However, in their July 25, 2012 petition to the FDA, the members of PROP asked the FDA to “strike the term moderate from the indication for noncancer pain, add a maximum daily dose, equivalent to 100 mg of morphine for noncancer pain, and add a maximum duration of 90-days for continuous (daily) use for noncancer pain.”
However, I do not believe that PROP has made its case. For starters, consider the language we use to describe pain. Since we have no scientific basis for the precise measurement of pain, exactly how will the line between moderate and severe chronic noncancer pain be determined? If opioid analgesics are not anesthetics, why wouldn’t we expect patients to continue experiencing pain while taking opioids? If patients have chronic pain, and it is associated with depression about 50% of the time, why are we surprised that there are comorbid mental health issues? If an individual patient has no problems associated with the use of 120, 180, or 240 mg of morphine equivalent on a daily basis, why do we need to reduce that dose? If an individual patient is functioning well with opioid therapy after 90 days, and there is no better treatment available, why would we stop treatment and inflict worsening pain? Assuming we agree to restrict opioids to fewer patients, will we really see fewer deaths, or just fewer deaths directly due to overdose instead of suicide? How exactly do we respect the patient’s right of autonomy and then override the decisions they make in consultation with their providers? What will become of the patient-physician relationship when absolute “rules” are enacted, and no individual distinctions are permitted?