age- and development-dependent changes in the adverse effects of medicines, both short and long term; and
unique pediatric diseases that require development of unique pediatric medications.
For orally administered drugs, children of different ages often need or prefer formulations that differ from those used with adults. These formulations may include liquids, chewable tablets, rapidly dissolving tablets, and more palatable flavors. A critical impetus for the Federal Food, Drug, and Cosmetic Act of 1938, (the basis for the modern FDA) was a tragedy involving a liquid sulfonamide that cost the lives of over 100 adults and children (Ballentine, 1981; Wax, 1995; Hilts, 2003). When the sulfonamides—the first truly effective antimicrobials—were developed in the 1930s, they came in pill form, which was not suitable for very young children. For a liquid formulation, the manufacturer’s chief chemist tried several solvents before devising a so-called elixir of sulfanilamide dissolved in diethylene glycol, a pleasant-tasting but toxic substance. The mixture, which also included flavoring agents, was evaluated for taste and fragrance but not safety. At least 34 children and 71 adults died of kidney failure after taking this elixir (Wax, 1995).6
Instances of harm to children from other unsafe drug formulations continue to occur. For example, in 1982, FDA warned that 16 premature infants had experienced “gasping syndrome” (resulting from metabolic acidosis leading to respiratory distress and other severe effects) and then died after being given intravenous medicines that contained excessive amounts of benzyl alcohol as a preservative (CDC, 1982). As recently as 2001, the warnings about this syndrome were added to labeling information for an intravenous drug—with the same preservative—that has been used on an off-label basis to treat cardiac arrhythmias in infants (de Vane, 2001). In developing countries, pediatric deaths have been associated with local formulations of acetaminophen containing diethylene glycol (Hanif et al., 1995; O’Brien et al., 1998).
At the time, the government was able to investigate the deaths and retrieve the unconsumed amounts of the toxic drug only because the manufacturer incorrectly labeled it an elixir, which wrongly implied the presence of alcohol and thus constituted illegal misbranding under the statutes of the time. The government could not have acted if the drug had been labeled simply a solution (Ballentine, 1981; Wax, 1995). Reflecting the FDA’s weakness at the time, the physician who first reported a suspicious pattern of deaths following consumption of the elixir contacted not the FDA but the American Medical Association’s Council on Pharmacy and Chemistry.