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www.wjpr.net Vol 3, Issue 10, 2014. 1
Petkova et al. World Journal of Pharmaceutical Research
MARKETING STRATEGIES FOR RETAINING THE MARKET SHARE
OF PHARMACEUTICAL PRODUCTS AFTER THE PATENT
PROTECTION
1
Antoaneta Cvetkova, 2
Valentina Petkova*, 3
Anna Todorova, 2
Milen Dimitrov
1
Medical College, Medical University – Varna, Bulgaria.
2
Faculty of Pharmacy, Medical University – Sofia, Bulgaria.
3
Faculty of Pharmacy, Medical University – Varna, Bulgaria.
SUMMARY
After a patent expires, pharmaceutical companies face the risk of
losing market shares. Reclassifying a brand drug that is “prescription
only” as OTC (over-the-counter) drug is a company strategy for
retention of revenue and profit that come from the sales of this product.
The tendency for reclassification of medical products as OTC drugs
corresponds both to the already prevailing model of patient-centered
care in the health systems and to the greater autonomy of the individual
patient in health care. The decision to switch from Rx to OTC is a real
challenge.
KEYWORDS:- patent expires, reclassification, pharmaceutical companies face.
INTRODUCTION
According to Art.171 [1]
of the Law on the medicinal products in human medicine, the
medicinal products dispensed on the Bulgarian market shall be classified as medicinal
products dispensed with medical prescription and medicinal products dispensed without
medical prescription (over-the-counter drugs). [9]
In most countries, access to and supply of medicinal products are governed by a regulatory
framework which is based on the risk-benefit assessment of a particular drug. In the United
Kingdom, for instance, there are three categories of medicines: POM (prescription only
medicines) – drugs available to patients only when prescribed by a medical practitioner, P
(pharmacy supervised sale) – drugs sold only under the supervision of a pharmacist, and GSL
World Journal of Pharmaceutical Research
SJIF Impact Factor 5.045
Volume 3, Issue 10, 01-07. Research Article ISSN 2277– 7105
Article Received on
07 October 2014,
Revised on 29 Oct 2014,
Accepted on 19 Nov 2014
*Correspondence for
Author
Dr.Valentina Petkova
Faculty of Pharmacy,
Medical University-
Sofia, Bulgaria.
,
www.wjpr.net Vol 3, Issue 10, 2014. 2
Petkova et al. World Journal of Pharmaceutical Research
(general sales list) – drugs available even outside pharmacies. [1]
These three categories are in
dynamic equilibrium and jointly shape the pharmaceutical market. When a new medicinal
product is licensed for use in the UK for the first time, in accordance with the evidence of its
safety and efficacy provided in the preclinical period, it is classified as POM. Two years later,
this medicine can be reclassified as P, unless there are specific circumstances to retain its
POM status, which is the more normal practice. The reclassification of a medicine goes
through a stringent and precise process of evidence submission and consultations with the
MHRA (Medicines and Health care products Regulatory Agency).
In Europe, there are also clear requirements about the criteria defining when a medicine
retains its POM status (Directive 92/26/EEC). There are various options for reclassification
across European countries, regardless of the initiatives for achieving harmonization of
pharmaceutical regulations within a common framework. When the patent expires, generic
products enter the market almost immediately, causing drastic decline in market share and
sales slump. The switch from Rx status to OTC status can be a good strategy for sales
retention long after patent expiration. Switches are motivated mainly by three factors:
pharmaceutical firms' desire to extend the viability of brand names; attempts by healthcare
funders to contain costs; and the self-care movement. Making drugs available over the
counter affects a large number of stakeholders, including patients, pharmaceutical firms,
physicians, pharmacists, drug regulatory agencies, and private and public health funding
organizations. [3]
Over the counter licensing is linked to direct to consumer advertising. [2]
This gives much
more marketing possibilities for drug promotion, as switch to over the counter can become
indirect advertising directly to consumers. [4]
A successful Rx-to-OTC switch depends on
several factors including the intensity and timing of the OTC marketing campaign of the drug
itself. [5]
In practice however, it is unusual for companies to switch the drug status as long as the patent
is still valid. The decision for drug reclassification is dependent on healthcare policies across
countries and, in particular, on attitudes of medical professionals, evolution of scientific
knowledge, national reimbursement and pricing policies, brand rules and regulations. Drug
deregulation reduces public expenditures, because when a number of drugs switch from
prescription-only to OTC status, they attract new consumers who already do not need a
prescription from a medical practitioner. Since 2007, there have been common European
www.wjpr.net Vol 3, Issue 10, 2014. 3
Petkova et al. World Journal of Pharmaceutical Research
standards guiding the reclassification to OTC status. There is also a draft guide developed by
the European Medicines Agency (EMA) on the packaging of OTC drugs, which includes
guidelines on pictorial symbols, web link, etc. supposed to help patients sort through the
information. The UK has the most “liberal” regime for switching to OTC status. Italy and
Hungary are also in the process of approving the sale of OTC drugs outside pharmacies. [6]
The aim of the European regulatory bodies is to introduce a centralized unified European
guidance on OTC drug status by 2015. (10) The number of medicines that have their status
switched to OTC will continue to grow worldwide, particularly the number of drugs for
treatment of chronic conditions. On a global scale, the most well-established procedures for
switching to OTC status are in the US, the UK, Germany, Spain and Mexico. [8]
Objectives: To examine the impact of drug reclassification on the sales volume across
pharmacies in the city of Varna.
