effectiveness of the New Drug Application. I suppose that it is also important to include some provision which would avoid infringement of property rights involved in trademarks that are already in force.* The provision for the compilation of all names, official or generic and proprietary or trademark is a good one, but it is hoped that some way will be found to coordinate this activity with that proposed by the Council on Drugs. This would be essential to avoid different names for the same substances and to avoid duplication of effort. Such cooperation and coordination has become possible with respect to the indexing of medical literature in which the AMA and the National Medical Library are working in unison. It should be possible in the case of the lists of names of drugs, their properties, uses and untoward effects, after these lists have been approved by the FDA and the Council on Drugs of the AMA. Since the AMA has the background and experience and is already doing most of this, the FDA should be able to reconcile the requirements of this bill with that of the educational program of the AMA insofar as it refers to drugs and I would like to express the hope this will be done. In other words, publication and distribution of the information as called for in the last part of this bill can best be carried out as a joint undertaking of the FDA and the Council on Drugs of the AMA. In the same vein it is to be hoped that the editorial and advertising policies of the journals published by the AMA, and following their lead, those of all other reputable journals will include the requirement that only generic or official names be used in all the text materials which they *An authoritative discussion about the naming of drugs was recently presented by Dr. Lloyd C. Miller, Director of Revision of the U. S. Pharmacopoeia, in the J. Amer. Med. Assoc. 177: 27 (July 8) 1961. 73753 0-61-pt. 247 publish and that the proprietary names be referred to either when the drug is first mentioned in the text or in a footnote. A tighter control on advertising matter by the FDA coordinated with that of the Council on Drugs of the AMA should also serve to keep the advertising in trade journals or in the so-called throw-aways or in house organs of pharmaceutical companies, within proper bounds even though it may not be equally possible to control their literary or scientific contents. MONTEFIORE HOSPITAL 210TH ST. & BAINBRIDGE AVE. Telephone: TULIP 1-1000 The Honorable AUG 16 1967gust 14, 1961 Senator Estes Kefauver, Chairman Committee on the Judiciary Subcommittee on Antitrust and Monopoly U.S. Senate Washington, D. C. Dear Senator Kefauver: Re: Hearings on S1552 Friday, July 21, 1961 There is a table on page 7 of my testi mony in which I compared Montefiore's purchase price of drugs by generic name to the list price of drugs by the trade name. As requested, I am enclosing here with another copy of this table which includes a listing of the purchase price to us of these drugs if we were to obtain them under the trade names. With kindest regards, MC:EH- Enclosure Sincerely yours, Жиши Martin Cherkasky, M. D. In accordance with my letter to you of June 13, 1961 I am submitting the views of the American Hospital Association on S. 1552 amending and supplementing the antitrust and federal food and drug laws. As the representative of approximately 5800 hospitals throughout the country, the American Hospital Association's primary concern is with the provision of adequate hospital care for the nation. Good hospitals marshal and organize the best professional skills and judgment available to provide care and treatment of patients. The treatment of these patients in many cases is dependent upon the effective use of drugs. Developments and advances in drugs in the last twenty-five years have been nothing short of revolutionary, and they have made a notable contribution to improved patient care in hospitals. Some of the provisions of S. 1552 are therefore of obvious significance to hospitals. The bill deals with the integrity of drugs from the standpoint of safety, maintenance of identity, strength and proper labeling. It makes provision for the designation of "official" names of drugs which will have a direct impact on the Hospital Formulary System. It may have an effect on the cost of drug purchases by hospitals, which constitute generally about five percent of the total outlay. In some of the larger hospitals, it may be as high as ten percent. |