Topical Corticosteroids: Regulatory Aspects




© Springer Nature Singapore Pte Ltd. 2018
Koushik Lahiri (ed.)A Treatise on Topical Corticosteroids in Dermatologyhttps://doi.org/10.1007/978-981-10-4609-4_31


31. Topical Corticosteroids: Regulatory Aspects



Rajetha Damisetty  and Shyamanta Barua 


(1)
Oliva Chain of Skin and Hair Clinics, Hyderabad, India

(2)
Department of Dermatology, Assam Medical College and Hospital, Dibrugarh, Assam, India

 



 

Rajetha DamisettyConsultant Dermatologist and Additional Medical Director (Corresponding author)



 

Shyamanta BaruaAssistant Professor



Abstract

Topical steroids are the keystones of dermatologic therapy. When used rationally, for the right indications, they are extremely effective and cause minimal effects. Sadly, their (mis)use is often fraught with adverse effects. Their potential for causing addiction has led to enormous psycho-socio-economic burden, in addition to long term and, at times, permanent disfiguring physical sequelae. Rampant abuse of irrational combinations of topical steroid-antifungal, with or without antibiotics, has led to the epidemic of recalcitrant steroid modified dermatophytosis in India. Regulatory aspects related to permissions to sell irrational steroid containing topical fixed drug combinations, drug dispensing without valid prescriptions, lack of control over who can prescribe steroid preparations and advertisements to lay public promoting steroid-hydroquinone-tretinoin creams as fairness creams have led to the menace of topical steroid abuse. If these flaws in the system are not corrected on a war-footing, the nightmare would worsen rapidly.


Keywords
Topical steroidsRational usage“Prescription drugs”Fixed drug combinationsDrug control authorities



Learning Points




  1. 1.


    Topical steroids are safe when used rationally, by physicians who possess understanding of skin, steroid potency, and patients’ psyche.

     

  2. 2.


    They are frequently used without appropriate prescriptions, as fairness or acne creams or relief of itching secondary to varied etiologies; they cause numerous short- and long-term adverse events and, at times, addiction.

     

  3. 3.


    Easy availability of irrational topical steroid containing FDCs has led to their rampant abuse in dermatophytosis in India.

     

  4. 4.


    Control of new drug licenses, ban of irrational topical steroid containing FDCs and strict implementation of drug dispensing rules ensuring that dispensing against valid prescriptions are the need of the day.

     


31.1 The Dark Side of Topical Steroids


Sulzberger and Witten in 1952 introduced compound F (hydrocortisone), the first topical steroid to the world of dermatology [1]. Hydrocortisone and later, its most more potent analogues seemed like the holy grail of dermatology, a means to quell inflammation of the integument [2]. A decade passed before the adverse events first report of adverse events surfaced [3]. Another decade passed before addiction to topical steroids was reported in 1973 [4]. Kligman and Frosch [5] coined the term “steroid addiction” and gave a poignant description of the physical, psychological and social trauma that patients “hooked” to topical steroids go through.

A spate of articles on misuse and addiction continued to pour in over the next four decades [616]. The unabated accumulation of literature on the subject is merely a sign of the growing menace of topical steroid abuse.


31.2 Regulatory Aspects Related to Topical Steroid Abuse


Drug control authorities of a country are responsible for issuing drug licenses for manufacture and sale and approving indications and that can be treated with the drug. They may also decide to cap the price of certain drugs. Laws of the land decide which drugs can be sold over-the-counter, without prescriptions. They also decide which drugs may be advertised to lay people, if at all. The law machinery needs to implement the laws and check how stringently rules are being honored.

In the context of topical steroids, the controversy lies around issuing licenses to irrational fixed drug combinations that contain antibiotics and antifungals, in addition to steroid molecules. Use of mid-potent steroids like mometasone in modified Kligman’s formula is also a case in point.


31.3 Focus on India, the Hotbed of Topical Steroid Abuse


Failure of regulatory authorities in India has no small role to play in the topical steroid menace that the nation is fighting. The major chinks in the armor of relevant law are:


  1. 1.


    Exclusion of all topical steroids from schedule H of drugs and cosmetics act.

     

  2. 2.


    Approval of numerous irrational topical steroid containing FDCs

     

  3. 3.


    Price control on betamethasone

     

  4. 4.


    Lack of will and means to implement laws to regulate sales.

     

Indian Association of Dermatologists, Venereologists and Leprologists (IADVL) has constituted a task force, the IADVL Taskforce Against Topical Steroid Abuse (ITATSA) to fight the growing menace of topical steroid abuse.


