About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

1 1 (September 27, 2017)

handle is hein.crs/govcgvt0001 and id is 1 raw text is: 




01;0i E.$~                                  &


                                                                                              September 27, 2017

Naloxone for Opioid Overdose: Regulation and Policy Options


In the United States, the annual number of drug overdose
deaths involving opioids has more than quadrupled since
1999, according to the Centers for Disease Control and
Prevention (CDC). Recent estimates (through the third
quarter of 2016) show that the age-adjusted rate of drug
overdose deaths has continued to rise. Research published
in the American Journal of Preventive Medicine finds that
the proportion of drug overdose deaths involving opioids
has been underestimated (Ruhm 2017). The prescription
drug naloxone is currently the only safe and appropriate
treatment for opioid overdose, according to the Substance
Abuse and Mental Health Services Administration
(SAMHSA) Opioid Overdose Prevention Toolkit.

How Nalon*           WoOrkS
The drugs commonly called opioids-whether prescription
drugs (e.g., oxycodone) or street drugs (e.g., heroin)-are
opioid agonists, meaning they bind to and activate opioid
receptors in the brain. Opioids relieve pain, may induce
euphoria, and have other effects such as depressing both the
central nervous system and the respiratory system. In the
event of an overdose, these latter effects may manifest in a
range of physical problems, including severe drowsiness,
dangerously slow breathing, coma, and even death.

Naloxone is an opioid antagonist, meaning it binds to
opioid receptors but does not activate them. When
administered during an opioid overdose, naloxone
temporarily displaces opioid agonists from the opioid
receptors and blocks additional opioid agonists from
binding to the opioid receptors. By temporarily displacing
and blocking opioid agonists, naloxone temporarily stops
their effects, thus reversing the overdose.

SAMHSA's Opioid Overdose Prevention Toolkit includes
five steps for first responders to take in the event of an
opioid overdose: (1) call for help (dial 911), (2) check for
signs of opioid overdose, (3) support the individual's
breathing, (4) administer naloxone, and (5) monitor the
individual's response.

Mi,<-yNro~be ,          , >,       .-     -
Concern about opioid overdose deaths has led many people,
including the members of the President's Commission on
Combating Drug Addiction and the Opioid Crisis, to call
for increased access to naloxone. Comparatively few people
oppose expanded access to naloxone, arguing that such
efforts implicitly condone opioid abuse. Naloxone must
often be administered by lay people outside a medical
setting (as described above); however, until recently
naloxone was available only in an injectable form, which
may be difficult for a lay person to administer (see Dosage
Form in the next column). Also, naloxone is currently
available by prescription only, which limits access (see
Prescription Requirement in the next column).


Naloxone is regulated under the Federal Food, Drug, and
Cosmetic Act (FFDCA, 21 U.S.C. §§301 et seq.), which
gives the Food and Drug Administration (FDA) in the
Department of Health and Human Services (HHS) primary
responsibility for ensuring the safety and effectiveness of
drugs, regardless of whether they are controlled substances.
See CRS Report R41983, How FDA Approves Drugs and
Regulates Their Safety and Effectiveness. Naloxone is not
known to carry risk of addiction and is not regulated under
the federal Controlled Substances Act.

Representatives of the FDA and other HHS agencies have
publicly discussed two major options for increasing access
to naloxone: (1) making naloxone available in easier-to-
administer forms and (2) making naloxone available
without a prescription.


For more than 40 years, naloxone was available only in an
injectable form, which is difficult for nonprofessionals such
as friends or family members to administer. Further, both
medical professionals and nonprofessionals are at risk of
accidental needle sticks when giving injections. In recent
years, the FDA has approved naloxone in forms that are
easier to administer.

Table I. Naloxone: Dosage Form

  Dosage Form           Sold As        Year Approved

Injectable         naloxone (generic)        1971
Auto-injector      Evzio®D                  2014
Nasal spray        NARCAN®                  2015
Source: Data publicly available from the FDA's Orange Book.
Notes: Injectable naloxone is available as a generic drug marketed by
multiple manufacturers: Evzio® is a registered trademark of Kal~o,
Inc., and NARCAN® is a registered trademark of Adapt Pharma
Operations Limited.


Naloxone is currently available only by prescription. The
FFDCA offers two mechanisms by which naloxone could
become a nonprescription (over-the-counter) drug. One
mechanism is the submission of a new drug application
(NDA) or a supplemental NDA, which would have to be
submitted by the manufacturer. The other mechanism is via
rulemaking pursuant to 21 C.F.R. §310.200(b), which
allows a prescription exemption when the Commissioner of
Food and Drugs finds that prescription-dispensing
requirements are unnecessary for safe and effective use of a
drug in self-medication (as directed by proposed labeling).
This process may be initiated by the commissioner or any
interested person (i.e., a citizen petition).


.O 'T


gogn, q \popmm- ,  goo
g
              , q
aS
' X
11LULANJILiN,

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline.

Already a HeinOnline Subscriber?

profiles profiles most