April 13, 2005
General and Plastic Surgery Devices Panel
U.S. Food and Drug Administration
5600 Fishers Lane
Rockville MD 20857-0001
Submission of Comments 11-13 April 2005 FDA Hearing on
Silicone Breast Implant Devices
My name is Betsy Mullen. I am the founder, President/CEO of
WIN Against Breast Cancer. I am representing WIN ABC today
and I speak from the perspective of an advocate and breast
cancer survivor who has had a mastectomy, and as a woman who
cares very deeply about the availability of silicone gel
implants and a woman's right to choose.
I am not being reimbursed for
addressing this panel. WIN ABC has received small grants
from Mentor Corporation that total less than $20,000 over
the 11-year period that WIN has existed, that in no way have
influenced my position on this issue. Like many breast
cancer advocates, I became involved in this issue following
my own breast cancer challenges. Diagnosed in 1992, I
underwent a mastectomy with immediate lattisimus dorsi
reconstruction and a saline implant. This was unfortunate
timing—just after the voluntary moratorium—so silicone gel
implants were not very accessible. Last year, I underwent a
revision of that reconstruction and the implant was
exchanged with a tissue expander, which will later be
replaced by a silicone implant to correct the poor aesthetic
results including extreme wrinkling from the saline implant.
WIN ABC and I, personally, have helped scores of breast
cancer patients, hearing many women state that they'd rather
die than lose a breast to cancer. That fear keeps some women
from even getting screened; for others, once diagnosed, it
influences and delays treatment decisions that give them the
best outcomes. When we let women know about their breast
reconstruction options which can include skin sparing
mastectomies, they are often able to reframe their attitudes
and gain the fighting spirit so crucial to cancer
survivorship and quality of life.
Quality of life is important
for all patients -- for all people. No cancer treatment and
no medical device are perfect. Panel members, with all due
respect, I read FDA's memos that were made public prior to
this meeting, and I am very disturbed about FDA's views on
QOL. FDA seems to be questioning the benefits of breast
implants. The benefits are self evident. The adjunct study
was initiated in the interest of public health. Medicare and
insurance pay for implants as a medical need.
Thus there is governmental
recognition of a medical benefit. It is insulting to breast
cancer survivors and other women to question the QOL
benefits -- to question this when we are fighting so hard to
keep access available for ourselves and our constituents.
It is offensive and
disconcerting that FDA would suggest in its panel memo that
some patients focus on appearance, while others are just
relieved at recovering from cancer. If you or a loved one
had testicular cancer and wanted a testicular implant, we
would not judge you as being focused on appearance. If
patients recover from cancer with a sense of wholeness, of
feeling good about their bodies -- is that not meaningful?
Is that not measurable? It is very meaningful to cancer
patients.
Silicone breast implants, for
a large sub-set of patients, are the best option to restore
the natural look and feel of a breast following a
mastectomy. We need to treat the whole person and make sure
that patients’ medical and psychosocial needs are met; that
they are empowered and informed to make treatment decisions
based on good science and evidence-based medicine. We want
to widen the treatment options for patients, not limit them.
We want the public to be well-informed by good science, not
bad hype that makes good headlines.
I can report first-hand that
misinformation often results in creating tragic barriers to
women and men seeking life saving breast cancer screening
and treatment services.
I cannot count the times
women have called our organization following a sound bite on
the news about "the dangers of implants" or that FDA has
"banned implants". Hype destroys hope. Misinformation leads
to disintegration of health.
The recent headlines about
rupture rates in the range of 90% are a case in point.
Statistics such as this taken out of context are
uninformative, misleading, and dangerous. The one 90% number
from FDA’s memo to the panel was an exaggerated number based
upon one particular method of projecting—essentially a
worst-case scenario—and was also skewed because it included
information on one particular type of implant that is not
representative of others. The actual data submitted to FDA
by the companies are more in line with published studies
that estimate rupture rates at 15% at 10 years.
Also in the past week, a few
organizations opposing SBIs continued to spread
misinformation regarding silicone breast implants. Despite
study after study reaffirming that there is no connection
between breast implants and connective tissue disease or
other long-term effects, these groups continue to raise this
issue. These actions are a disservice to breast cancer
patients and survivors and to all women.
Breast implants have been
studied for decades and have been under intense scrutiny for
a large portion of that time. The science is sound and
ongoing. Every day, women seek breast cancer treatment
options that include reconstruction with silicone gel
implants, often their best reconstructive option, an option
that can result in a new lease on life at a time when life
seems so fragile and precarious, a choice that means hope,
healing, and vitality to the all too many patients
confronted with a breast cancer diagnosis.
Providing access only through
clinical trials creates an unnecessary barrier and
additional burden and stress in the lives of already
challenged cancer patients.
It is my hope that your
insight and wisdom will result in preserving the
availability of silicone gel implants and the opportunity
and right of women to make informed treatment decisions
relying on sound science and evidence-based medicine and to
choose whether or not to use them. Women make critical
decisions every day of their lives – for their children,
families, and themselves – please don’t underestimate our
ability to make this decision, to handle this choice.
Thank you.
Last Updated:
04/14/2005
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