CATS - Children Afflicted By Toxic Substances
Jama Russano
413 Fort Salonga Road
Northport, NY 11768
Ph: 631-757-4829
To: Food and Drug Administration
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852
Docket Number 2004D-0002
April 12, 2004
Dear FDA,
Over the last 12 years it has become clear that silicone and secondary
chemicals used in breast implants are a health risk to: Young Women, Women
of child bearing years and to a Fetus. Before Surgical Device's are approved
for Plastic Surgery Implantation, Manufacturers must conduct Clinical Trials
to evaluate the health risks on the following:
a.) Young women - ages 13 to 21:
What are the health effects on a young growing body.
Do silicone gel/oils along with secondary chemicals cause Endocrine
Disorders? Have adverse impact on growing bones, etc... Is a young woman
more promiscuous? Exposing her to HIV and Pregnancy?
b.) Emotional Health (before and after implant surgery).
Are young women capable of understanding that breast implants are a life
time of surgeries, that there is no turning back? Is it made clear that if an
adverse problem occurs that they must pay for their health care? Can Young
women understand and make the determination that she may not be able to
breast feed. Is a mother able to live with the guilt, that; a.) She is sick and
unable to take care of her family b.) She made her child(ren) sick?
c.) Women of child bearing age:
What are the hormonal effects?
Have their immune systems been compromised? Are they more propone to
infertility, miscarriages, and pregnancy problems such as placenta previa?
Are they getting Cancer and Auto Immune Diseases at an early age?
d.) Understanding the risks (before the surgery):
It needs to be documented (If women had the opportunity to go through the
surgery over again, knowing and experiencing the implants, would they have
made the decision not to have had the surgery? Looking back, do they feel
they were given all the information they needed to make an informed
decision)?
e.) The ability to breast feed after implant surgery:
Women's nerve endings are cut, milk ducts are blocked during implant
surgery. Many are unaware of these problems and many do not know if they
want to breast feed. It must be identified how many are effected by this type
of procedure.
e.) Health Risks of Breast feeding (silicone and secondary chemicals passing
through milk ducts):
Do silicone gel/oils and secondary chemicals migrate through the milk ducts,
exposing a new born to undeveloped esophagus? How, much of these
chemicals get through and what are the health effects.
f.) What are the overall health effects on children (short and long term,
regardless of breast feed or bottle feed):
Does silicone gel/oils and secondary chemicals cross the placenta barrier,
exposing the developing fetus to various chemicals. Do the chemicals used
in the manufacture of breast implants Endocrine Disrupters? Do children
grow out of their health problems? How many children are exposed? Are the
ill effects life time? Are they experencing bone and growth problems?
g.) All children born to a mother with an implant must be followed short and
long term, far past a 10 year period.
h.) Identifying First (silicone) and Secondary Chemicals (platinum, benzene,
etc.):
The FDA, Physicians and the consumer must have access to the combination
of chemicals that are used in the devices. Chemicals such as Phthalates are
used in manufacturing. When combined with other chemicals it could pose
various health problems to a human.
i.) Long term health effects on children (physical and emotional).
Once again, long term studies should be conducted. It has been reported
that many children exposed to a breast implant show signs of ADD, low or
high hormone levels. What is the emotional impact a child has, once a child
learns that he/she has been exposed to their mother's implants?
j.) Third Generation:
Can a child exposed to implants "via in-utero", cause harm to their children?
What happens when two adults exposed to implants have children?
k.) It has been stated that the FDA has no funding for Med Watch.
It is also clear that once a product is on the market, it is vary hard to get the
product off. If a device is approved, for market and the number of Patients
with complaints should be equal to the number of persons studied in the trial.
The device should go on probation until further evaluation can be done. The
FDA must bring more funding to the Med-Watch Program and the program be
properly monitored.
To get a clear understanding on all health risks and safety factors associated
with all types of
plastic surgery devices including silicone and saline breast implants,
Retrospective studies
outlining the above should be conducted on the hundreds of thousands of
young women and
children. These issues have been avoided far too long.
We have also learned that there is no substitute for properly conducted
prospective clinical trials. Post-market surveillance and postapproval
conditions are of little value to women considering breast implants after
approval. Further, we have learned of many instances where women have
been unable to report medical problems to the FDA through the MedWatch
system and that the FDA rarely considers the large number of adverse
events reported through the post-market surveillance system. For these
reasons, the FDA must ensure that long-term safety is addressed prior to
approval.