Mandate
To determine whether implanted PIP breast implants could give reasons for concern from the health point of view when compared with state of the art implants, taking into account their structure, composition and detected defects (e.g. low quality silicon, single envelopE instead of double envelopE) and the risk of rupture and oozing they may present;
General response
The data available presently on PIP silicone breast implants is necessarily limited at this stage, as the PIP manufacturer did no clinincal or epidemiologic research. So, the evidence on failure rates and complications related to PIP silicone breast implants are based on case reports. The large number of breast implant studies conducted to date and reported in the literature did not for the most part examine data by manufacturer. The focus of attention in this initial response is on the following aspects:
− Physical and chemical properties of the PIP silicone breast implants, where available;
− Findings of the effects of PIP implant contents in the required animal tests, where available;
− Reports of incidents of PIP implant failures, where available.
Physical and chemical properties: The more recent PIP silicone breast implants, in common with those of other manufacturers, comprise a single envelope/shell. The implants consist of an outer shell filled with a gel. In common with those of most other manufacturers, they were manufactured using the polymer polydimethylsiloxane, also known as silicone. The chemical reaction resulting in gel formation must be controlled because it governs the degree of crosslinking. The more variable this reaction is, the greater the variation of the content of volatile and/or low molecular mass components in the implant (gel and shell) is likely to be. Use of industrial grade silicone along with a lesser control of the cross linking process appears to be associated with a higher content of low molecular weight components. As a consequence of the migration of these components it is reasonable to conclude that the shell might be weakened and that components could leak into the surrounding tissue.
Tests conducted by the French Authorities on the physical integrity of a sample of PIP silicone breast implants indicated weaknesses in PIP shells not found in other commercially available implant. Findings in Toxicity tests: To date few studies aimed at evaluating the toxicity of the contents of PIP silicone implants so far have been conducted using tests specified for assessing the safety of Class III medical devices. The tests that were performed are designed to assess cytotoxicity, irritancy and genotoxicity. Medical grade silicone gels give negative results in these tests. In the case of the contents of the PIP silicone implants, tests for cytotoxicity and genotoxicity were negative.
However, an in vivo test for irritancy was positive. This indicates the potential for inducing local irritancy when the silicone gel is released form the implant. The extent will depend on the amount released, the duration of exposure and other local conditions. The implications of this positive result for irritancy for women with PIP silicone implants are currently uncertain and require further investigation.
Incident reports: There are cases reported suggesting that PIP silicone breast implants may have a higher failure rate in the first few years after implantation compared with those from other breast implant manufacturers. There are also a few case reports that ruptured PIP silicone implants may be associated with a higher incidence of swollen and painful lymph nodes.
The limited and selective clinical data and the absence of epidemiologic data on PIP silicone breast implants provide insufficient evidence to warrant a conclusion that women with PIP silicone breast implants have a greater risk to their health than women with breast implants from other manufacturers. However, studies among women with 58 standard-quality implants (including patient with ruptured implants) have shown that the risks of cancer and connective tissue disease are not increased among women with such implants. The limited available information, allied with the findings from tests of the physical and chemical properties of the shell and silicone and of the in vivo irritancy test, raises some concerns about the safety of PIP silicone breast implants as the possibility of health effects cannot be ruled out.
The SCENIHR is asked to identify the generic risks and benefits of various actions that might be taken to address these concerns. As noted above there are obvious difficulties in providing scientifically based advice because:
− Over time, regardless of the manufacturer there will be an increased failure rate of the implants;
− For many women it is uncertain whether their breast implant is a PIP manufactured implant;
− Simple clinical examination alone is unlikely to identify those patients with a leaking/ruptured implant;
− Many such implants have been inserted by surgeons who are not qualified in plastic surgery.
This might be a source of higher failure rates among their patients. It is important to identify as far as possible high risk categories of patients based on the identified risk factors noted above. Manufacturer, duration of implant, patient symptoms and psychological state have been identified. However these criteria are insufficiently established at present and a patient by patient approach is therefore required. It is important that the risks identified in this opinion are considered in the light of the risks involved in unnecessary explantation.
Question 1A: What is the global reported incident rate associated with PIP breast implants?
Currently available data do not allow a reliable estimate.
Question 1B: How does this compare with the global reported incident rate for other breast implants?
Currently available data do not allow a reliable estimate.
Question 1C: What percentage of this global reported incident rate is associated with rupture of PIP breast implants?
Currently available data do not allow a reliable estimate.
Question 1D: What percentage of this global reported incident rate for PIP implants is associated with other adverse effects on health and what are these adverse health effects?
Currently available data do not allow a reliable estimate.
Question 1E: Is there evidence that PIP breast implants are more difficult to explant, before or after rupture, in comparison with other breast implants?
The evidence although limited indicates that there is no difference provided the device and fibrous capsule is intact. If the device has ruptured and particularly if it has caused substantial inflammation then the removal is more difficult. Thus a higher rupture rate of an implant made by a particular manufacturer would be problematic.
