Historical Interviews
These remarks, by persons
involved with the silicone breast implant controversy, reflect only a
sample of the strong emotions aroused by the episode. This month the
entire issue of the new Epi Monitor is devoted to an interview with
scientists involved with the silicone breast implant controversy at
Dow Corning. This topic has been in the news throughout 1992 because
of questions raised about the safety of this medical device which has
been on the market for about 30 years. The reported lack of
satisfactory safety data has outraged many citizens and scientists,
and many have found it difficult to understand how we could have come
to be in the situation we now face with this product.
Since Dow Corning employs
epidemiologists, and most recently hired well-known epidemiologist
Ralph Cook from Dow Chemical, the Epi Monitor
interviewed Dr. Cook and his colleagues to get their perspective on
the controversy and how and why it developed. Included in the
interview were Robert LeVier, PhD, Technical Director
for the Health Care Business, who has been at Dow Corning for 20 years
and Myron Harrison, MD, the Corporate Medical
Director, who just joined the company. Most recently, Dow Coming has
withdrawn from the market, and the FDA has banned the use of the
implants except in special studies. We trust readers will find this
interview fascinating and will come away better prepared to deal with
similar challenges in their specialty areas if and when they arise.
Epi Monitor:
What is the key piece of information or the key database that the
company is or was relying on to assert that breast implants have been
safe?
LeVier: The
answer is ordinarily quite long, but I’ll try to compress it the best
I can. Dow Corning has something like 10,000 safety studies of
silicone of which 329 were included in the Pre-market Approval
Application (PMAA) as having direct and strong relevance to the safety
of the material that was used in the breast implant. Those studies
really show three events that are noteworthy. One is that there is
always a foreign body reaction to these materials, just as there are
to all known medical materials like polyethylene and metals and so on.
By foreign body reaction I mean there is an acute inflammatory stage
followed by a chronic inflammatory state that transitions over a few
weeks or months to the formation of a scar or capsule around the
implant. All materials do this. The second event is that, at least in
rodents in life-time studies, sarcomas are generated at the
implantation site immediately around and adjacent to the implanted
material. That’s been known since 1941, for all materials that have
been tested. Finding it for silicone was not a new event, and in fact,
the FDA recognized upon reviewing our data that that was the case.
Thirdly, is the absence of something. That is, there is an absence of
systemic toxicity across a very broad range of studies and through
several species. So overall when we looked at those 329 studies, our
conclusion on the basis of laboratory work is that silicone is like
other synthetic materials. They are not truly and absolutely inert—the
body does recognize them as foreign and responds to them as I’ve just
indicated.
Excuse me, I missed one point.
We also have evidence that very small amounts of mobile components of
implants distribute in the body; for example, polydimethyl siloxane
goes where you would expect it to go, namely to the reticulo-endothelial
system, as is the case for polystyrene microspheres and carbon
particles and other things. Those are the laboratory data. The other
supporting evidence comes really from the medical literature. There
are case reports of adverse effects like infection and contracture and
hematoma, and of course, some apparent rheumatic disease. All these
reports taken together in our opinion indicate that the incidence of
adverse effects is largely known, and is not particularly unexpected
in most cases...
Epi Monitor:
Can I interrupt you there...You say taken together they suggest the
incidence is low?
LeVier: For
example, let’s take infection. The incidence of infection is down
around the one to three percent range, virtually like what you would
expect from other procedures in hospitals. The rate of contracture is
higher than any of us would like, but it is known and surgeons know
what that rate is and what the corrective measures are. The data in
the literature provides no evidence whatsoever that these implants,
for example, cause breast cancer. I would cite the Deapen-Brody Study
as reasonable evidence that there’s not an excess of breast cancer.
The most contentious area is the rheumatic disease issue. But I would
point out that since 1964, the Miyoshi paper from Japan, there are
about 50 or so case reports of women with silicone breast implants
analyzed with rheumatic disease. Over a 28 year period that would not
strike us as necessarily different than a normal background.
Epi Monitor: If
I’m following the thrust of your answer here, it’s a little different
than the question I asked in the sense that you’re really answering
what is the basis for the company’s assertion that the devices are
safe. You’re going over two major categories of evidence—329 lab
studies and case reports from the literature which you interpret as
reassuring overall. Is that right?
LeVier: I think
those are the major ones. But I could add that our understanding of
the chemistry of the materials is also instructive and has bearing on
expectations for biological activity. Just to cite one example, the
chemistry used here is inherently not pyrogenic. If there should be
pyrogenicity as an issue, it would undoubtedly come from a
non-silicone source, such as bacterial contamination during
manufacturing or surgery, or something like that. You indicate that
I’m not quite answering your question...
