. The products do not meet the definition of a medical food in 21 USC 360ee(b)(3), which defines a medical food as a food which is formulated to be consumed or administered enterally under the supervision of a physician and which is intended for the specific dietary management of a disease or condition for which distinctive nutritional requirements, based on recognized scientific principles, are established by medical evaluation. The regulations further define a medical food as one that is intended for the dietary management of a patient who has special medically determined nutrient requirements, the dietary management of which cannot be achieved by the modification of the diet alone [21 CFR 101.9(j)(8)(ii)]. Your products UltraClear®, UltraMeal®, UltraInflamX™, and UltraGlycemX™ are not medical foods because the diseases and conditions described in the product labels do not have distinct nutritional requirements and because the products do not have any unique impact on the dietary management of those diseases and conditions beyond that which could be achieved by modification of the normal diet alone. 5/21/2012 12:14 PM Warning Letter to Metagenics, Inc. 2 of 3 http://www.casewatch.org/fdawarning/prod/2003/metagenics.shtml Because UltraClear®, UltraMeal®, UltraInflamX™, and UltraGlycemX™ do not meet the definition of a medical food, they are not subject to the exemption from nutrition labeling afforded medical foods. Therefore, your products are misbranded within the meaning of Section 403(q)(1) of the Act because the labels do not bear nutrition labeling in the appropriate format, as prescribed in 21 CFR 101.9. In addition, your products bear label claims suggesting that they are useful in the treatment of various diseases. These claims include: UltraClear’ is formulated to nutritionally support overall liver detoxification activity and the removal of potentially harmful toxins associated with health conditions such as food allergies, chronic fatigue syndrome, . . . and migraine headaches. “UltraMeal® is . . .designed to nutritionally support the management of conditions associated with altered body composition, including . . . hypertension . . . .” “UltraInflamX™ NUTRITIONAL SUPPORT FOR INFLAMMATION” and “UltraInflamX™ is designed to nutritionally support patients with chronic inflammatory conditions, such as osteoarthritis, rheumatoid arthritis, psoriasis and eczema, as well as other conditions associated with excessive inflammation.” “Designed to provide nutritional support for those with insulin resistance, or type 2 diabetes, UItraGIycemX™ promotes a healthy insulin and glucose response.” The presence of the above referenced claims indicates that the products are intended to treat, cure, or mitigate diseases. Such claims are evidence that the products are intended for use as drugs within the meaning of Section 201(g)(1)(B) of the Act. The products are new drugs under section 201(p) of the Act because there is no evidence that these products are generally recognized as safe and effective for their intended uses. Therefore, they may not be legally marketed in the United States without approved New Drug Applications (Section 505 of the Act). These products are also misbranded within the meaning of Section 502(f)(1) of the Act because the labeling fails to bear adequate directions for use. The above violations are not meant to be an all-inclusive list of deficiencies in your products and their labeling. It is your responsibility to ensure that products marketed by your firm comply with the Act and its implementing regulations. The Act authorizes the seizure of illegal products and injunctions against manufacturers and distributors of those products. You should take prompt action to correct these deviations and prevent their future recurrence. Failure to do so may result in enforcement action without further notice. Please advise this office, in writing, within fifteen (15) working days of the receipt of this letter, as to the specific steps you have taken to correct the violations noted above and to assure that similar violations do not occur. If corrective actions cannot be completed within fifteen working days, state the reason for the delay and the time within which the corrections will be completed. Your response should be directed to Mr. Larry Stevens, Compliance Officer, U.S. Food and Drug Administration, 19900 MacArthur Blvd., Suite 300, Irvine, CA 92612. Sincerely, /s/ Alonza E. Cruse Director, Los Angeles District 5/21/2012 12:14 PM Warning Letter