O.K., now for the “rest of the story.” This one is a little tangled, but stick with it…
In 1938 we got laws in the US requiring that drugs be shown to be safe by the FDA to be marketed.
In 1962 new laws were added requiring that drugs also be shown to be effective. This was also retroactive to previously approved drugs. Drugs that were approved prior to 1962 and were “identical, similar or related” to a drug that was found to be effective could get a “piggyback” approval.
In 1964 Estratest was first sold. It did not have FDA approval as required.
In 1972 the FDA found 5 estrogen+androgen drugs safe and effective for “menopausal syndrome in those patients not improved by estrogen alone.”
In late-1972 the company asked the FDA if Estratest could get approval as “identical, similar or related” to the 5 drugs above. The FDA’s reply is unknown, but since Estratest came on the market after 1962, it doesn’t meet the qualification for “piggyback” approval.
In 1976 the FDA again found the 5 effective but amended the labeling to read “moderate to severe vasomotor symptoms [hot flashes, night sweats] associated with the menopause not improved by estrogen alone.”
In 1979 the FDA wrote to the company telling them that Estratest was under legal review, and that no action relating to its approval would be taken.
In 1981 the FDA determined that Estratest might meet qualifications based on the 1976 findings, and the company filed an ANDA (
Abbreviated
New
Drug
Application) with the FDA.
In 2003 the FDA reviewed the available literature and found that there was a lack of substantial evidence that Estratest was more effective for vasomotor symptoms than estrogen alone. The FDA also reversed its 1972 and 1976 approvals of the 5 estogens+anrogens, but none of the 5 was still on the market. Here’s the full FDA docket, but I’ll warn you it’s a tough read:
FDA Docket. And here’s the FDA’s Talk Paper from 2003:
FDA Talk Paper. In it they say, “It has been FDA's long-standing policy to allow the continued marketing of drug products while matters such as these are being resolved, provided there is no documented serious public health or safety issue associated with such products.”
In December 2004 the safety data from Estratest, which is no worse than any other estrogen product, was used as back-up support for Proctor & Gamble’s application for the Intrinsa testosterone patch.
So here we are in 2005 and the FDA has not approved Estratest, nor have they removed it from the market. It’s been being used for 40 years and no one has found any safety problems with it. The FDA has determined it doesn’t work better for hot flashes than just estrogen, but no one has looked at the libido item. The FDA won’t review that claim until the company makes it. The FDA does hint at it in their 2003 Talk Paper, saying, “FDA encourages the development of clinically meaningful information about new uses of these combination products, including for the treatment of female sexual dysfunction.”
But for now Estratest is still in regulatory limbo.
-Margo