Epi Monitor:
What I wanted to get at was, can you point to one or two or three
studies as the most key pieces of evidence for the assertion that the
implants are safe? In other words, what does the assertion ultimately
hang on? Maybe you feel it hangs on too many things to be able to say
that two or three are very key. That’s what I was trying to get at.
LeVier: Well, I
think the latter is absolutely the case. The full body of evidence
provides a spectrum of information that is most valuable here, but let
me try to respond to your question, nonetheless, in the way in which
you’ve posed it. If I think about pivotal studies, I would think of a
group of six studies we did on the effects of silicone on the immune
system—well done, GLP (Good Laboratory Practices) controlled,
essentially state-of-the-art studies—that conform in every way to what
the National Toxicology Program protocols would expect to be done.
Epi Monitor:
These are laboratory studies?
LeVier: Yes,
they are. Secondly, trying to stay with the spirit of your question, I
would cite a set of two studies. Our own animal studies showing
sarcomas, coupled with the Deapen-Brody Studies showing an absence of
apparent translation to humans.
Epi Monitor: An
article I read quoted one of your company’s consultants who said that
there were five key studies—that the crux of the company’s case was
based on doctors’ records of about 1,000 patients showing five percent
with complications, and less than one percent with serious
complications. These studies apparently were of records not of women
per se. So I wondered, in your own opinion, what were the key studies,
what was the crux of the matter from your point of view, and I think
that’s what you're answering now.
LeVier: You
bring up a good point. We do have clinical studies, a total of five,
as I recall that add up to a bit over 1,000 women. What I’m not
including are three studies that are still underway. And that body of
1,000 plus women is pivotal and instructive, and it is important in
regards to characterizing complications. I suppose in my own mind, I
didn’t list that as core, simply because there are so many studies in
the literature that are fundamentally supportive of that conclusion,
as well as the studies done by other manufacturers. It is important
but there are many other studies that come to bear on it.
Epi Monitor:
There are sometimes many studies, but for a variety of reasons,
they’re not done optimally and when something is considered to be
established, people often say, “well, it’s the Smith Study, or it’s
the Jones Study that really nailed this down,” either because it was
the largest study, or because it looked at the most important
variables or it had the best control group, whatever. When they have
to go back and say “what really established it?”, “what really proved
it?” they always fall back on that particular study. I was looking to
see if, in the mind of the company scientists, there was a key study.
If there is, I think it would be interesting and important to get that
out.
Cook: But
aren’t you discussing the other side of the coin, the key study that
showed lack of cause and effect? I think when you’re talking about
lack of cause and effect, you’re in that sort of catch-22 in that you
can’t prove a negative in a sense, but you’re looking at the
preponderance of data. And I think that’s really what Bob is saying,
that if you look at the preponderance of data and the consistency and
the coherence of the data, it seems to lead us in the direction that
these are safe materials.
Epi Monitor:
You can have a key negative study just as well as a key positive
study...
LeVier: In
regards to the cancer issue, I think we could fairly categorize the
Deapen-Brody Study as pivotal at this point, although additional
studies are underway and still other ones will be done.
Epi Monitor: Is
this the one that was done in California?
LeVier: Yes.
First reported, I think in ’86 and followed up every five years. They
just published their most recent update in the April Journal of
Plastic and Reconstructive Surgery.
Epi Monitor:
What are the most outstanding gaps or the greatest weaknesses in the
available information that we do have?
Cook: From my
perspective, I think there is an issue having to do with
immunological/connective tissue and that seems to be focusing on
systemic scleroderma. That’s one of the reasons we moved ahead the
University of Michigan study under David Schottenfeld
to really address that issue.
The difficulty in these issues
is that the concerns and/or allegations can come fairly rapidly, but
the research can take three to five years. I think there is an
anticipation gap between what the public expects—they almost expect
push-button epidemiology—and what the reality of the discipline is,
the data collection, all the logistical problems, the analyses,
development of the protocol, etc. So, I’m not sure I view it as a
weakness in this sense, but rather what is the next level of
investigation that needs to be done, and that’s the scleroderma
case-control study.
Epi Monitor:
How long has this suspicion been around?
Cook: I don’t
really view it as Shazam! We now have a suspicion. What you’re talking
about is you get a case report of a particular type of disease. Is
that first case report the initiation of the suspicion? Probably not.