to Metagenics, Inc. 3 of 3 http://www.casewatch.org/fdawarning/prod/2003/metagenics.shtml This page was posted on July 9, 2005. Make a Donation | Search All of Our Affiliated Sites | Home Links to Recommended Companies PharmacyChecker.com: Compare drug prices and save money at verified online pharmacies. Natural Medicines Comprehensive Database. Trustworthy information on dietary supplements and herbs. ConsumerLab.com: Evaluates the quality of dietary supplement and herbal products. Outdoor lighting by Arcadian: Best prices and services on outdoor lighting fixtures. OnlyMyEmail: Award-winning anti-spam services. Herbal Medicine, 3rd edition. Excellent reference book, discount-priced. 10 Types: Website design, development, and hosting with superb technical support. 5/21/2012 12:14 PM MEMORANDUM DEPARTMENT OF HEALTH AND HUMAN SERVICES PUBLIC HEALTH SERVICE FOOD AND DRUG ADMINISTRATION CENTER FOR DRUG EVALUATION AND RESEARCH DATE: February 20, 2001 FROM: Parivash Nourjah, Ph.D. Signed 02-26-01 Division of Postmarketing Drug Risk Assessment I, HFD-430 THROUGH: Julie Beitz, M.D. Signed 02-21-01 Director, Division of Postmarketing Drug Risk Assessment I HFD-430 TO: Kent Johnson, M.D. Division of Anti-Inflammatory, Analgesic, and Ophthalmologic Drug Products HFD-550 SUBJECT: Epidemiologic evidence of DHEA in the etiology of neoplasia PID#: D000665 SUMMARY We are not aware of any published epidemiologic studies that examine the cancer risk associated with exogenous dehydroepiandrosterone (DHEA) administration. However, one case-report was found to describe the medical condition of a patient with advanced prostate cancer after receiving DHEA. The cancer condition worsened after receiving DHEA, but when the patient stopped taking DHEA, the cancer regressed. Since the discontinuation of DHEA was accompanied by the initiation of estrogen therapy, the association of exogenous use of DHEA with the cancer progression is unclear. In general the epidemiologic studies reviewed in this report have many limitations. Temporal precedence bias, small size, inability to control for confounding variables, and the method of DHEA measurement 1 are among the most common limitations of studies reviewed in this report. No meaningful conclusion about the association of exogenously administered DHEA and cancer risk can be made based on these epidemiologic studies of endogenous levels of DHEA. INTRODUCTION This consult follows Dr. Brinker’s comprehensive report on the relationship of endogenous sex hormones and etiology of cancer dated January 4, 2000. The purpose of this consult is to review the literature again to identify any reports on exogenous use of DHEA and cancer risk. In general, the epidemiological data addressing the association of endogeneous DHEA with cancer are very limited and the results are conflicting. The studies varied in study design and size, method of DHEA assessment, stage of cancer and ability to control for confounding variables. The study designs are either prevalence case-control or nested case-control studies. In general, the temporal association between DHEA levels and cancer cannot be established in prevalence case-control studies. In these studies, one cannot determine whether the change in DHEA level is caused by the cancer or whether any change in DHEA level is a predisposing factor for cancer. The size of the studies is often very small,so that, adjustment for confounding variables (even if they were collected) is not possible. In most studies reviewed, some of the important confounding variables were controlled by conducting a matched design followed by matched analysis. In recent years, DHEA can be found at local health food stores, supermarkets, pharmacies, and Web pages from many companies, and is advertised as an antiaging agent. Therefore, any recent study of DHEA and cancer should consider both the use of DHEA as a dietory supplement and the level of endogenous DHEA. None of the recent studies ascertained any information on the exogenous use of DHEA. The method of measuring DHEA is also crucial and often is far from perfect in these studies. DHEA levels in serum change by diurnal and menstrual cycles. Thus any studies which examine DHEA should consider these cyclic sources of variability in their design. 