OTC Products: Age Limits for Safe Use
While the FDA was scrutinizing nonprescription
products to determine time limits for safe use (see last
month’s “Consult Your Pharmacist”), the agency also was
examining the need for age limits on OTC medications.
The FDA determined minimum ages for safe use of many
ingredients. Pharmacists can help ensure that these
guidelines are followed.
FDA-approved age limits are clearly marked on the
labels of most nonprescription products; however,
various manufacturers have begun supplying their own
pediatric dosing charts. The FDA has questioned the
legality of these charts, and pharmacists need to be
aware of how to use the dosing information provided (see
“Manufacturer-Supplied Dosage Charts for Babies”).
However, even when an FDA-approved dosage
recommendation is provided, the pharmacist may be
confronted with an uncomfortable dilemma regarding
dosing. For example, a parent or caregiver may wish to
be advised of a safe dose of an antidiarrheal for a
14-month old or a proper dose of an
antihistamine-containing cold preparation for a 4-year
old. Labels on such products recommend consultation with
a physician, but the parent/caregiver often approaches
the pharmacist instead. Even with the best of
intentions, the pharmacist who suggests a dose runs the
risk of harming the child and incurring liability. For
this reason, it is helpful to examine several products
and their respective age cut-offs.
Rationales for
Age Limits
The FDA recognizes that consumers need guidance in
regard to safe ages for use of nonprescription products
for several reasons. This article will categorize some
of the reasons and provide examples to assist the
pharmacist in performing patient triage (recommending an
OTC product, referring the patient to a medical
practitioner, or recommending against use of an OTC
product). Some ingredients may have several reasons why
their use is not recommended for patients below certain
ages.
Unacceptable Risk: In some cases,
patients below a certain age may experience adverse
effects of a product or its active ingredient, and the
effects would be too severe to warrant any potential
benefit from use. For example, oral antihistamines
generally are not labeled for use in patients under the
age of 6 years. (The only exception is the FDA-approved
use of dimenhydrinate in motion sickness.) The
antihistamine precaution stems from a possibility of
paradoxical stimulation, rather than the expected
drowsiness, seen in patients younger than 6 years.1
Thus, anyone requesting a recommendation for a product
to treat the common cold or allergic rhinitis should be
questioned to determine the patient’s identity and age.
Another example of unacceptable risk in pediatric
patients is with codeine. Schedule V codeine-containing
cough preparations are sold without a prescription in
some states, provided the pharmacist and patient comply
with applicable state laws. During the FDA’s
nonprescription drug review, several pediatricians
stressed that codeine in children would be dangerous.2
The agency affirmed that children under the age of 6 are
most vulnerable to codeine reactions, such as
respiratory arrest, coma and death. For that reason, the
final warning on codeine-containing products prohibits
dosing in patients younger than 6 years old. If the
product is administered to children under age 6
(presumably only with a physician’s approval), the FDA
advises use of a special dosing device.
Inability to Use the Product Properly:
In some cases, the FDA places an age limit on a
nonprescription ingredient because a child may not be
capable of properly using products that contain the
ingredient. An example is fluoride-containing rinses,
which are used topically to strengthen dental enamel,
through correctly rinsing and expectorating.
Unfortunately, children under the age of 6 years may not
have full control of the swallowing reflex, and may
accidentally swallow the rinse.3
If a child younger than 6 years ingests excessive
fluoride, dental fluorosis resulting in dental staining
is possible. If the city in which the child lives has a
water supply that is fluoridated, the risk of dental
fluorosis is magnified. Thus, current labeling on
fluoride-containing dental rinses states, “Children
under 6 years of age: consult a dentist or doctor.”4
Little Need for the Product: Some
products are given an age limit because the FDA does not
envision a situation in which children younger than that
age would or should need it. One example is the use of
syrup of ipecac. Syrup of ipecac is used for induction
of emesis in accidental or intentional poisonings.