And then you start looking at a pattern of case reports, or somebody
does, and this whole issue, if you will, of passive post-marketing
surveillance, and the tide sort of rises. And I think in this
particular issue, it was exacerbated by some of the publicity about
some of the process, and so I think a lot of people’s attitude, even
about the scleroderma is that— “gee, there’s not a lot of evidence for
it,” —but if it’s anything, that’s probably the one that should be
investigated.
Epi Monitor:
Based on some kind of theoretical considerations more than what’s been
reported in the case reports?
Cook: No, based
more on the fact that if you look at the case reports, that’s where
the case reports seem to be clustering. But even there you’re talking
about maybe a half a dozen to a dozen case reports in the literature
having to do with scleroderma. Now, I would pose the question back to
you: In say a million women, would a dozen case reports of any
particular type of outcome be suspicious? I think what you have to do
is you have to start looking at that total picture.
Epi monitor:
Well, this is one of the big issues that has been part of this
controversy all along. It seems like we don’t have a clear definition
for what is a trigger. And the company, it appears, has not felt that
the threshold or the trigger had been reached for investigating some
of these allegations, or case reports. When the publicity began about
the breast implants, it made it seem like the trigger or the threshold
had been reached a long time ago, and that the company was lax in not
addressing some of these conditions sooner. And exactly where the
trigger is, is ultimately a matter of judgement because it is not
clearly defined. So I was just trying to get a sense about how
long-standing the suspicion about scleroderma has been around, not
necessarily the date of the first case report, but how long has there
been an expectation that this should be investigated?
Cook: Aside
from what I’ve already said, I’m not sure how to answer that. We
certainly have been looking at the issue of protocols. The company put
out an RFP about two years ago, and the studies were initiated some
time in 1991. So I think if you go back in the literature you can look
at some of this having surfaced years ago perhaps in Japan, but when
you start looking at that you find that— “jeez, this wasn’t even
silicone, it was injections of paraffin” —or it was injections of
silicone that were purposely mixed with something else to get the
capsule and so what we’re viewing now as a complication was, in fact,
viewed in years past as a laudable event, because it was part of the
process of the use of the silicone. So public expectations have
changed over time, and I think, quite frankly, that’s driven part of
this too.
Epi Monitor: In
your opinion, from the company’s point of view, have all serious,
suspected consequences been investigated in a timely fashion?
Cook: I think
you’re putting some qualifiers in there, from the point of view of
“all” and “serious” and “timely.” I see us moving forward and we have
a research agenda in place. In one of your previous issues,
Mary Ann Woodbury laid out some of the things with the NYU
study, and with the University of Michigan study—we’re very
aggressively now looking at a variety of databases to see whether or
not there are some secondary data analyses that can be brought to bear
to address this issue. So in the sense of could it have gone faster? I
suppose so. Is it unreasonable? My estimation having been here this
period of time is probably not. The timing is not unreasonable.
Epi Monitor:
Were there ever any epidemiological studies that the company
sponsored, either cohort or case control studies, to look at some of
these safety issues?
LeVier:
Certainly the cancer issue, we are a sponsor of the Deapen-Brody work.
We have not co-sponsored epidemiologic studies of rheumatic disease,
until the one we now have going for about 10 months for all the
reasons that Ralph just pointed out.
Epi Monitor: So
the major, if not the only, epidemiologic study has been this one by
Brody that you referred to for cancer.
Cook: I don’t
mean to be nit-picking on all of this, but what constitutes an
epidemiological study? If what you’re talking about is clinical
investigations, the company has been involved in a number of clinical
investigations over a number of years.
Epi Monitor: I
would define it pretty narrowly to mean...
Cook: In a more
purist sense from the point of view of cohort, case-control, or ones
that address statistical power—that type of thing?
Epi Monitor:
Yes. That’s what I mean. The only one like that is the Brody one,
right.
LeVier: Dow
Corning also encouraged participation, financially only, in the
Calgary study by Dr. Birdsel, which is also a cancer study. [to be
published]
Epi Monitor: If
you’ve identified the questions around scleroderma as the most
important unanswered questions, and the University of Michigan study
is designed to address that, are there others? If so, can you say
where they are, or what type of studies they are?
Cook: One of
the other things that’s happening with the NYU study is that we will
also be looking at a variety of other outcomes besides cancer.
Obviously the NCI is doing some work also. They’re going to be looking
at a cohort of about 12,000, so all of those are also going to bear on
this whole issue.