2 We found one case-report study from the literature in which the author suggested that the administration of DHEA to patients with prostate cancer should be done with caution. METHOD We conducted a literature search by using the National Library of Medicine’s PubMed search engine to identify epidemiological studies. We used neoplasia and DHEA to identify the studies. For the purpose of this report, we selected those studies which were not reported by Dr. Brinker previously. STUDY SUMMARIES Prostate Cancer: Stahl et al (1992) conducted a prevalence case-control study to compare the DHEA levels in 19 prostate cancer patients with the DHEA levels in 23 age-matched controls. The DHEA level was assayed by RIA kits. They found that the levels of both DHEA and DHEAS (DHEA-sulfate) were significantly lower in prostate cancer patients than the control group. This study lacked any information on the quality of DHEA samples. Comstock et al (1993) conducted a nested case-control study within a cohort of volunteers who participated in a [ ] Blood Bank study. From August to November 1974, 25,620 volunteers donated blood to study serum factor precursors of cancer. Comstock et al compared the DHEA/DHEAS level of 81 prostate cancer patients with 81 age-sex-race matched controls. All the cancer patients were diagnosed for the first time between 1974 and 1987. All blood specimens were frozen after donation and rethawed before reading. The serum samples of cases and their controls were assayed on the same day. DHEA/DHEAS levels were assayed by using radioimmunoassay (RIA) kits from Wein Laboratory. Although not statistically significant, this study showed that both DHEA and DHEAS levels were lower in prostate cancer patients than their control group. The authors noted no dose-response association with either DHEA or DHEAS. One potential limitation of this study is 3 temporal precedence bias. The possibility of this bias cannot be ruled out, since the latency of prostate cancer is long and the cancer patients could have had cancer at the time of blood donation. Jones et al (1997) published a case report in which a patient with advanced prostate cancer was treated with DHEA. The administration of DHEA flared up his cancer while it reduced some of his symptoms. Upon the discontinuation of DHEA, the size and firmness of the prostate diminished, and the level of prostate-specific antigen (PSA) and testosterone decreased. Since the discontinuation of DHEA was followed by the initiation of estrogen therapy, it is not clear whether the improvement of his cancer was due to estrogen therapy or due to the discontinuation of DHEA. It is noteworthy that the patient was previously unresponsive to hormonal therapy, and whether the DHEA treatment had any impact on his conversion to being responsive to estrogen therapy is an interesting question. Ovarian cancer Helzlsouer et al (1995) conducted a nested case-control study within the [ ] blood blank study. They identified 31 newly diagnosed ovarian cancers between 1975 and 1989. For these cases, 62 controls were matched on age, menopausal status, and for premenopausal women, the number of days from the beginning of the last menstrual period. Serum samples were frozen at –70° C after donation and thawed right before preparing the aliquots for this study. The DHEA/DHEAS levels were assayed by using RIA kits and performed for each case and matched control set at the same day. The investigators showed that the levels of DHEA/DHEAS in serum were much higher in cases than controls. There could have been a temporal precedence bias in this study since the cases were identified within a year of blood donation. Whether some women had cancer at the time of blood donation is unknown. Weight, a known risk factor for ovarian cancer, was not collected, so the study could not control for its effect. Breast cancer: Zumoff et al (1981) conducted a prevalence case-control study, in which the 24-hr mean levels of 4 serum dehydroisoandrosterone (DHA) level and dehydroisoandrosterone sulfate (DHAS) of 11 women with primary operable breast cancer were compared with 37 healthy women. The DHA level was assayed by the radioimmunoassay technique as described by Rosenfeld and the DHAS was assayed by radioimmnoassay as described by Nieschlag. The study showed that postmenopausal breast cancer patients had higher DHA and DHAS plasma levels than the healthy women, while the premenopausal breast cancer patients had lowered DHA and DHAS than controls. Solid tumors: Lissoni et al(1998) conducted a prevalence case-control study to examine the association of DHEAS with stage of cancer. The study consisted of 70 patients with solid tumors and 100 age-sex-matched healthy controls. The histologic types of cancer were: gastrointestinal tract tumors:28; breast cancer: 24; non-small cell lung cancer: 18. There were 28 patients without and 42 patients with distant metastases. Blood sera were collected in the morning after an overnight fast, and DHEAS was assayed by RIA method using commercially available kits. The result of this study showed that irrespective of tumor histologic types, the serum level of DHEAS was similar between early cancer patients and the control group. Advanced cancer patients had much lower DHEAS levels than controls. DISCUSSION DHEA and DHEA-Sulfate are major adrenal secretory products in humans. They possess androgenic activity as they are metabolized to steroids such as testosterone. Thus, the association of testosterone and estrogen on the risk of breast cancer and prostate cancer can shed some light on the association of DHEA and neoplasia. While the evidence for an association between testosterone and the risk of prostate cancer is still conflicting, there is substantial evidence of an association between estrogen and breast cancer. There are epidemiologoic studies which directly examined the association between endogenous DHEA and cancer risk; however, the epidemiologic evidence for an association is not consistent. For prostate 5 cancer, two epidemiologic studies [Stahl (1992) and Comstock (1993)] showed that cancer patients had lower DHEA levels than their non-cancer counterparts. Based on these studies, one might expect that DHEA therapy may improve the prostate cancer, however, the result from the case-report [Jones(1997)] suggests that the use of exogenous DHEA may worsen prostate cancer. For ovarian cancer, compared to prostate cancer, a different result is suggested for the association of endogenous DHEA and cancer risk. The serum DHEA level was found to be higher in ovarian cancer patients than the control counterparts [Helzlsouer (1995)]. The association of DHEA and breast cancer could be different in pre- and post-menopausal women. In postmenopausal women, a positive association between DHEA level and breast cancer was reported by Cauley(1999) and Zumoff (1998) studies. The latter study showed that in premenopausal women, the level of endogenous DHEA was lower in breast cancer patients than the healthy controls. In general the epidemiologic studies reviewed in this report have many limitations. Temporal precedence bias, small size, inability to control for confounding variables, and the method of DHEA measurement are among the most common limitations of studies reviewed in this report. No meaningful conclusion about the association of exogenously administered DHEA and cancer risk can be made based on these epidemiologic studies of endogenous levels of DHEA. ____Signed by__________ Parivash Nourjah, Ph.D. Epidemiologist __Signed by_______ Anne Trontell, M.D. Deputy Director 6 REFERECES Cauley JA, Lucas FL, Kuller LH, et al: Elevated serum estradiol and testosterone concentrations are associated with a high risk for breast cancer. Study of Osteoporotic fractures Reseach Group. Ann Intern Med 1999;130:270-7. Comstock G.W., Gordon G.B., and Ann w Hsing: The relationship of serum dehydroepiandrosterone and its sulfate to subsequent cancer of the prostate: cancer epidemiology, Biomarkers and prevention 1993 Vol 2, 219-221 Lissoni P, Rovelli F, Giani L, Mandala M, Meregalli S, Barni S, Confalonieri G, Bonfanti A. Dehydroepiandrosterone sulfate (DHEAS) secretion in early and advanced solid neoplasm: Selective deficiency in metastatic disease. Int J Biol Markers 1998; 13:154-157. Helzisourer K.J., Alberg A.J., Gordon G.B., Longcope C., Bush T.L, Hoffman S.C., Comstock G.W.: Serum gonadotropins and steroid hormones and the development of ovarian cancer. JAMA 1995; 274:1926-1930. Jones J.A., Nguyen A., Straub M, Leidich R, Veech R.L., and Wolf S.: Use of DHEA in patient with advanced prostate cancer: a case report and review. Urology 1997 50:784-788. Schatzl G, Reiter WJ, Thurridl T, Waldmuller J, Roden M., Soregi S, and Madersbacher S.: Endocrine patterns in patients with benign and malignant prostatic diseases. Prostate 2000 44:219-224 Stahl F., Schnorr D, Pitz C., and Dorner G: Dehydroepiandrosterone (DHEA) levels in patients with prostatic cancer, heart disease and under surgery stress. Exp Clin Endocrinol 1992, Vol 99, 68-70. Zumoff, b., Levin, J., Rosenfeld R.S., Markham, M. Strain, G. W. and Fukushima, D.K. Abnormal 24hr mean plasma concentrations of DHEA and DHEA-sulfate in women with primary operable breast cancer. Cancer Res. 41:3360-3363, 1981 7