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    Comments Submitted to the Expert Committee on the Use of Essential Drugs

    April 10, 2002

    Comments regarding the inclusion of antiretrovirals (ARVs) and the WHO process for updating the model list of essential drugs (EDL), submitted on behalf of Health GAP (Global Access Project)

    The effort by the WHO to increase the relevance and usefulness of the EDL is, for people living with HIV/AIDS, both welcome and long overdue. By eliminating the price of medicines as a de facto criterion for exclusion from the EDL, the WHO has paved the way for creating an EDL that is a crucial tool for people with HIV/AIDS, their care providers and Member governments working for sound and just national medicines policies.

    We urge the WHO to expedite the rapid inclusion of powerful ARVs to the updated EDL. Sufficient data defining the toxicities and efficacy of ARVs has been generated by the scientific community during the years the WHO chose to exclude ARVs from the EDL.

    We note that the most recent list of ARVs submitted to the Expert Committee for consideration and posted to the WHO website is incomplete, lacking key medicines with demonstrated usefulness in resource-poor settings such as nevirapine. The Expert Committee should correct these and other omissions.

    The Expert Committee should give special attention to the addition of fixed dose combination (FDC) ARVs to the updated EDL, including d4T+3TC+nevirapine.

    FDC ARVs are important for increasing compliance among people with HIV, diminishing the risk of drug resistance and drug failure. People with HIV/AIDS need access to powerful combinations of antiretrovirals in order achieve full benefit from this category of medicines.

    The rational development of FDC ARVs has been neglected among most drug manufacturers because (in all but the case of AZT+3TC+abacavir/Trizivir) FDC ARVs would require collaboration among proprietary companies. This decision by industry has worsened the crisis in untreated HIV disease. A decision by the Expert Committee to highlight the importance of FDC ARVs can play a significant role in rectifying this situation.

    The efforts of WHO related to the update of the EDL‹the development of the WHO Model Formulary as well as the WHO Essential Medicines Library‹will yield practical tools that should have been available to countries working for access to essential medicines years ago, in accordance with requests from Members in numerous WHA resolutions. WHO must allocate sufficient resources and high priority for the accelerated completion of these projects.

    submitted by Asia Russell for Health GAP. email: asia@critpath.org | tel: +1 267 475 2645


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