Epi Monitor:
Just by way of summary...the key epidemiologic studies of the major
unanswered questions involve Michigan, NYU and the NCI study?
Cook: We’re
working with another group up in Cambridge, Abt Associates—what we’re
calling the complications study. Now, I would anticipate that there
are a variety of other groups that are also going to be looking at
this, like NCI, the Canadian government, maybe other groups...I know
that some of the people up at Mayo have certainly surfaced on this
issue, and whether they intend to do something further, I don’t know.
Epi Monitor:
What about the other two manufacturers. Are they involved, do you
know?
Cook: Yes. They
are co-sponsors on some of the work that we are doing. We also are
seeking opportunities to identify databases whereby we might be doing
some secondary data analysis. This interview is in a sense an REP,
because if some of the readers are particularly interested or have
some suggestions we’d be very happy to hear from them.
Epi Monitor:
Well, we can make a point of that. Let’s be clear then. What is it
that you’d like to bring to people’s attention? That you’re looking
for databases that people know of that might be suitable for secondary
analyses for either immune system or cancer-type outcomes?
Cook: Immune
system or cancer-type outcomes that might bear on the issue of
silicone.
LeVier: Before
we leave this, let me add that while all this work at the clinical
level is going on, we also have studies underway and we’ll do
additional studies at the laboratory-level on both the cancer and
immune issues to test hypotheses. To test for the apparent
plausibility of various mechanisms that have been proposed. That work
will be going on for some years to come.
Epi Monitor: To
some extent, the level of activity you describe could be viewed as
rather high for a company that has withdrawn from the market. I know
the company has said that it would continue to investigate this, so I
would like you to just take a minute to describe how you see the
future, how long you see the company in this, how much money and staff
are really going to be devoted to this, and for how long...Just so
readers can get an idea of what role the company will be playing even
after it has withdrawn this product.
Cook: To answer
your questions in turn, long, lots and lots...
Epi Monitor:
Long time, lots and lots of money?
Cook: Long
time, lots and lots of money and lots and lots of personnel time.
Epi Monitor:
When you said “lots and lots of money” were you talking about possibly
more than the $10 million the company has set aside?
LeVier: I think
the position is that we’ve set aside $10 million, and if we need more
than that, it will be made available.
Cook: That $10
million is $10 million for research. I think it is probably a very
conservative estimate of what the company has committed to spend as
far as expanding the scientific database in this whole process.
Epi Monitor: Do
you see yourself using some of that $10 million to start up other
studies in the future, similar say to Michigan or WU, or do you see it
more perhaps to expand those studies?
Cook: Let me
put it this way. This morning, Bob, Myron and I sat down and we
started going through 87 proposals that we currently have. And we’re
anticipating that we will be receiving more. If we’re not going to
consider additional research, we would not be going through those
proposals.
Epi Monitor: Is
that in response to a specific RFP or because of publicity? Are these
epidemiologic studies or what?
Cook: No,
they’re not all epidemiologic studies. They cover the gamut. We’re
trying to go through there and see what are the questions that we view
as important, what are the questions that others are viewing as
important, and we’re not in this alone. As you probably know, the
Public Health Service under Dr. Mason has convened a breast implant
task force to look at the research needs.
Epi Monitor: I
wasn’t aware of that. That’s interesting. Who’s chairman of that?
Cook: There are
actually two co-chairs: Dr. Adamson, from the NCI and Dr. Henney from
the FDA.
Epi Monitor:
Have they gotten off the ground yet?
Cook: Oh, yes,
they’ve had a series of meetings.
LeVier: We are
also receiving proposals directly that are unsolicited.
Cook: Yes, I
just got a telephone call today from somebody on the west coast.
Epi Monitor:
Are you encouraging that?
Cook:
Personally, I would like to encourage it—but with some trepidation.
But I think if people have good ideas, we certainly would like to hear
from them. We are actively soliciting the opportunity to identify
databases that we might use for secondary data analysis. Our
orientation there is to see whether or not we can interest the primary
investigator into moving this type of analysis high on their agenda.
Or, if not, whether they would be willing to make the database
available to some other party. The idea would be to try to promote a
marriage between the primary investigator and the person doing the
analysis, perhaps to the extent of funding some of those analyses, or
whether some of these databases might be made available to us, and we
could do the analyses in-house. So we’re looking at a variety of
different options. We’re open to suggestions.
Epi Monitor:
About the registry—there’s been a lot of talk about that in the media,
and I’d just like to clarify what is going to happen. How is that
expected to work?
