TESTIMONY OF ROBERT CARROLL, MD, TO THE FOOD & DRUG
ADMINISTRATION REGARDING THE FDA PROPOSAL ON MAKING EMERGENCY CONTRACEPTION
AVAILABLE OVER THE COUNTER December 16, 2003
Re: Docket No 2001P-0075
(concerning a proposal to "Switch Status of Emergency Contraceptive
From RX to OTC")
My name is Robert Carroll. I am a retired physician in Pittsburgh. I am
here as an individual, not representing any group or organization, and
I have no financial interest whatever.
My interest is the question of permitting over-the-counter sales of the
morning after pill stems from my concern regarding the epidemic of sexually
transmitted disease, especially among young people. I practiced medicine
as a general internist from 1949 until 1995. The increase in STD's in the
last several years of my practice was startling and disturbing. For the
past eight years I have been presenting elective classes to students at
our local senior high school on STD's
As is well known, our society has undergone a sexual revolution in the
past 30 or 40 years. Our young people have been encouraged to engage in
sexual activity, with the understanding that it was safe and socially acceptable
as long as contraception was used.
They were not, and are not now, being adequately informed of the significant
danger of acquiring STD's, with or without the use of contraceptives.
Let me briefly note the extent of the STD problem. The following statistics
apply only to the United States.
About 3 million new cases of Chlamydia infection occur annually- about
half of these in teen agers. Most cases are asymptomatic. Untreated, 40%
will acquire pelvic inflammatory disease. Of these, 20% become infertile,
18% have chronic pain, and 9% develop life-threatening conditions..
Gonorrhea, with similar effects, occurs in 650,000 reported cases, mostly
teens. The true number is probably twice that.
More than 50 million Americans test positive for Herpes Simplex infection.
Medication can help, but herpes is forever.
An estimated 5 million new cases of Trichomoniasis occur each year. It
may be one of the most important co-factors in the spread of HIV infection.
It may also cause premature rupture of membranes and premature birth in
pregnant women.
Hepatitis B and hepatitis C are also transmitted sexually and cause great
morbidity and mortality.
Five and a half million new cases of Human Papilloma Virus occur annually.
It is the cause of virtually all cases of cervical cancer, which claims
about 5000 lives a year.
All told, over 15 million new STD infections occur annually in this country
Not all the statistics are bad. As the message of the STD epidemic outlined
here has been delivered, there has been a measurable and consistent increase
in sexual abstinence among teenagers. This trend is accompanied by a progressive
decrease in the number of pregnancies and abortions.
It is self-evident that over-the-counter availability of the morning after
pill will increase sexual promiscuity and its attendant physical and psychological
damage.
If our young people are free to stop in at a store and purchase a potent
drug, with no medical supervision, no parental knowledge, without even
a conversation with a school nurse or a "womens' health" advisor,
the results may well be catastrophic.
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