Although a dose is provided for patients as young as
6 months old, the FDA declined to extend dosing for
children below that age. The agency stressed that the
risk of accidental poisoning in children under the age
of 6 months would be extremely rare because children are
usually quite limited in voluntary mobility at those
ages.5
Sunscreens are a somewhat different example of
products that should not be necessary in young children.
For several reasons, children under the age of 6 months
should not be taken into the sun for periods long enough
to warrant sunscreen use. The child cannot properly
verbalize that his or her skin is becoming sunburnt,
cannot voluntarily move to the shade, cannot sweat
effectively, and has low dermal melanin content.6
Further, the skin of children under the age of 6 months
may have different absorptive characteristics from the
skin of older children and adults. Enhanced percutaneous
absorption of sunscreen may occur.7
Thus, the FDA does not permit labeling of sunscreens for
use in children younger than 6 months, and there is
little need for them because parents or caregivers
should completely avoid placing young babies in the sun.
Condition Reflects Serious Pathology:
The pharmacist should be extremely wary in selling
certain groups of products for use in young patients.
The conditions for which the products are indicated
would usually be trivial in an adult but would reflect
serious pathology in a child. One example is the use of
toothpastes containing potassium hydroxide for
hypersensitive teeth. Hypersensitive dentinal enamel is
a phenomenon caused by many contributing factors. The
primary cause is recurrent microtrauma to the dental
enamel caused by overzealous brushing or using a brush
with unacceptably firm bristles. Either practice can
thin dental enamel and open dentinal tubules, allowing
the inner tooth pulp to register pain when confronted
with heat, cold, sweets, air, or pressure. Dentinal
thinning occurs after a fairly long period of enamel
removal, making this etiology virtually nonexistent in
childhood. If a child has hypersensitive dental enamel,
it may be due to serious causes, such as a cracked tooth
or filling, caries, or malocclusion (teeth do not align
properly while chewing). Therefore, toothpastes for
hypersensitive dental enamel are not permitted for use
in patients under the age of 12 years unless recommended
by a dentist or physician.8
The pharmacist should refer patients under the age of 12
complaining of dental hypersensitivity to a dentist to
rule out any serious underlying cause for the problem.
MANUFACTURER-SUPPLIED
DOSAGE CHARTS FOR BABIES |
For the last several
decades, some manufacturers of nonprescription
products have supplied dosage charts to pharmacists.
The charts purport to provide safe dosages for
babies as young as 0–3 months of age. Cough-cold
remedies, acetaminophen, loperamide, and ibuprofen
are some of the products whose manufacturers have
formulated pediatric dosing recommendations.
Pharmacists often assume that these charts are
FDA-approved and that the dosages are appropriate
for them to use for patient recommendations.
However, these pediatric dosages were provided in
FDA monographs as professional labeling, which is
only to be used when relationship exists between the
patient and another licensed prescriber (e.g.,
physician, dentist). The FDA has addressed this
issue through the office of the Division of OTC Drug
Evaluation.12 The
agency stressed that pharmacists providing advice
about professional uses of nonprescription products
could be subject to civil liability. When a
manufacturer alleges that the charts are
FDA-approved, pharmacists should ask for a letter to
the company from the FDA, specifically approving the
dosage information. If such a letter cannot be
provided, the pharmacist should realize the
potential for patient harm and resulting civil
liability before making recommendations. |
A similar age problem arises with hemorrhoid
treatments. Hemorrhoids may persist for many years
without serious sequelae in adults. However,
hemorrhoidal symptoms in children usually indicate a
serious underlying condition, such as parasitic
infestation, rectal prolapse, megacolon, or cystic
fibrosis. When pediatric hemorrhoids are actually
present, they are a result of serious conditions such as
portal hypertension associated with liver disease, vena
caval or mesenteric obstruction, or cirrhosis. The
underlying condition must be promptly treated for the
hemorrhoids to subside. For this reason, nonprescription
hemorrhoidal products are contraindicated in patients
under the age of 12 without a physician recommendation.9,10
Skin hyperpigmentation disorders are a final example
of conditions that may reflect underlying pathology in
pediatric patients. Skin lightening agents containing
hydroquinone (e.g., Porcelana, Esoterica) are approved
for use in ephelides (sun-induced freckles). However,
pharmacists must question children or caregivers
interested in using the products to ensure that the
lesions to be treated are small, medium-brown macules
scattered across the skin in areas of sun exposure. The
macules should fade in the winter season. If the lesions
do not reflect this pattern, the patient, regardless of
age, should be referred. Patients under the age of 12
should obtain a physician recommendation for
hydroquinone use.11
This allows the practitioner to confirm the existence of
sun-freckles while ruling out other causes of skin
discoloration (e.g., tinea versicolor or
medication-induced pigmentation).
