Piracetam raises FDA concerns

seep

Bluelighter
Joined
Nov 28, 2008
Messages
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Hi mods sorry if this skirts the rules but there's no other way to post news about this and I thought it was a hoax until the FDA actually posted the warning letter (which I quote in near-entirety in the NSFW box cuz federal documents are in the public domain) yesterday

GRAHAM, N.C.—A vendor received a warning letter from FDA in late August, questioning the marketing of several dietary supplement products, including . . . piracetam . . .

FDA cited concerns about Brand A Piracetam and Brand B Piracetam, specifically stating the products, marketed as dietary supplements, do not contain any “dietary ingredients" approved for sale in the United States, meaning the products do not qualify as dietary supplements. While the vendor did submit a new dietary ingredient notification (NDIN) in 2003 for piracetam, FDA responded in 2004 that it did not consider piracetam to be a dietary ingredient. If the products are not dietary supplements, the agency determined certain structure/function claims made on the products relating to support of memory, cardiovascular health, and reduction of stress and fatigue position the products as unapproved drugs.

Link to official copy of warning letter, which was posted yesterday.

Relevant text of warning letter:

NSFW:
Public Health Service
Food and Drug Administration Atlanta District Office
60 Eighth Street N.E.
Atlanta, GA 30309

August 30, 2010

WARNING LETTER
10-ATL-19​

HAND DELIVERED

Mr. Vendor, Owner
address of vendor

Dear Mr. Vendor:

On February 16 - 17, 2010, the U.S. Food and Drug Administration (FDA) conducted an inspection of your facility located at address. We have also reviewed your firm's website...

This letter concerns your firm's marketing of the following products: Brand A Piracetam, Brand B Piracetam . . .

Piracetam Containing Products

Your firm markets your piracetam products, "Brand A Piracetam"
and "Brand B Piracetam" as dietary supplements; however, both products are excluded from the definition of a "dietary supplement" under section 201(ff)(1) of the Act, 21 U.S.C. § 321(ff)(1). To be a dietary supplement a product must, among other things, "bear[ ] or contain[ ] one or more ... dietary ingredients" as defined in section 201(ff)(1) of the Act. Section 201(ff)(1) of the Act defines "dietary ingredient" as a vitamin, mineral, amino acid, herb or other botanical, or dietary substance for use by man to supplement the diet by increasing the total dietary intake, or a concentrate, metabolite, constituent, extract or combination of any dietary ingredient from the preceding categories. The only substance listed as a dietary ingredient on the labeling for your "Brand A Piracetam"
and "Brand B Piracetam" products is piracetam. Piracetam is not a vitamin, mineral, amino acid, herb or other botanical, or dietary substance for use by man to supplement the diet by increasing the total dietary intake. Further, piracetam is not a concentrate, metabolite, constituent, extract or combination of any such dietary ingredient. Thus, because your Brand A Piracetam and Brand B Piracetam products do not bear or contain any dietary ingredients as defined in section 201 (ff)(1) of the Act, these products do not qualify as dietary supplements under section 201(ff) of the Act.1

Your website and labeling include statements such as the following:

Brand A Piracetam

• "Piracetam supports memory and concentration, overall well-being, cardiovascular health, and helps reduce stress and fatigue."

Brand B Piracetam

• "Piracetam supports memory and concentration, overall well-being, cardiovascular health, and helps reduce stress and fatigue."

The claims listed above make clear that "Brand A Piracetam"
and "Brand B Piracetam" are intended to affect the structure or any function of the body of man or other animals. Accordingly, these ·products are drugs, under section 201(g)(1)(C) of the Act, 21 U.S.C. § 321(g)(1)(C), because they are not foods and they are intended to affect the structure or any function of the body. Moreover, these products are new drugs as defined by section 201(p) of the Act, 21 U.S.C. § 321(p), because they are not generally recognized as safe and effective for use under the conditions prescribed, recommended, or suggested in their labeling.

Under sections 301(d) and 505(a) of the Act, 21 U.S.C. § 331(d) and 355(a), a new drug may not be introduced or delivered for introduction into interstate commerce unless an FDA approved application is in effect for it. There are no approved applications for "Brand A Piracetam"
and "Brand B Piracetam." Your sale of these products without approved applications violates these provisions of the Act.

. . .

The issues and violations cited in this letter are not intended to be an all-inclusive statement of the violations that exist in connection with your products. You are responsible for investigating and determining the causes of the violations identified above and for preventing their recurrence or the occurrence of other violations. It is your responsibility to ensure that all products marketed by your firm comply with the Act and its implementing regulations.

You should take prompt action to correct the violations cited in this letter. Failure to promptly correct these violations may result in legal action, without further notice, including, without limitation, seizure and injunction. Other federal agencies may take this Warning Letter into account when considering the award of contracts.

Within fifteen (15) working days of receipt of this letter, please notify this office in writing of the specific steps that you have taken to correct violations. Include an explanation of each step being taken to prevent the recurrence of violations, as well as copies of related documentation. If you cannot complete corrective action within fifteen working days, state the reason for the delay and the time within which you will complete the corrections. Furthermore, please advise this office what actions you will take to address product that you have already distributed.

Additionally, if another firm manufactures the products identified above, your reply should include the name and address of the manufacturer. If the firm from which you receive the product is not the manufacturer, please include the name of your supplier in addition to the manufacturer.

