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Dear Doctor: As you may be aware, on Friday, September 3, 2004, the FDA cited concerns about ProHeart 6 and issued a press release requesting the recall of the product. Fort Dodge Animal Health has voluntarily complied with the U.S. Food and Drug Administration Center for Veterinary Medicine's request to temporarily cease marketing and recall ProHeartâ 6 to the veterinarian level until the FDA's questions regarding safety are resolved. Fort Dodge Animal Health has also announced its strong support for FDA's formation of an independent Advisory Panel to review and evaluate safety data on ProHeart 6. While Fort Dodge Animal Health is cooperating with FDA's request for a recall, we strongly disagree with the Agency's interpretation of the data and the conclusions that were drawn. Based on a thorough evaluation of FDA's data, and consultation with independent experts in veterinary medicine and epidemiology, Fort Dodge Animal Health remains extremely confident in the safety and efficacy of ProHeart 6. The Company fully supports the initiation of the review process, and will work closely with FDA to provide the necessary information for the panel to make a fair and accurate assessment in a very timely manner. Our first and foremost concern is providing safe and effective products to ensure the health and well being of all pets. It is important to note the voluntary recall of ProHeart 6 has no impact on any of Fort Dodge's other pharmaceutical or biological products. As a committed partner to veterinary practitioners, livestock producers and pet owners worldwide, Fort Dodge continues to make a difference in the future of animal health through innovative research and product development that addresses current and emerging animal health needs. Formal recall information, with detailed instructions about return of product, will be sent to you. Until that time, we ask you to remove the product from your inventory and cease using it. We encourage you to call our Professional Services department at 1-800-533-8536 if you have additional questions, or to contact your Fort Dodge territory manager. Thank you for your prompt attention to this important information. Sincerely, <signed> Brent Standridge PH6 is generally well tolerated. A small percentage of dog showed mild, transient swelling or itching at the injection site. While rare, digestive, neurological or hypersensitivity reactions may occur. For any additional questions, please call 1-800-477-1365. Information About the Voluntary Recall of ProHeart 6 Response to FDA Concerns FDA Concern Fort Dodge Response Since launch in 2001 through August 2004, the overall rate of reports for ProHeart 6 has been calculated at approximately 3 unfiltered reports for each 10,000 doses sold. Independent data from one of the most comprehensive databases available in the U.S. indicates a reporting rate of 4 reports per 10,000 doses actually administered to dogs. Considering the difference between "doses sold" to veterinarians and "doses administered," we believe this data to be representative of what is occurring in actual field use, and disagree with the FDA's assertion that there is significant "under reporting" with the product. Our belief is underscored by the fact that ProHeart 6 is administered only by veterinarians, and has received undue media and Internet attention, both of which increase the likelihood of event reporting. Nonetheless, the breakdown of unfiltered reports is as follows (based on reports per 10,000 doses): · For allergic reactions, the number of unfiltered reports for May 02 - April 03 was 2.2 per 10,000 doses. From May 03 - April 04, that number was 0.85 per 10,000 doses. · For illness, the number of unfiltered reports for May 02 - April 03 was 2.1 per 10,000 doses. >From May 03 - April 04, that number was 0.98 per 10,000 doses. · For death, the number of unfiltered reports for May 02 - April 03 was 0.4 per 10,000 doses. >From May 03 - April 04, that number was 0.28 per 10,000 doses. Regarding death reports for ProHeart 6, the FDA was quoted in the November 2003 issue of DVM News Magazine: "The FDA claims that nine of the 240 reported deaths are directly tied to the drug." This statement indicates the FDA's conclusion that the vast majority of the deaths reported for ProHeart 6 are unrelated, which is in line with Fort Dodge's data. Noted in this document are examples of dogs included in the adverse event database. Despite medical evidence that reflects health issues not related to ProHeart 6, the cases are included in the analysis of the database and the subsequent conclusions. FDA Concern Fort Dodge Response Research by Bronson (Am J Vet Res, Vol. 43, No. 11, p.2057-2059, 1982) shows the mean age at death from hepatic necrosis as 4.9 years. The FDA's own data reflects the average age for liver signs, with relation to ProHeart 6 reports, as 4.5 years, which is in keeping with the baseline canine population in the U.S. Based on unfiltered reports with some reference to hematologic signs/autoimmune signs, the incidence rate for ProHeart 6 is 0.0025 percent or one in approximately 31,000 doses. Again, Bronson reported that one percent of all deaths in dogs were due to hemolytic anemia. Even with unfiltered reporting numbers, ProHeart 6 is well below the baseline of disease for the U.S. canine population. FDA Concern Fort Dodge Response FDA Concern Fort Dodge Response It is estimated that almost half of all pets over the age of 10 will develop cancer (Cancer in Dogs and Cats, Brakke Consulting, 2002). While cancer is more common in older dogs, it does occur in young ones, as well. In the unfiltered reports for