Methodology: We surveyed four allergy products after their switch to OTC status and
examined the impact on their sales volumes. We used data provided by a retail pharmacy
chain of five pharmacies located in the city of Varna.
FINDINGS AND DISCUSSION
For the purpose of this research, we decided to trace the changes in sales volumes of four
different medical products: Allergosan tb. (Chloropyramine hydrochloride) 25 mg / 25
Tablets; Lorano tb. (Loratadine) 10 mg / 7 Tablets; Zyrtec tb. (Cetirizine dihydrochloride) 10
mg / 10 Tablets and Claritine tb. (Loratidine) 10 mg / 10 Tablets.
We selected these antihistamines for a couple of reasons. Allergosan is a typical antiallergic
agent manufactured by a Bulgarian company - Sopharma AD, it is familiar to patients across
a wide age range, and its price is low (BGN 3.06). Zyrtec tb. is a brand name drug
manufactured by UCB Pharma GmbH, Germany. In comparison with Allergosan, it is a more
recent product with less side effects, its dosing is more convenient, but its price is
considerably higher (BGN 13.53). Lorano tb. and Claritine tb. are drugs with different brand
names but with the same INN (both products have the same original molecule - loratadine).
Lorano tb. and Claritine tb. are non-sedating antihistamines with relatively lower prices as
compared to Zyrtec. Lorano tb. is manufactured by Salutas Pharma GmbH Otto-von-
Guericke-ALLee 1 and its price is BGN 11.60. Claritine tb. is manufactured by Schering-
Plough and its price is BGN 11.60.
www.wjpr.net Vol 3, Issue 10, 2014. 4
Petkova et al. World Journal of Pharmaceutical Research
Table 1 displays unit sales data by year (the data corresponding to the year of reclassification
are in bold).
Table 1. Unit sales before and after deregulation.
Zyrtec Allergosan Lorano Claritine
2008 332 439 Not available 430
2009 480 652 276 627
2010 404 955 389 515
2011 662 1028 344 478
2012 417 1198 397 536
Data show that the sales of all surveyed products increased after the Rx-to-OTC switch.
Especially distinct is the sales trend of Allergosan tb. - the sales in 2012 increased 2.73-fold
in comparison to the sales in 2008 (the year preceding the status switch). The sales after the
switch to OTC status of the other surveyed drugs increased as well – a 1.26-fold increase for
Zyrtec tb, a 1.44-fold increase for Lorano tb, and a 1.25-increase for Claritine tb. The sales of
Allergosan for the period 2008-2012 surged at an average annual sales growth rate of 213.16
percent. Though Claritin tb. saw a downward sales trend from 2009 until 2011, its average
annual sales growth rate from 2008 through 2012 was 124.72 percent. For the same period,
Zyrtec tb. faced an unstable growth and an average annual sales growth rate of 14.88 percent.
For the period 2009-2012, Lorano tb. experienced an unstable growth and its average annual
sales growth rate was 135.78 percent.
The graphs below display the sales trends of each separate product.