Cook: My sense
is that you’re probably going to see sometime in the future at least
two types of registries. One is going to be a retrospective registry.
The other one is going to be a series of prospective registries. The
prospective registries obviously are going to be associated with
continued implanting of these devices and therefore they would be
largely driven by the two companies that are currently still in the
business, Mentor and McGhan. The retrospective registry—some of those
discussions are really focusing back on what are the ultimate
objectives for this type of registry because I think everybody
realizes that we had better be very clear on our objective going into
both the retrospective and the prospective registry.
Epi Monitor: Do
you expect that there will be RFPs for those registries, or how will
that work? Is this something epidemiologists might anticipate bidding
on in the future or how do you see that playing out?
Cook: I can’t
speak for Mentor and McGhan, I would have to punt back to them.
Epi Monitor:
What about your retrospective registries? Would that be something you
might contract with a group to do?
Cook: I think
that’s in the process of discussion right now. Certainly the idea of
perhaps using a contract group has been discussed, there’s a lot of
advantages to it.
Epi Monitor:
Ralph, can you comment on how long you expect to be involved with
these activities at Dow Corning? Has that been fixed in time? I think
some of the readers who know you might be curious to know how long you
might be expected to be involved with this work.
Cook: Well, I
am a full-time Dow Corning employee. I anticipate this is my full-time
job for the foreseeable future. I hope sometime in the not too distant
future to retire, my hair is greying fast. Some of that has to do with
age, some of that has to do with issues, but I would anticipate that
I’m going to be involved in Dow Corning both from the point of view of
this issue, and quite frankly, I’m in the process now of figuring out
ways that we’re going to be implementing a comprehensive occupational
epidemiology program within the company to augment some of the things
that have already been done in the past by Mary Ann Woodbury and some
of the other people that have worked here. So, I’m going to be
involved in a variety of different issues.
Epi Monitor:
From the point of view of the scientists or the epidemiologists that
have been at Dow Corning and have gone through this episode—I’d like
to hear what you would candidly offer as lessons learned. What
comments would you care to make to other epidemiologists or scientists
who are now working for other companies and who will be in the news in
six months or 12 months from now? Would anyone like to take a crack at
that?
LeVier: I’ll
try to say something about it. Some of the lessons are almost obvious
and they’re very simple but they’re worth repeating. One of the things
that I think has been hard for us to learn has been to speak plain
English on every occasion—that we have to make sure that surgeons,
other physicians, consumers are communicated to by us in simple, plain
English. I think we’ve been, as so many scientists will be, a little
bit obtuse from time to time. Secondly, I think that a scientist, like
myself, can look at issues that arise and say comfortably to himself,
“Oh, that’s not biologically plausible, so I’m not going to think
about it.” I have found for myself that’s a mistake. You have to take
all these issues that arise seriously in the beginning and not
conclude so quickly that just because it’s not biologically plausible
that you don’t have to worry about it. You do have to worry about it.
So, that’s a big lesson. And thirdly, I suppose is to put our own
materials in context at all points in time with all the materials that
are out there. Not to study just our own. Because one of the peculiar
things that happens here is we’ve got a huge amount of data on
silicone. There’s a lot less on other materials and that provides a
certain opportunity for questioning and having issues arise with this
material that I think are undoubtedly relevant to all materials. Maybe
I’ll stop there, but as a scientist, those are some of the issues.
Cook: There’s a
couple that come to my mind. One is the techniques in post-marketing
surveillance have to be looked at and perhaps the whole science of
post-marketing surveillance is overdue for further development. That’s
one area. I think the other issue that I see, and that we’ve talked
about in the past, is the importance of industrial scientists
publishing their work. Because I think there is an important check and
balance that’s involved in that whole process. You know, obviously
we’re getting very aggressive at this stage at doing a lot of work and
putting a lot of work out into the literature hopefully as fast as we
can. So I think that’s another point that I think epidemiologists and
industrial epidemiologists have to think about.
Epi Monitor: So
you say perhaps the company in the past has done work that was not in
the literature, that could have been, or should have been?
Cook: Well, I
mean we have 10,000 studies, as Bob said. And we have considerably
less than 10,000 publications. And I think that one of the problems
that we’re dealing with in this particular issue is a lot of vague
allegations and concerns. When our scientists look at the body of
evidence that’s available, in totality, it doesn’t seem to support
that, and yet I’m sympathetic perhaps to people on the outside who
don't have access to that same body of evidence because it’s not
readily available in the peer reviewed literature. In fact, even the
300+ studies that are in the PMAA, for example, I would suspect many
people would not have ready access to that. So there’s an issue of
access there that I think we need to take a longer, harder look at.