ProHeart 6, the rate of cancer is 0.07 reports per 10,000 doses. Nearly 77% of these cases are in dogs older than six years. The Veterinary Cancer Registry shows 75% of dogs with cancer are seven years or older. Cohen, et al. (Cohen, et al., Cancer Research, Epidemiological Analysis of the Most Prevalent Sites and Types of Canine Neoplasia Observed in a Veterinary Hospital, 34: 2859-2868) reported 2,499 cancer cases in 60,000 dogs presented to veterinary hospitals over a 12-year period. The rate of prevalence was 4.2%. The unfiltered ProHeart 6 database shows 122 reports out of 18.2 million doses (through April 2004) with a diagnosis of cancer, which is considerably lower than that seen in the general canine population. In addition, the wide range of cancer seen in the unfiltered ProHeart 6 reports is reflective of the range of normally occurring cancers seen in the general canine population. An example of a dog included in the cancer category for ProHeart 6 is as follows: The dog, a 10.5-year-old Yorkie with a known sensitivity to ivermectin (lethargy and vomiting), was treated with ProHeart 6. Approximately four months later, the dog presented with anorexia, ataxia and lethargy. Initial diagnostic evaluation revealed bilateral luxating patellas. The dog was also thought to have a possible liver problem or a tumor, but the owner initially declined medical treatment and a further diagnostic evaluation. A referral veterinary ophthalmologist later examined this dog for a vision problem. While the veterinarian could not make an initial definitive diagnosis, he did note that if this problem were pharmaceutically related, he would expect the problem to be symmetric, not asymmetric as exhibited by this dog. Eight months after the injection, the dog was diagnosed with lymphoma in its right eye. The veterinary ophthalmologist noted he has seen this same problem in a number of dogs that had not been administered ProHeart 6. Evidence of glaucoma was found in the other eye. Approximately one month later, the dog was euthanized at the owner's request because of the dog's difficulties. Two veterinarians told the owner that the lymphoma most likely spread to other parts of this dog's body. The referral veterinarian suggested a necropsy be performed; the owner declined. Despite the evaluations of the attending veterinarians, FDA has assigned the following signs in this dog as being "probably related to the drug." - Anorexia, Depression/Lethargy, Neoplasm, Weight Loss, WBC High/Blood Problem, Ataxia, Circling, Blindness, Hyphaema and Eye/Eyelid Lesion. Lymphoma is a common cancer in dogs, with a reported incidence of 11.4 cases per 10,000 dogs per year (Morris & Dobson, ISBN, 0-632-05282-1). FDA Concern Fort Dodge Response FDA Concern Fort Dodge Response The rate of anaphylactic reactions has decreased from 2.2 per 10,000 doses in May 02-April 03 to 0.85 per 10,000 doses in May 03-April 04. In addition, there has also been a decrease in the "illness" category of reports from 2.1 per 10,000 doses to 0.98 per 10,000 doses, which supports the premise that many of the illnesses reported (vomiting, diarrhea) were allergy related. Frequently Asked QuestionsTo answer some of your questions and those raised by your clients, Fort Dodge has drafted the following information for your reference. If you have questions not covered in this document or you would like to discuss any issues further, please contact our Professional Services department at 1-800-533-8536. 1. What is the current situation with ProHeart 6? While Fort Dodge Animal Health is cooperating with FDA's request for a recall, we strongly disagree with the Agency's interpretation of the data and the conclusions that were drawn. The Company fully supports the initiation of the review process, and will work closely with FDA to provide the necessary information for the panel to make a fair and accurate assessment of these data. We look forward to working with the panel and remain confident in the safety and efficacy of ProHeart 6. 2. Was Fort Dodge required to comply with the FDA's request to voluntarily recall ProHeart 6? 3. Why did Fort Dodge not contact veterinarians in advance about the voluntary recall? Unfortunately, we could not respond to the FDA's position until they issued their press release, which occurred after 4:30 p.m. Eastern Time on Friday, 03 September 2004. We sincerely regret that the timing of this process was such that we were unable to alert our customers in a more timely manner. While dissemination of information to the media can be instantaneous and far-reaching, providing immediate information to tens of thousands veterinarians across the country proves significantly more difficult. We have posted these materials on the Veterinary Information Network, as well as www.proheart6dvm.com , for your convenience. If you have further questions, please call our Professional Services department at 1-800-533-8536. Fort Dodge Animal Health has consistently communicated with veterinarians about issues relevant to the animal healthcare industry, including ProHeart 6. Effective communication with our constituencies has been and continues to be a priority for Fort Dodge. 4. If ProHeart 6 has already been voluntarily recalled, why is an independent advisory committee being convened? 5. Does Fort Dodge plan to reintroduce the product at a later time? 6. What should dog owners do if they have used ProHeart 6 for their dog(s)? 7. What should I do if a pet owner feels his/her dog has had a reaction to ProHeart 6? 8. If ProHeart 6 is not available, what should dog owners' use? 9. How has the Internet impacted ProHeart 6?
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