Fig.1 Allergosan tb. Fig.2 Zyrtec tb.
www.wjpr.net Vol 3, Issue 10, 2014. 5
Petkova et al. World Journal of Pharmaceutical Research
Fig.3. Claritine tb. Fig.4. Lorano tb.
The model of annual sales trends was developed with regression analysis techniques. As we
can see, the annual sales of Allergosan continued an upward trend throughout the entire
period, whereas Zyrtec tb. faced an unstable sales growth. As a result of deregulation, both
Allergosan and Zyrtec faced an increase in sales in the first year of Rx-to-OTC switch. And
while this uptrend continued throughout the entire period for Allergosan, Zyrtec faced an
increase in sales and sales fluctuations alike. It seems reasonable that the economic crisis and
the considerably higher price of Zyrtec have influenced consumers in their decision to choose
Allergosan rather than Zyrtec.
Fig.5 Sales volume in pharmacies before and after deregulation.
www.wjpr.net Vol 3, Issue 10, 2014. 6
Petkova et al. World Journal of Pharmaceutical Research
As a result of deregulation, both Lorano sales and Claritine sales rose in the first year after
the Rx-to-OTC switch. In the years following the peak in 2009, both products experienced a
sales decline. Still, the levels of sales remained higher than 2008 (the last year the medicines
were dispensed on prescription). Throughout the entire period, both products faced a gradual
increase in sales, more pronounced for Lorano tb. The similar trends of both medicines
indicate the impact of market factors over the sales.
Fig.6 Sales volume in the pharmacies before and after deregulation.
CONCLUSIONS
Intensifying competitive pressure in the health care market and patients’ discontent with the
long waiting times for prescriptions create favourable conditions for a future broadening of
pharmacists’ authority to include pharmaceutical care activities. The trend to deregulation
from POM status and the fact that OTC drugs are available only in pharmacies should be
considered by the pharmacy profession as an opportunity for extending the range of effective
patient counselling and a way of maintaining market positions. The Rx-to-OTC switch
enhances the sales volume and has a positive impact on retailers.
The tendency of Rx-to-OTC switch is inextricably linked to another tendency – the transfer
of drug related costs from the government to the individual consumer. As far as low-priced
OTC drugs are concerned, this is not a major issue. However, some of the newly deregulated
drugs are quite expensive, which additionally restricts patient access and increases health
inequalities. There is a trend toward broadening the range of medicines with OTC status. The
www.wjpr.net Vol 3, Issue 10, 2014. 7
Petkova et al. World Journal of Pharmaceutical Research
OTC market is becoming more competitive and profitable. The Rx-to-OTC switch is one of
the strategies for retention of revenue and profit resulting from product sales. [7]
According to FDA, pharmacists have not only more professional opportunities but also more
responsibilities within this new drug paradigm. [11]
REFERENCES
1. Bond C. The OTC Pharmaceutical Market - Policy and Practice. Pharmaceutical
Monitoring Journal, XII, 2011; 6(64): 5.
2. Bunney RG (2005) Switching prescription drugs to over the counter: Over the counter
licensing is linked to direct to consumer advertising, BMJ, 2005; 330: 906.
3. Cohen JP, Paquette C, Cairns CP (2005) Switching prescription drugs to over the counter,
BMJ 2005 330:39-41)
4. Duerden M and Walley T (2005) Direct to consumer marketing: Switch to over the
counter can become indirect advertising directly to consumers, BMJ, 2005; 330: 906)
5. RX-to-OTC Switching. Market Analysis, Data & Figures, Press Release, www.the-
infoshop.com/press/fe14207_en.shtml, Navigant Consulting, Inc., Accessed November
2014.
6. Major S, Vincze Z, Self-medication in Hungary, from the Perspective.
7. http://www.arbilis.com/periodicals.php?magid, Danchev N, Nikolova I, Petkova V,
Benbassat N, OTC medicines: Bulgarian and World Experience. Science Pharmacology
Journal, No. 1/2011.
8. http://ec.europa.eu/health/ph_overview/Documents/strategy_wp_en.pdf, WHITE PAPER
Together for Health: A Strategic Approach for the EU 2008-2013
9. http://lex.bg/laws/ldoc/2135549536
10. http://www.medicinenet.com/script/main/art.asp?articlekey=79398, Stoppler, M. Alli
(orlistat) Weight Loss Drug Available OTC,
11. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3411219/, Barlas, St. FDA Considers a
New Paradigm for Over-the-Counter Medications, P&T, May 2012; v 37(5).

