Comment Submissions - Announcement of Additional Public Comment Period on Acetaminophen

OEHHA: Acetaminophen is a key medication to control surgical pain. In this period of increasing medication shortages, anesthesiologists commonly need to be creative as to which pain medications are available to be given. Removing acetaminophen will decrease our already limited options. Secondly, in this period of trying to minimize narcotics, we commonly rely on acetaminophen to decrease the pain of surgery. Multimodal (using pain medications from different classes) is very effective, and limiting the classes of medications at our disposal will limit pain control options. Third, acetaminophen is unique in the fever reduction aspects - which no other medication has. The science on acetaminophen is strong. It is one of the most widely study medications, with an incredibly safe record. I am aware that California politicians have written to this body to try to educate about the science of this medication, so I will not reiterate what they have already stated. However, I believe the Associate Press said it best with: "The U.S. Food and Drug Administration has warned state officials that labeling acetaminophen as cancer-causing would be “false and misleading” and also illegal under federal law." If OEHHA declares acetaminophen causes cancer, many physicians will not prescribe this important medication to their patients. No physician will prescribe a carcinogen in order to avoid a few days of post surgical pain. In short, please think of patients first and do not label acetaminophen as a carcinogen without robust, compelling scientific data. Respectfully submitted, Phillip J. Richardson, MD, MBA, FASA, CPE California Anesthesiologist