Question 1F: Is there evidence of any increased report of lymph node complications associated with the PIP breast implants?
There is evidence from an animal study of increase in irritancy. In contrast medical grade silicone gel does not cause detectable irritation in animal models. There is limited case history data in PIP explant patients indicating a possible increase in lymph node swelling and painful lymph nodes. It should be noted, however, that there may be overreporting of such conditions. This may arise due to reporting and ascertainment biases as a consequence of the widespread concern generated by media reporting on PIP silicone breast implants when compared to reporting of these conditions in non-PIP implant patients.
Question2
In case reasons for concern related to implanted PIP breast implants are identified, to make a risk/benefit analysis of explantation. The evidence to date, indicating a health risk for women with PIP silicone breast implants, is not strong. However there is some concern regarding an increased inflammation from ruptured PIP silicone breast implants. It is not possible to make a general risk benefit statement at this time. Rather, for the time being, the risk benefit assessment needs to be based on a patient by patient basis by the aesthetic surgeon, bearing in mind the time since the implantation and the psychological state of the patient.
FRENCH PIP IMPLANTS SEQUENTIAL NEWS in 2012
16th March
Around 7000 women in the UK have been fitted with banned PIP breast implants prior to 2001. Therefore all women who have previously had PIP implants should consult with a specialist. The MHRA and the French regulator have now said that PIP implants made before 2001 may also contain the unauthorised non-medical grade silicon.
15th March
The MHRA releases an extension of the device alert relating to PIP implants to include and “pre-2001 PIP implants”(copy here)
7th February
Sir Bruce Keogh, Medical Director of the NHS has told MPs that there is “significant uncertainty” to women with PIP implants. It’s that level of uncertainty which creates the anxiety with relation to the ‘ticking timebomb’.”We are left with uncertainty around the potential damage from the silicone itself.”
6th February
Blood silicone levels are not useful tests to detect implant rupture. There is no correlation between serum silicone levels and the status of the implant.
2nd February
Special Reuters Report on PIP Implants
1st February
The expert report from the European Union has just been published. This is the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) report on “The Safety of PIP Silicone Breast Implants“
30th January 2012
Jean-Claude Mas is reported in the Telegraph newspaper to have told investigators that he used fake business data to fool health inspectors. The industrial gel was in 75 percent of PIP breast implants. This saved the company about one million euros per year.
27th January 2012
Jean-Claude Mas is released on €100,000 bail. He is not allowed to leave France.
26th January 2012
Jean-Claude Mas has finally been arrested today in Marseille. French police will now hold him for up to 48-before deciding on charges, which could include involuntary manslaughter.
22nd January 2012
Numerous protestors have staged demonstrations outside both the Harley Medical Group and the Transform Medical clinics in Birmingham.
20th January 2012
Proposals are being discussed to develop a future model that will protect patients against companies that go into administration leaving them with no recourse if their implants have ruptured except the NHS. Such a scheme would involve the manufacturers having to be registered with an insurance protection scheme, akin to the existing holiday insurance protection, ABTA. The ABTA scheme of financial protection provides a course of redress if something goes wrong and they raisethe standards in the industry and help to ensure that the public get a fair deal. Such a scheme in relation to breast augmentation makes a lot of sense. During the PIP implant scandal we have seen Harley Medical, Transform and Surgicaire refuse to remove and replace the faulty implants, and numerous other small clinics simply close down perhaps to avoid any liability. In addition most specialist breast surgeons favour the reintroduction of a breast implant register (a national register did exist between 1993 and 2006, but it was funded by the Department of Health, not compulsory, and was withdrawn). Such a register would need to be compulsory if it were to enable accurate data collection. These two proposals would be excellent news for patients
19th January 2012
Link to the Yorkshire Evening Post news story:http://www.yorkshireeveningpost.co.uk/news/latest-news/central-leeds/leeds_rush_for_ops_to_swap_pip_breast_implants_1_4155390
17th January 2012
Mr Turton is interviewed by Treatment Advisor: http://www.treatmentadviser.com/before-after-pictures-categories/pip-implants
16th January 2012
Mr Turton has opened a specialist dedicated PIP breast clinic at the Leeds Nuffield Hosptial to deal with demand from patients with the PIP implants. This clinic is exclusively for patients with PIP implants who had breast augmentation performed at other hospitals who require assessment or redo surgery.
15th January 2012
Adverts appeared throughout the National Press, placed by the UK Governement, advising women about faulty French PIP implants. In addition, a large number of angry women protesters marched in protest to the Transform Medical offices on Cavendish Street in London. The Health Minister Andrew Lansley, confirmed that the NHS would support all women who have the implants, but would not be replacing implants that were placed for non-clinical reasons. But if there was agreement with the surgeon, the PIP implants would be removed for free.