Epi Monitor:
I’d like to use a quote to introduce the next question. It is from
Noel Rose from Johns Hopkins who said “I just don’t have a good feel
for why we are left 20 years on, still saying we are sorry, we wish
these things would have been looked at 20 years ago.” I think it’s an
interesting question that a lot of us have who read about this. How is
it that we came to be in this situation now?
LeVier: Keep in
mind that more studies have been done on silicone than any other
synthetic material ever to my knowledge, and by the very fact of doing
that gives the opportunity to raise questions that wouldn’t even exist
in anyone’s mind for the other materials that have not been looked at.
That’s an important point. The second point is that for a number of
societal and regulatory reasons, regulatory expectations change at a
very rapid rate. We fully expect to honor that, conform to that, with
our present and future products in every way. But I think it’s a
little bit ludicrous to point at us or at any other company as somehow
being at fault for a regulatory environment that didn’t even exist;
it’s all really quite new in many ways.
Epi Monitor:
You’re raising the issue that the regulatory environment changes and
sometimes at a very rapid rate, and so...
LeVier: Now I
am not trying to give the FDA itself a really bad time. Consider that
the FDA is under extreme pressures to deal with all manner of claims
and charges in the evolving societal expectations, I think they’re
doing the very best they can to deal with this. But the public debate
has put most of the weight for dealing with the change on us. And I
don’t think that’s right or wrong, it just doesn’t answer it. I think
there are other players here, such as the agency.
Cook: In my
mind, what you’re doing is getting some really rapid shifts in
societal expectations. I think that we are doing our best to adapt to
those, to anticipate those, to put into play processes and programs
that will adequately address those, but the questions can come faster
than the answers just because of the nature of the process.
Epi Monitor:
One explanation given for this situation is that no clear standard had
to be met. This was best expressed to me in a quote from Alan
Magazine, and he put it this way: “It is as if they said they
will penalize you if you don’t obey the speed limit, but then they
don’t tell you what the speed limit is.” So, there was no clear
standard that had to be met. Do you agree or disagree?
LeVier: I’ll
agree with that because the FDA had no power to regulate devices
before 1976, and reacted as quickly as they could. They virtually
didn’t have regulations until 1978. So there was a very long period of
time when certainly reasonable people could disagree about what
standards ought to be met.
Epi Monitor:
I’m not sure I get your answer. In other words, if there were
regulations by 1978, then isn’t that saying that there was a standard
as of ’78?
LeVier: There
was an evolving standard which was quite rudimentary at the time and
we and other companies conformed to those standards and they’ve
evolved since then. As I said earlier, they’re changing at an
incredible rate. Remember this product was first sold in 1963 or 64,
and there simply were no regulations at that time.
Epi Monitor: So
the standard that you’re trying to conform to now has been the
standard since when?
LeVier: I’m
hesitating on that because, as the agency deals with this very
difficult situation, where there are political pressures and societal
pressures and so on, the apparent regulatory requirement is changing
literally by the month.
Cook: For
example, it’s unclear to us as to whether or not a retrospective
registry is in fact mandated by regulation. But nonetheless, we’re
spending a fair amount of time on trying to figure out how we would go
about implementing a retrospective registry, what the objectives are,
how the logistics would work, etc, and yet maybe a year, two years,
five years down the line, retrospective registries may be required by
regulations. Now, what’s the starting point on that one?
LeVier: In
addition, I’ve just been reminded that the 515 (b) (a regulation for
the device industry) which defined the requirements for breast
implants appeared in final form in April 1991.
Epi Monitor:
The second explanation I’ve read about, which is what I think we’ve
been saying is: there has been a clear standard, but this standard was
changed and made more rigorous recently. I suppose that’s what you’ve
been saying, it’s been evolving and being made more rigorous.
LeVier: Well, I
think we would agree with that, although I would offer a caution. I
wouldn’t want you to think that we think there is some sort of
capriciousness or unilateral behavior on the part of the agency. They
are faced with a Herculean task.
Epi Monitor:
The third explanation I have is also related to this: There has been a
clear standard, but no clear timetable by which the standard had to be
met. I guess you would disagree with that because you would say that a
timetable is not so much the issue, it’s more the issue of an unclear
standard, or a changing standard.
LeVier: Yes,
I’d agree with the timing issue, but I think it’s really a little
subpart of the previous item that you cited.