Highest and
Lowest Age Limits
Teething Products: The lowest age limit
specifically labeled by the FDA is for teething products
(e.g., topical benzocaine). These products were assigned
an age limit of 4 months; their use is not recommended
in children under that age without a practitioner’s
recommendation.6
Recent Rx-to-OTC Switches:
Conversely, the highest age limits are mostly on recent
Rx-to-OTC switches. Ketoprofen should not be recommended
for patients under the age of 16 years. Minoxidil for
hair loss is not indicated for patients 18 years of age
and under. Similarly, nicotine patches and gum cannot
legally be sold to anyone under age 18.6
If a patient under 18 years of age wishes to cease
smoking, the pharmacist must refer him or her to a
physician. The physician may either prescribe a smoking
cessation product or provide a written recommendation
for a nonprescription product. Pending further safety
information, the FDA may also require any diet or cold
product containing phenylpropanolamine to be labeled
with a minimum age limit of 18 years. When in doubt,
pharmacists should always read the label of
nonprescription products to determine the minimum age
for use. If no age recommendations are listed, the
standard limit of 2 years applies (i.e., use is not
recommended in patients under the age of 2 years).
Patient Information
Determining a Safe Dose: The common
cold is one problem for which many people wish to treat
children. However, if you read the labels on cold
medications (such as nasal decongestants and most cough
products), you will not find one to be used in children
under age 2. Some (all products containing
antihistamines) are not to be used in children under age
6. You may still wish to purchase these products, but
there is no dose given on the label to guide you in
giving a safe amount of the product to a young child.
Some people might simply give a 1-year old child half
the dose recommended for a 2-year old, but do not assume
this is a safe thing to do.
Instead, call the child’s pediatrician or general
practitioner to get a recommendation. The physician will
then be aware that your child is taking the product in
case there is a serious reaction to it later. Your
physician also has knowledge of other factors that would
affect safe use of the product, such as other medical
conditions (heart problem, kidney disease). In addition,
pediatricians often have a favorite product (along with
dosage) they can recommend for such problems as nasal
congestion and cough. Further, the pediatrician may wish
to check for conditions that occur with or are mistaken
for the common cold, such as strep throat, sinus
infections, upper respiratory infections, or ear
infections. The child can then be given a prescription
for an appropriate treatment.
Knowing When to See a Doctor:
Several conditions are more dangerous if they occur in a
child compared to when they occur in an adult. In these
cases, the child should see a physician. Diarrhea can
become serious in children very rapidly because of loss
of fluids and electrolytes. Any child under the age of 3
years who has diarrhea should be taken to a doctor.
Adults may treat the minor pain of arthritis, but
arthritis in a child is potentially very serious and
must not be treated without a physician consultation.
Other types of pain in a child (e.g., headache, muscle
aches) are also more serious than in an adult. Labeling
on medications for these problems will warn not to use
the product for more than 10 days in an adult but no
more than 5 days in a child.
Insomnia in an adult is usually a short-term problem
caused by adult worries, but insomnia in a child is a
condition for which the caregiver should seek physician
help. Nonprescription sleeping products are not to be
used in patients under age 12. Sensitive teeth in
children should not be treated with special toothpastes
unless recommended by a dentist or physician. Children
with hemorrhoid symptoms should see a doctor rather than
use over-the-counter treatments. Young patients should
also see a doctor before skin lightening agents (Esoterica,
Porcelana) are used on sun-induced freckles.
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