Managing the risks of medical technology: Do hazard surveillance systems provide an early warning of medical device problems?

The Food and Drug Administration (FDA) is responsible for risk assessment and risk management in the post-market surveillance of the U.S. medical device industry. One of the FDA regulatory mechanisms, the Medical Device Reporting System (MDR) is an adverse event reporting system intended to provide the FDA with advance warning of device problems. It includes voluntary reporting for individuals, and mandatory reporting for device manufacturers. ^ In a study of alleged breast implant safety problems, this research examines the organizational processes by which the FDA gathers data on adverse events and uses adverse event reporting systems to assess and manage risk. The research reviews the literature on problem recognition, risk perception, and organizational learning to understand the influence highly publicized events may have on adverse event reporting. Understanding the influence of an environmental factor, such as publicity, on adverse event reporting can provide insight into the question of whether the FDA's adverse event reporting system operates as an early warning system for medical device problems. ^ The research focuses on two main questions. The first question addresses the relationship between publicity and the voluntary and mandatory reporting of adverse events. The second question examines whether government agencies make use of these adverse event reports. ^ Using quantitative and qualitative methods, a longitudinal study was conducted of the number and content of adverse event reports regarding breast implants filed with the FDA's medical device reporting system during 1985–1991. To assess variation in publicity over time, the print media were analyzed to identify articles related to breast implant failures. ^ The exploratory findings suggest that an increase in media activity is related to an increase in voluntary reporting, especially following periods of intense media coverage of the FDA. However, a similar relationship was not found between media activity and manufacturers' mandatory adverse event reporting. A review of government committee and agency reports on the FDA published during 1976–1996 produced little evidence to suggest that publicity or MDR information contributed to problem recognition, agenda setting, or the formulation of policy recommendations. ^ The research findings suggest that the reporting of breast implant problems to FDA may reflect the perceptions and concerns of the reporting groups, a barometer of the volume and content of media attention. ^

Use of short term test systems for the prediction of the hazard represented by potential chemical carcinogens

It has been hypothesized that results from the short term bioassays will ultimately provide information that will be useful for human health hazard assessment. Although toxicologic test systems have become increasingly refined, to date, no investigator has been able to provide qualitative or quantitative methods which would support the use of short term tests in this capacity.^ Historically, the validity of the short term tests have been assessed using the framework of the epidemiologic/medical screens. In this context, the results of the carcinogen (long term) bioassay is generally used as the standard. However, this approach is widely recognized as being biased and, because it employs qualitative data, cannot be used in the setting of priorities. In contrast, the goal of this research was to address the problem of evaluating the utility of the short term tests for hazard assessment using an alternative method of investigation.^ Chemical carcinogens were selected from the list of carcinogens published by the International Agency for Research on Carcinogens (IARC). Tumorigenicity and mutagenicity data on fifty-two chemicals were obtained from the Registry of Toxic Effects of Chemical Substances (RTECS) and were analyzed using a relative potency approach. The relative potency framework allows for the standardization of data "relative" to a reference compound. To avoid any bias associated with the choice of the reference compound, fourteen different compounds were used.^ The data were evaluated in a format which allowed for a comparison of the ranking of the mutagenic relative potencies of the compounds (as estimated using short term data) vs. the ranking of the tumorigenic relative potencies (as estimated from the chronic bioassays). The results were statistically significant (p $<$.05) for data standardized to thirteen of the fourteen reference compounds. Although this was a preliminary investigation, it offers evidence that the short term test systems may be of utility in ranking the hazards represented by chemicals which may be human carcinogens. ^

Effects of informative censoring on the hazard function: Application to the proportional hazards regression model

The standard analyses of survival data involve the assumption that survival and censoring are independent. When censoring and survival are related, the phenomenon is known as informative censoring. This paper examines the effects of an informative censoring assumption on the hazard function and the estimated hazard ratio provided by the Cox model.^ The limiting factor in all analyses of informative censoring is the problem of non-identifiability. Non-identifiability implies that it is impossible to distinguish a situation in which censoring and death are independent from one in which there is dependence. However, it is possible that informative censoring occurs. Examination of the literature indicates how others have approached the problem and covers the relevant theoretical background.^ Three models are examined in detail. The first model uses conditionally independent marginal hazards to obtain the unconditional survival function and hazards. The second model is based on the Gumbel Type A method for combining independent marginal distributions into bivariate distributions using a dependency parameter. Finally, a formulation based on a compartmental model is presented and its results described. For the latter two approaches, the resulting hazard is used in the Cox model in a simulation study.^ The unconditional survival distribution formed from the first model involves dependency, but the crude hazard resulting from this unconditional distribution is identical to the marginal hazard, and inferences based on the hazard are valid. The hazard ratios formed from two distributions following the Gumbel Type A model are biased by a factor dependent on the amount of censoring in the two populations and the strength of the dependency of death and censoring in the two populations. The Cox model estimates this biased hazard ratio. In general, the hazard resulting from the compartmental model is not constant, even if the individual marginal hazards are constant, unless censoring is non-informative. The hazard ratio tends to a specific limit.^ Methods of evaluating situations in which informative censoring is present are described, and the relative utility of the three models examined is discussed. ^