"When you have a choice to make and don't make it, that is in itself a choice." -- William James

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Ohio Dental Board Logo

 

     David A. Kessler, M.D.
     Commissioner of Food and Drugs
     Food and Drug Administration
     5600    Fishers Lane, Room 14-71
     Rockville, Maryland     20857 
     Dear Dr. Kessler:
     The Ohio State Dental  Board is urgently requesting that the Food and
     Drug Administration  provide guidance to the states regarding the status
     of the dental drug  Sargenti Paste, Sargenti Compound, or N2.
     I understand that a  Sargenti formulation is now under FDA review, and 
     must assume this is being  done under a new drug application (NDA) process.
     Over the years, there  have been many formulas used, most of which contain
     paraformaldehyde, a drug  we feel is unsafe and should not be used on
     the general public.
     I have before me a  certification and affidavit dated October 30, 1990, 
     and signed by Carolann W.  Hooton, that states in part that there is not
     on file, nor has there  ever been on file, an approved NDA, permitting
     the distribution of  Sargenti Paste, Sargenti Compound, or N2, in
     interstate commerce for  use in humans.
     In late 1990, the Ohio  State Dental Board received a copy of a letter
     from Associate  Commissioner for Legislative Affairs, Hugh Cannon, to
     U.S. Senator Howard  Metzenbaum, regarding Sargenti Paste [link].  In  closing, 
     Mr Cannon states that “we  have forwarded your letter to the appropriate
     office within FDA’s  Center for Drug Evaluation and Research (CDER) for
     Review, and any  appropriate followup . . .”  The board  has received no 
     advice, guidance, etc,  from CDER.   We are in need of guidance  from the
     FDA regarding the status  of Sargenti Paste, Sargenti Compound, or N2.
     This Board has proposed a  rule banning the use of Sargenti Paste con-
     taining paraformaldehyde  in our state.  The Ohio Dental Association 
     lobbied members of our  legislature to stop us from taking such an action. 
     Enclosed are letters from  Representative Cliff Skeen to the ADA,  and 
     their reply.
      We are willing to hold up  action on this rule, allowing time for the
      FDA to once again study  the use of this drug and, hopefully, issue 
      guidance to state  regulatory agencies and boards.  Our  problem then
      becomes time, as we  should take action, if this becomes necessary, before
      the end of this  year.  Thus, we ask that you give this  request special
      consideration, and your immediate attention.
         
      Thank you for your assistance.

signature

 

     MHY:sc
     cc: J.R. May, PH.D., Division of Federal-State Relations
     Dr. William Allen, American Dental Association
     Rep. Cliff Skeen, Ohio  House of Representatives
     Board Members
     Omar P. WHisman, Executive Director
     File

 

 

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Retyped 2009
Scanned letter – page 1, page 2