Open Letter of Appeal to FDA about Electroconvulsive Therapy (ECT)

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During ECT, a large electric charge (800-900 milliamperes) is pulsed through the brain for up to eight seconds (depending on device settings). It causes the “Flat-lining” of brain activity.

When brain activity resumes, it resumes in periodic flashes of coma (delta) waves. Those flashes gradually become more frequent and then the recipient awakes from a coma. (Kirstein, L., & Ottosson, J.-O. (1960).

Experimental studies of electroencephalographic changes following electroconvulsive therapy: the role of the electrical stimulation and of the seizure studied by variation of stimulus modification by lidocaine of seizure discharge. Acta Psychiatrica Scandinavica. Supplementum, 35(145), 49–67. Retrieved from https://pubmed.ncbi.nlm.nih.gov/14409401/).

I was severely injured by ECT so I have a deep personal interest in ensuring the public understands the true risks of this procedure to make informed treatment decisions.

Poorly understood risk factors patients should be aware of:

  • electroconvulsive therapy’s (ECT) safety testing
  • electrical dosing standards and limits

Reaching out to the FDA

To do this I submitted a Freedom of Information Act request to the FDA for all of ECT’s Premarket Approval (PMA or safety testing) applications and Product Development Protocols (PDP or ECT’s electrical dosing rules).

The FDA established a deadline for manufacturers to submit this information by March 26, 2019. I gave device manufacturers an extra day, requesting information submitted by March 27, 2019.

I requested this information from the US FDA because I feel it is the only way to prioritize patient safety.

Life after ECT is not easy because repetitive brain injury assessment, rehabilitation and other support is not available.

I feel that all electroshock patients and their family members deserve to understand:

  • ECT is not standardized
  • Every doctor who administers ECT does so using more than seven variables and including unique settings on one of several unstandardized medical devices
  • ECT is a more an art than an evidence-based medical treatment
  • Research confirms that ECT Risks outweigh perceived benefits
  • There is no after care to identify, manage or support people who live with the severe effects of ECT

The FDA denied my expedited request saying that I did not demonstrate compelling need.

I responded by writing an open letter of appeal which included 97 citations.

It is co-signed by 14 professional and paraprofessional organizations, 168 Americans, and 49 international citizens whose countries base their guidelines in part on the FDA’s decisions.

Signatories included up to eight words to describe their perspective on “Real-World Data” and “Real-World Evidence” regarding electroconvulsive therapy’s (ECT) post-market safety, adverse events and regulatory decisions. (read here)

You can find more information about the Audit ECT Campaign and the international patient safety petition from the following links

Sarah P. Hancock

Sarah Price Hancock, MS, CRC, lived for nearly two decades misdiagnosed with severe "treatment resistant" mental illness. She was given 116 bilateral ECT treatments and now lives with Delayed Electrical Injury's Myoneuroal Disorder. Sarah holds a Master’s in Rehabilitation Counseling and taught for four years in San Diego State University’s Rehabilitation Counseling program. She is the Co-Founder and Trustee of the Ionic Injury Foundation. She also hosts The Emotional Self-Reliance Podcast and guest lectures on psychiatric recovery.