31.3.1 The Indian Drug Regulation Scene


An article in Lancet [17] said “To say that India’s drug regulatory authority, the Central Drugs Standard Control Organization (CDSCO)—whose remit includes new drug approval, licensing of manufacturing facilities, and regulation of drug trials—is not fit for the purpose seems a gross understatement. A damning 118-page report from the Indian Parliamentary Standing Committee on Health and Family Welfare documents its successive failings. It describes a vast, geographically disseminated organization that is dangerously understaffed: “nine officers at headquarters deal with 20,000 applications, more than 200 meetings, 700 parliamentary questions, and 150 court cases per year. There is also a dearth of medically qualified staff, poor support infrastructure, a seeming lack of coordination between departments, and a scarcity of decent computer systems.” Medication misuse in India has been termed a public health problem [18].


31.3.2 The Schedule H Tragedy and Legislation to Regulate Marketing and Sales of Topical Steroids


Schedule H is an appendix to the Drugs and Cosmetics Rules, India 1945 [19]. It includes a class of drugs, which cannot be purchased over the counter without the prescription of a qualified doctor. The manufacture and sale of all drugs are covered under the Drugs and Cosmetics Act and Rules. Four steroid molecules have been listed in this schedule, viz. clobetasol propionate, clobetasone 17-butyrate, fluticasone propionate, and mometasone furoate. The former two are available only for topical use on skin while the latter two are available for intranasal use too.

A footnote in the schedule H of the D&C Act stated that “The salts, esters, derivatives and preparations containing the above substances excluding those intended for topical or external use (except ophthalmic and ear/nose preparations containing antibiotics and/or steroids) are also covered by this Schedule” [19]. After incessant lobbying by ITATSA, this is slated to be modified.

Thus, topical steroids were not in the purview of schedule H. This is the root of topical steroid abuse in India. In most countries, no topical steroid may be purchased without a valid prescription. In a few countries, mildest of steroids, 1% hydrocortisone is available over the counter.

After extensive lobbying by IADVL, the drug technical advisory board decided to amend the footnote to include topical steroids on May 13th 2016 [20]. A notification of the same was published in the gazette of government of India on 12th Aug, 2016 [21]. No objections to this amendment were received within the stipulated six weeks apparently. Yet, till May 2017, the final notification regarding implementation is still to be issued.

Even if the amendment is carried out (without further modification), potent steroid molecules like halobetasol and betamethasone dipropionate remain outside the schedule. The Drug Controller General of India took cognizance of this fact and called for reassessment of list of drugs in schedule H; he acknowledged the role of IADVL in initiating this change of attitude [22].

If the government of India intends to safeguard the skin health of its citizens, amendment of schedule H to include all steroid molecules and implementation of this change in letter and spirit has to be initiated. Till then, the strongest of steroid creams can be legally sold to the Indian consumer without prescriptions. Advertisements promoting these potentially dangerous products will continue to lure hapless people into the steroid addiction trap.


31.4 Plethora of Irrational Steroid Containing FDCs in India


Topical steroid-antifungal ± antibacterial combinations account for 43% of all topical steroid preparations sold, contributing to a staggering Rs. 753 crore, out of the total Rs. 1.716 billion of all topical steroid sales [23]. Most of these preparations are irrational and unscientific. Widespread use of topical steroids in conjunction with antifungals has led to the emergence of recalcitrant and atypical fungal infections [24]. The use of these FDCs has become so commonplace that most of the dermatophytosis seen by dermatologists is now steroid modified. As patients feel relief within just a few days of usage of these creams, they stop the topical preparation. Local immune suppression caused by the steroid component of the cream allows spread of the infection. Intermittent exposure to antifungals makes the organism resistant to its action. The medication is restarted when the itching and redness return, usually with a vengeance. Steroid part of the cream provides some symptom relief but the antifungal fails to do any good, resulting in the infection spreading rapidly. This vicious cycle has made treating steroid modified tinea a frustrating and expensive exercise. As it is contagious, family members frequently acquire recalcitrant tinea and end up spending money they can ill-afford to.

Unless urgent action is initiated, irrational topical steroid containing FDCs are all banned and strong legislation implemented to stop the unsupervised sale of steroid creams, this nightmare will turn more sinister. It might be years before the sensitivity of dermatophytes returns to normal even if effective steps are taken.

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Mar 5, 2018 | Posted by in Dermatology | Comments Off on Topical Corticosteroids: Regulatory Aspects

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