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Marketing strategies for retaining the market shareof pharmaceutical products after the patent

  • 1. www.wjpr.net Vol 3, Issue 10, 2014. 1 Petkova et al. World Journal of Pharmaceutical Research MARKETING STRATEGIES FOR RETAINING THE MARKET SHARE OF PHARMACEUTICAL PRODUCTS AFTER THE PATENT PROTECTION 1 Antoaneta Cvetkova, 2 Valentina Petkova*, 3 Anna Todorova, 2 Milen Dimitrov 1 Medical College, Medical University – Varna, Bulgaria. 2 Faculty of Pharmacy, Medical University – Sofia, Bulgaria. 3 Faculty of Pharmacy, Medical University – Varna, Bulgaria. SUMMARY After a patent expires, pharmaceutical companies face the risk of losing market shares. Reclassifying a brand drug that is “prescription only” as OTC (over-the-counter) drug is a company strategy for retention of revenue and profit that come from the sales of this product. The tendency for reclassification of medical products as OTC drugs corresponds both to the already prevailing model of patient-centered care in the health systems and to the greater autonomy of the individual patient in health care. The decision to switch from Rx to OTC is a real challenge. KEYWORDS:- patent expires, reclassification, pharmaceutical companies face. INTRODUCTION According to Art.171 [1] of the Law on the medicinal products in human medicine, the medicinal products dispensed on the Bulgarian market shall be classified as medicinal products dispensed with medical prescription and medicinal products dispensed without medical prescription (over-the-counter drugs). [9] In most countries, access to and supply of medicinal products are governed by a regulatory framework which is based on the risk-benefit assessment of a particular drug. In the United Kingdom, for instance, there are three categories of medicines: POM (prescription only medicines) – drugs available to patients only when prescribed by a medical practitioner, P (pharmacy supervised sale) – drugs sold only under the supervision of a pharmacist, and GSL World Journal of Pharmaceutical Research SJIF Impact Factor 5.045 Volume 3, Issue 10, 01-07. Research Article ISSN 2277– 7105 Article Received on 07 October 2014, Revised on 29 Oct 2014, Accepted on 19 Nov 2014 *Correspondence for Author Dr.Valentina Petkova Faculty of Pharmacy, Medical University- Sofia, Bulgaria. ,
  • 2. www.wjpr.net Vol 3, Issue 10, 2014. 2 Petkova et al. World Journal of Pharmaceutical Research (general sales list) – drugs available even outside pharmacies. [1] These three categories are in dynamic equilibrium and jointly shape the pharmaceutical market. When a new medicinal product is licensed for use in the UK for the first time, in accordance with the evidence of its safety and efficacy provided in the preclinical period, it is classified as POM. Two years later, this medicine can be reclassified as P, unless there are specific circumstances to retain its POM status, which is the more normal practice. The reclassification of a medicine goes through a stringent and precise process of evidence submission and consultations with the MHRA (Medicines and Health care products Regulatory Agency). In Europe, there are also clear requirements about the criteria defining when a medicine retains its POM status (Directive 92/26/EEC). There are various options for reclassification across European countries, regardless of the initiatives for achieving harmonization of pharmaceutical regulations within a common framework. When the patent expires, generic products enter the market almost immediately, causing drastic decline in market share and sales slump. The switch from Rx status to OTC status can be a good strategy for sales retention long after patent expiration. Switches are motivated mainly by three factors: pharmaceutical firms' desire to extend the viability of brand names; attempts by healthcare funders to contain costs; and the self-care movement. Making drugs available over the counter affects a large number of stakeholders, including patients, pharmaceutical firms, physicians, pharmacists, drug regulatory agencies, and private and public health funding organizations. [3] Over the counter licensing is linked to direct to consumer advertising. [2] This gives much more marketing possibilities for drug promotion, as switch to over the counter can become indirect advertising directly to consumers. [4] A successful Rx-to-OTC switch depends on several factors including the intensity and timing of the OTC marketing campaign of the drug itself. [5] In practice however, it is unusual for companies to switch the drug status as long as the patent is still valid. The decision for drug reclassification is dependent on healthcare policies across countries and, in particular, on attitudes of medical professionals, evolution of scientific knowledge, national reimbursement and pricing policies, brand rules and regulations. Drug deregulation reduces public expenditures, because when a number of drugs switch from prescription-only to OTC status, they attract new consumers who already do not need a prescription from a medical practitioner. Since 2007, there have been common European