Please send your reply to Derek C. Price, Compliance Officer, U.S. Food and Drug Administration, 60 Eighth Street, N.E., Atlanta, GA 30309. If you have any questions about the content of this letter, please contact Mr. Price at 404-253-2277.

Sincerely
/S/
John Gridley
District Director
Atlanta District Office

* We note that in 2003, (b)(4) submitted a New Dietary Ingredient Notification (NDIN) for piracetam, naming your firm as the distributor, pursuant to section 413(a)(2) of the Act, 21 U.S.C. §350b. Section 413(a)(2) of the Act requires premarket notification to CFSAN prior to the introduction of a new dietary ingredient into interstate commerce. The NDIN is required to contain infonnation which is the basis for the conclusion that a dietary supplement containing such new dietary ingredient will reasonably expected to be safe. CFSAN's response letter
to Mr. (b)(4) NDIN, which was issued on January 9, 2004, stated that piracetam is "not a dietary ingredient."
 
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of all drugs, piracetam

the DEA's day will come. awareness will continue to increase in society. they can't see the cliff ahead of them

the suffering caused by certain agencies needs to be accounted for in my opinion. interfering with our medicine, wiping less affluent neighborhoods clean entirely, hidden money transfers, jailing the mentally ill, with an overall tint of racism

piracetam, with no addictive potential, with evidence that supports those claims mentioned in the OP, now has the FDA's eye? keep it up, you're suppressing what is fundamentally human, our growth and improvement of ourselves
 
Wow, I'm glad I fell for the "vendor trick" then. It was actually a pretty good deal and I was out, so no harm in any case. I just felt a little silly when I heard people saying it was a lie to unload piracetam.

Well said qwe. These prohibitive agencies are a criminal gang of extortioners saving the healthy and disciplined from substances that give them unique control over having some of the best and most profound experiences in life (esp. psychedelics).

If any employees read this while googling for stories of your own ego-boosting heroics, listen up. Quit your job. You're ignorance and ironic self-righteousness is both dangerous and tragic. Get over yourself and do something better with your life.
 
I'm usually a fan of the FDA but I think they're being dangerously nit-picky here. What's gonna happen (as they well know) is it'll be sold as an RC and so it won't fall under their cGMP purview. There'll be little incentive for vendors to market a pure product and toxic reactions to side products will likely occur.

I don't buy into the anti-FDA conspiracy theories, but it looks like they're forgetting their principal mission, which is to protect the American public from poorly manufactured foods and unsafe pharmaceuticals. Honestly, I don't know what the FDA's plan is with piracetam. Maybe the relevant investigators just need some sex or something so they'll lighten up a bit and keep things in perspective.
 
^I don't buy into FDA conspiracy theories either (in fact after having the opportunity to speak with some of the smartest and most respected people in the world and watching them futilely try to create a coherent plan to advise an interdisciplinary research program during a fellowship a year ago I've never been more convinced that humans are far too self-interested and incompetent to succeed at most all large and complicated conspiracies.)

I do, however, believe strongly in the irrational conviction in, and resistance to change, beliefs that people are certain they have arrived at through the principled guide of their own efforts.
 
I contacted the FDA to ask them directly about the issue and got the following response, feel free to repost this in other piracetam-ban related forums:

NSFW:
Thank you for writing to the Division of Drug Information in the Center for Drug Evaluation and Research (CDER). Please accept our apology for the delay.

The information we received from the Office of Compliance is that the FDA has recently issued a Warning Letter to a firm that was marketing piracetam-containing products. (See http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm225605.htm). The firm was marketing piracetam products as dietary supplements. Piracetam is not a dietary ingredient, and the products do not qualify as dietary supplements. These products are drugs because they are intended to affect the structure or any function of the body. There are no approved applications for these products, as such, they are unapproved new drugs because they are not generally recognized as safe and effective for use under the conditions prescribed, recommended, or suggested in their labeling. The sale of these products without approved applications violates these provisions of the Federal Food, Drug, and Cosmetic Act.

The FDA is responsible for ensuring that that drugs products marketed in the United States are shown to be safe and effective, of good quality and to meet appropriate standards for manufacturing and labeling. This is generally done through the new drug approval process. The FDA drug development and approval process can be found on the Agency's website at http://www.fda.gov/Drugs/Developmen...pplications/NewDrugApplicationNDA/default.htm

We hope this information is helpful to you.

Sincerely,

Division of Drug Information LL
Center for Drug Evaluation and Research
Food and Drug Administration

For up-to-date drug information, follow the FDA's Division of Drug Information on Twitter: http://twitter.com/fda_drug_info

This communication is consistent with 21 CFR 10.85 (k) and constitutes an informal communication that represents our best judgment at this time but does not constitute an advisory opinion, does not necessarily represent the formal position of FDA, and does not bind or otherwise obligate or commit the agency to the views expressed.

They also provided a nifty link to the FDA twitter!
 
You guys aren't understanding this-


The FDA is not banning Piracetam. The FDA issued a warning letter to the vendor because he was wrongly marketing Piracetam as a dietary supplement. This is a case-specific letter to a single vendor. Once again, the FDA has not announced any plans regarding a ban on Piracetam.
 
Mr. Man, I agree with the letter of what you're saying, but not the spirit. There's a lot of great shit that has had to go gray in recent years because the FDA has bullied the vendors.
 
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