Epi Monitor:
The fourth point that was brought up was: additional studies were
considered by the company as being too expensive, therefore you didn’t
do them for that reason.
LeVier: Well, I
don’t know what those studies are. Obviously when you’re in business,
cost and expenses are a practical issue. I’m not aware of studies that
we’re not doing because of reasons of cost.
Cook: Let me
respond to that a little differently. Here we are sitting, for example
today, with 87 proposals. Now, in one sense some people would not
understand why we would not rush to fund all 87 of those. And others
would fully understand why we might winnow through those and decide on
one, two, five, half a dozen. Now is that an issue of cost, or is
there some other dynamic that’s going on? The discussion having to do
with some of the studies that we are currently funding certainly took
place during a period of time before we funded them but we are funding
them, and we are moving ahead with them.
Epi Monitor:
The other explanation is that there was concern that new studies would
more likely discover new hazards rather than prove that the implants
were safe, and the company did not want to hear bad news about
implants.
Cook: I’m not
sure how we would comment on that over and above saying obviously we
are very aggressively looking at a variety of studies at the present
time.
Epi Monitor:
Here is a comment made by someone in the newspaper: “Sometimes you can
have a mind set that a drug will be very commercially important”—I
guess you could substitute implant here—“you don’t want to hear bad
news about it, you don’t really develop or acknowledge some problems.”
Do you think any of that was going on in the company?
LeVier: I would
suppose there are a couple of answers. One is the record of studies
we’ve done that indicates that we certainly try to pay attention and
do a lot of work. It’s also true in human nature that it’s difficult
to maintain vigilance. I suppose that’s true of everyone. But our
primary assertion is, we have conducted more studies on silicone than
anyone I think has ever conducted on any implantable material. Could
we have done a better job? I suppose in some way the answer to that is
always yes, but I think we’ve done fairly well.
Epi Monitor:
The other comment I’ve read had to do with the problems that called
for additional study. They were not judged common or frequent enough
to warrant full-scale investigation. We talked about that in the past,
this whole issue of threshold, but this suggests that the problems
that called for additional study were just not considered to be common
or frequent enough. Was that operating at all?
Cook: You mean
is judgement operating at all? Well, the answer would be yes.
Judgement is operating at multiple different levels. I would
anticipate that there’s probably a spectrum of scientists out there
that are looking at this whole issue and saying, if you will, that
this is being driven by less than four dozen case reports, and what a
waste of resources. We could be spending all of this money on
investigations of AIDS. And there’s probably others that are saying in
those four dozen case reports, there were two cases of X disease;
therefore, you should mount a full study of X disease. So you’re
dealing with that spectrum. It seems as though people are expecting a
black and white answer to what, in the statistical sense, is a
continuous variable.
Epi Monitor:
That gets back to the point we were talking about earlier, that what
exactly constitutes a trigger is not black and white, it’s a matter of
judgement. Another explanation for the current situation is that there
were large amounts of women who were very satisfied with the implants;
therefore, it was unlikely that such an acceptable product could have
any serious problems associated with it. I wondered to what extent
that might have held sway in the minds of some of the people in the
company?
LeVier: Well, I
think I can only speak for the scientific community here, but typical
scientists are not overly impressed with a bunch of people that are
happy, and are telling you that there aren’t potentially any
difficulties. I think there always could be. That’s why we’ve
continued to do research. People finding that as the explanation is
really quite inappropriate and inaccurate.
Epi Monitor:
How about the notion that the company was aware of safety problems,
but was seeking to hide information, not collect more? I think you've
sort of alluded to that already. Do you want to comment any more?
LeVier: Only to
say that I disagree. Absolutely. As I’ve said publicly before. I think
there’s no basis for that comment.
Epi Monitor:
From talking with you, my sense is that we’re in the situation that
we’re in because it’s been an evolving process. Over time our own
expectations have changed. The expectations that we’re saying that
we’re failing to meet today, it’s not that they’ve been there for 30
years as long as the product has been with us. But they have been more
recent; therefore, the reason that we’ve failed to meet all of our
expectations is that those expectations have not been constant.
LeVier: I think
that applies to the entire spectrum of the device industry, not just
silicones. It’s the fundamental issue that applies to the entire
industry.
Cook: I don’t
think it’s confined just to the device industry. I think we’re seeing
that happening on a whole variety of things. I think you’re seeing it
happen in clinical medicine, for example. People’s expectations about
what to expect out of a visit to their doctor is driving a lot of the
issue on health care costs. There are all sorts of societal dynamics
that are coming to play. We happen to be involved in one part of it,
but it’s certainly not exclusively ours, or exclusively the device
industry’s, or even exclusively medicine’s.