  • 3. www.wjpr.net Vol 3, Issue 10, 2014. 3 Petkova et al. World Journal of Pharmaceutical Research standards guiding the reclassification to OTC status. There is also a draft guide developed by the European Medicines Agency (EMA) on the packaging of OTC drugs, which includes guidelines on pictorial symbols, web link, etc. supposed to help patients sort through the information. The UK has the most “liberal” regime for switching to OTC status. Italy and Hungary are also in the process of approving the sale of OTC drugs outside pharmacies. [6] The aim of the European regulatory bodies is to introduce a centralized unified European guidance on OTC drug status by 2015. (10) The number of medicines that have their status switched to OTC will continue to grow worldwide, particularly the number of drugs for treatment of chronic conditions. On a global scale, the most well-established procedures for switching to OTC status are in the US, the UK, Germany, Spain and Mexico. [8] Objectives: To examine the impact of drug reclassification on the sales volume across pharmacies in the city of Varna. Methodology: We surveyed four allergy products after their switch to OTC status and examined the impact on their sales volumes. We used data provided by a retail pharmacy chain of five pharmacies located in the city of Varna. FINDINGS AND DISCUSSION For the purpose of this research, we decided to trace the changes in sales volumes of four different medical products: Allergosan tb. (Chloropyramine hydrochloride) 25 mg / 25 Tablets; Lorano tb. (Loratadine) 10 mg / 7 Tablets; Zyrtec tb. (Cetirizine dihydrochloride) 10 mg / 10 Tablets and Claritine tb. (Loratidine) 10 mg / 10 Tablets. We selected these antihistamines for a couple of reasons. Allergosan is a typical antiallergic agent manufactured by a Bulgarian company - Sopharma AD, it is familiar to patients across a wide age range, and its price is low (BGN 3.06). Zyrtec tb. is a brand name drug manufactured by UCB Pharma GmbH, Germany. In comparison with Allergosan, it is a more recent product with less side effects, its dosing is more convenient, but its price is considerably higher (BGN 13.53). Lorano tb. and Claritine tb. are drugs with different brand names but with the same INN (both products have the same original molecule - loratadine). Lorano tb. and Claritine tb. are non-sedating antihistamines with relatively lower prices as compared to Zyrtec. Lorano tb. is manufactured by Salutas Pharma GmbH Otto-von- Guericke-ALLee 1 and its price is BGN 11.60. Claritine tb. is manufactured by Schering- Plough and its price is BGN 11.60.
  • 4. www.wjpr.net Vol 3, Issue 10, 2014. 4 Petkova et al. World Journal of Pharmaceutical Research Table 1 displays unit sales data by year (the data corresponding to the year of reclassification are in bold). Table 1. Unit sales before and after deregulation. Zyrtec Allergosan Lorano Claritine 2008 332 439 Not available 430 2009 480 652 276 627 2010 404 955 389 515 2011 662 1028 344 478 2012 417 1198 397 536 Data show that the sales of all surveyed products increased after the Rx-to-OTC switch. Especially distinct is the sales trend of Allergosan tb. - the sales in 2012 increased 2.73-fold in comparison to the sales in 2008 (the year preceding the status switch). The sales after the switch to OTC status of the other surveyed drugs increased as well – a 1.26-fold increase for Zyrtec tb, a 1.44-fold increase for Lorano tb, and a 1.25-increase for Claritine tb. The sales of Allergosan for the period 2008-2012 surged at an average annual sales growth rate of 213.16 percent. Though Claritin tb. saw a downward sales trend from 2009 until 2011, its average annual sales growth rate from 2008 through 2012 was 124.72 percent. For the same period, Zyrtec tb. faced an unstable growth and an average annual sales growth rate of 14.88 percent. For the period 2009-2012, Lorano tb. experienced an unstable growth and its average annual sales growth rate was 135.78 percent. The graphs below display the sales trends of each separate product. Fig.1 Allergosan tb. Fig.2 Zyrtec tb.
