Docket: FDA-2009-N-0392
Medical Devices: Neurological Devices; Electroconvulsive Therapy Device; Establishing a Public Docket
Comment On: FDA-2009-N-0392-0001
Medical Devices: Neurological Devices; Electroconvulsive Therapy Device; Establishing a Public Docket
Submitter Information
Organization: National Council on Independent Living’s (NCIL) Task Force on Violence and Abuse of People with Disabilities
General Comment
“Primum non nocere”
Until the medical profession, legislature or the FDA begin to heed the words of advocates and “survivors” of ECT and ban it’s use all together; the NCIL Task Force on Violence and Abuse of Individuals with Disabilities supports the position allowing the FDA to more closely regulate the manufacturers of ECT devices and those practitioners utilizing ECT as a treatment modality.
We encourage the FDA to use this regulation as an opportunity to research the long term effects of ECT; looking at not only the physical ramifications but also the emotional trauma one experiences and the stigma associated with having a history of this type of treatment.
ECT has survived 43 years of existence, while thankfully many of its counterparts have been all but removed from psychiatric treatment planning, such as lobotomies, insulin shock treatments, eugenics, gyrators, starvation and use of a tranquilizing chair.
Individuals with mental illness are at a very high risk of becoming victims of violence and abuse; and victims of violence and abuse are at great risk of developing a mental illness. Close scrutiny of who gets treated with ECT is needed so survivors of violence and abuse are not re-victimized by the treatment, proposed to be helpful.
The quick “cure” is not the most effective course to take with survivors because there is a need to process, explore and master the trauma, these goals are better reached through the use of talk therapy.
NCIL supports mental health parity that would give individuals more choices in the treatments of their mental illness and will continue to work with advocates across the country to end this often barbaric treatment of our fellow human beings.
View submission on Regulations.gov