LeVier: I would
surely agree with Ralph. It applies to the environment, food, our
expectations have experienced a fundamental societal shift.
Epi Monitor:
That’s interesting in regards to lessons learned. Dr. LeVier was
saying “speak plain English”, “Take all issues that arise seriously.”
Then the one about putting materials in context with others, but I
think we ought to add in there, something about staying in touch with
evolving social expectations.
Cook: I think
that’s valid.
Epi Monitor:
When one reads about this breast implant controversy, there is this
clear feeling of outrage that people experience. This, in fact, is not
because people have changed their minds about what they want, but that
they’ve known all along what they want and it has not been complied
with. If that’s true, there really is quite a diametrically opposed
view of the situation on the part of the people reading about it and
on the part of the people in the company that are in the middle of it.
Cook: I would
challenge that. As an epidemiologist you know that if you can define
your terms and really get the specifics, then you can really start
addressing it. I would say that there is a sense of outrage, there is
a sense that the expectations were not addressed, but you could
challenge people as to what they’re expectations were on product X for
the following year. I would argue that many of the expectations
articulated by people would be fairly vague. I would also suggest that
their expectations, if you were able to do this in some kind of
longitudinal frame, would probably change over time depending on the
context of some of the changes that were going on in society. So I
would agree with you that there is outrage, but I would disagree
having to do with the specificity of the expectations because I view
that as being in flux in our whole society.
Epi Monitor:
That’s interesting because then what you’re suggesting is that people
are outraged for nonspecific reasons, yet they express their outrage
in specific terms.
Published May 1992
Postscript 2000
These past eight years
of dealing with the silicone breast implant controversy, initially as
an epidemiologist employed by the Dow Corning Corporation (a former
manufacturer of the medical devices) and more recently as a part-time
consultant to the company, have been both fascinating and frustrating.
The issue is complex and space is limited, so my update is brief.
The registry mentioned
in the initial interview never was implemented. Registries can serve
many different objectives, but no single registry can meet all of
them. It became obvious that the different objectives of the disparate
interest groups could best be served by other mechanisms. In
retrospect, they were.
In early 1992, the
federal government set up an Interagency Regulatory Liaison Group to
identify the major scientific questions that needed to be answered
vis-á-vis silicone breast implants. That group held a series of
technical meetings and developed a final report. To the best of my
knowledge, it was never made public.
Even in the absence of
any centralized direction and with limited federal grant support,
research exploded. Based upon the relatively large amount of
information that is currently available, a number of prestigious
review bodies have concluded that the evidence does not support a
cause and effect relationship between breast implants and any systemic
disease--neither cancer, any of the classic connective tissue
diseases, nor one or more novel atypical conditions. Ironically, the
most provocative hypothesis that has evolved out of this research is
that silicone breast implants may be protective against breast cancer,
both initial onset and recurrence. The mechanism is unknown.
Research continues on
the local complications, in particular, capsular contracture (the
sometimes painful hardening of the tissue capsule that naturally forms
around every foreign body) and implant rupture. Implementation of
rigorous pre-, intra- and post-surgical protocols have reportedly
reduced the frequency of contracture ten-fold, down to about 2%. On
the other hand, investigations of rupture have been complicated by the
phenomenon of “silent rupture”--implant disruptions that are difficult
or impossible to detect since they neither compromise the cosmetic
effect nor correlate with any obvious signs or symptoms. Non-invasive
detection techniques are still being developed. The clinical approach
to implant rupture appears to be evolving from one of routine
explantation to watchful waiting.
In spite of the
scientific results, the large number of lawsuits forced Dow Corning
into bankruptcy and the other major manufacturers (Baxter,
Bristol-Myers Squibb and 3M) into a multi-billion dollar settlement.
Dow Corning is currently awaiting court approval of a plan of
reorganization which it developed in conjunction with the plaintiff
attorneys. Among the many groups who were given the opportunity to
vote on this plan, approximately 95% of the women with implants who
voted, accepted it. The linch-pin of this plan is another
multi-billion dollar settlement, paradoxically with the largest
payments slated to go to women with certain systemic diseases and
atypical conditions. However, in the end, those in the legal system
will be the major beneficiaries of the silicone breast implant
controversy. Some of the plaintiff attorneys likely will pocket tens
of millions of dollars in contingency fees, orders of magnitude more
than most of their clients.
Ralph R. Cook,
MD
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