  • 5. www.wjpr.net Vol 3, Issue 10, 2014. 5 Petkova et al. World Journal of Pharmaceutical Research Fig.3. Claritine tb. Fig.4. Lorano tb. The model of annual sales trends was developed with regression analysis techniques. As we can see, the annual sales of Allergosan continued an upward trend throughout the entire period, whereas Zyrtec tb. faced an unstable sales growth. As a result of deregulation, both Allergosan and Zyrtec faced an increase in sales in the first year of Rx-to-OTC switch. And while this uptrend continued throughout the entire period for Allergosan, Zyrtec faced an increase in sales and sales fluctuations alike. It seems reasonable that the economic crisis and the considerably higher price of Zyrtec have influenced consumers in their decision to choose Allergosan rather than Zyrtec. Fig.5 Sales volume in pharmacies before and after deregulation.
  • 6. www.wjpr.net Vol 3, Issue 10, 2014. 6 Petkova et al. World Journal of Pharmaceutical Research As a result of deregulation, both Lorano sales and Claritine sales rose in the first year after the Rx-to-OTC switch. In the years following the peak in 2009, both products experienced a sales decline. Still, the levels of sales remained higher than 2008 (the last year the medicines were dispensed on prescription). Throughout the entire period, both products faced a gradual increase in sales, more pronounced for Lorano tb. The similar trends of both medicines indicate the impact of market factors over the sales. Fig.6 Sales volume in the pharmacies before and after deregulation. CONCLUSIONS Intensifying competitive pressure in the health care market and patients’ discontent with the long waiting times for prescriptions create favourable conditions for a future broadening of pharmacists’ authority to include pharmaceutical care activities. The trend to deregulation from POM status and the fact that OTC drugs are available only in pharmacies should be considered by the pharmacy profession as an opportunity for extending the range of effective patient counselling and a way of maintaining market positions. The Rx-to-OTC switch enhances the sales volume and has a positive impact on retailers. The tendency of Rx-to-OTC switch is inextricably linked to another tendency – the transfer of drug related costs from the government to the individual consumer. As far as low-priced OTC drugs are concerned, this is not a major issue. However, some of the newly deregulated drugs are quite expensive, which additionally restricts patient access and increases health inequalities. There is a trend toward broadening the range of medicines with OTC status. The
  • 7. www.wjpr.net Vol 3, Issue 10, 2014. 7 Petkova et al. World Journal of Pharmaceutical Research OTC market is becoming more competitive and profitable. The Rx-to-OTC switch is one of the strategies for retention of revenue and profit resulting from product sales. [7] According to FDA, pharmacists have not only more professional opportunities but also more responsibilities within this new drug paradigm. [11] REFERENCES 1. Bond C. The OTC Pharmaceutical Market - Policy and Practice. Pharmaceutical Monitoring Journal, XII, 2011; 6(64): 5. 2. Bunney RG (2005) Switching prescription drugs to over the counter: Over the counter licensing is linked to direct to consumer advertising, BMJ, 2005; 330: 906. 3. Cohen JP, Paquette C, Cairns CP (2005) Switching prescription drugs to over the counter, BMJ 2005 330:39-41) 4. Duerden M and Walley T (2005) Direct to consumer marketing: Switch to over the counter can become indirect advertising directly to consumers, BMJ, 2005; 330: 906) 5. RX-to-OTC Switching. Market Analysis, Data & Figures, Press Release, www.the- infoshop.com/press/fe14207_en.shtml, Navigant Consulting, Inc., Accessed November 2014. 6. Major S, Vincze Z, Self-medication in Hungary, from the Perspective. 7. http://www.arbilis.com/periodicals.php?magid, Danchev N, Nikolova I, Petkova V, Benbassat N, OTC medicines: Bulgarian and World Experience. Science Pharmacology Journal, No. 1/2011. 8. http://ec.europa.eu/health/ph_overview/Documents/strategy_wp_en.pdf, WHITE PAPER Together for Health: A Strategic Approach for the EU 2008-2013 9. http://lex.bg/laws/ldoc/2135549536 10. http://www.medicinenet.com/script/main/art.asp?articlekey=79398, Stoppler, M. Alli (orlistat) Weight Loss Drug Available OTC, 11. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3411219/, Barlas, St. FDA Considers a New Paradigm for Over-the-Counter Medications, P&T, May 2012; v 37(5).