14th January 2012
Mr Turton was interviewed live on BBC New 24 to give his reaction to the PIP implant scandal. He explained that women had a right to be angry and that the private clinics that had refused to replace them for free had left patients in an horrendous situation. This combined with different levels of support in different countries was a bitter pill to swallow. He explained his expert findings in the patients he has helped, and how this differed to normal breast implants.
13th January 2012
PIP implants were rebranded as Rofil-Medro or M implants. Some UK women had cheap surgery abroad in Poland, Belgium and Czechoslovakia. They may undergone augmentation with PIP implants by another name and hence be unaware of it.
12th January 2012
ITV reported on the French Silicone Implant story in a documentary at 17:30. They followed several patients who had faulty implants placed by the Harley Medical Group, the company who have continued to refuse to replace them. Chris Choi travelled with one patient Annie Winner, to meet another patient who was undergoing surgery to remove and replace the faulty implants. Kate Ward had the faulty implants placed by Harley Medical in 2005, and she was worried about the unknown health risks of doing nothing. Even though she was symptom free she wanted the implants to be removed and replaced with a known high quality implant. She told ITV that she travelled to see Mr Turton at the Leeds Nuffield to ensure she had expert care in the highest quality and safest environment. Kate had her implants removed without difficulty by Mr Turton; he found both implants to be bleeding silicone. This means no rupture was present and only a small volume of silicone had escaped through the intact implant shell. Kate’s breast showed signs of mild inflammation on the inside and once the bad silicone had been removed she underwent redo- augmentation by Mr Turton using Allergan’s breast implants. Kate was interviewed again just 2-hours after surgery by ITV and she explained her great sense of relief. The ITV team has tracked 100 women caught up in this story. It is an enlightening documentary into the PIP implant scandal.
11th January 2012
Harley Medical went on BBC news to refuse to carry out free implant exchange, placing the blame squarely on the UK regulator. Kate Ward also went on BBC news to tell her story of the PIP implants placed by Harley Medical Group 5 years ago. She was refused exchange surgery by Harley Medical and came to Mr Turton at the Leeds Nuffield for exchange of PIP implants to the FDA approved Allergan implants. Just 24-hours after surgery she was live on the main BBC evening news discussing the findings. Mr Turton was also interviewed live and he explained how she had marked silicone bleed- a leakage of the the industrial silicone through the implant’s supposed protective shell. Kate’s breast tissue was otherwise intact and Mr Turton was able to rectify her problem in what was a straightforward operation. Mr Turton reiterated that he felt the private clinics who placed these French PIP implants in the first place had a moral duty to provide the after care and support. He felt that should offer free implant exchange where requested and desired by the Specialist. The Dutch Government becomes the latest to support free exchange of implants for the PIP victims.
10th January 2012
The Welsh Government has announced today that it will offer free of charge redo breast augmentation to all women who received the banned PIP implants, including those who were treated privately. This will be available on the NHS in Wales. It will only apply to women who can prove they have exhausted all options of recovering such surgery from the original private provider. It will also only be available to Welsh women who have a GP within a Welsh post-code. Approximately 2000 women in Wales are thought to have been augmented with the French PIP implants.
8 January 2012
Harley Medical have reported that they were responsible for placing the faulty French PIP implants into 13,900 women up until as recently as March 2010.
6th January 2012
From 2005 the manufacturing of the PIP implant changed. The outer shell was altered by the manufacturer removing a layer and this may have caused an increase in the fragility of the implants.
Breaking News:
Today the UK Government has reiterated that it has found no evidence to recommend the routine removal of all PIP implants. If the PIP implants have been placed by the NHS as part of reconstructive breast surgery, the implants can be replaced on the NHS after consultation with your specialist. However, the UK Government is not offering this to patients who had private cosmetic breast surgery with PIP implants. The expert review also stated that they can not be confident that PIP did not change the silicone in the implants, so they cannot rule out the possibility that some are toxic.
The NHS will support removal of PIP implants if originally inserted by the NHS, and that it is justified by an assessment of clinical need, risk or the impact of unresolved concerns, and that the woman with her doctor decides that it is right to do so. The Department of Health has issued a statement that it expected private firms to follow the NHS offer on removal and replacement of the implants among those women with anxieties and that they believe private providers have a duty to take steps to provide appropriate after-care to patients they have treated. The private providers have legal obligations to their patients. The NHS will offer a package of care for its patients, and the Department of Health expect the private sector to do the same.
URGENT UPDATE ON PIP IMPLANTS: STATEMENT BY ANDREW LANSLEY, SECRETARY OF STATE
The following statement has been released on Friday 6th January 2012
The interim report of the expert group brought together in relation to breast implants made by PIP has been released today.
A statement has been released from the Department of Health and Andrew Lansley
Mr Dick Rainsbury, President of the Association of Breast Surgery has made the following statement:
‘Today’s announcement on the management of patients with PIP breast implants is to be welcomed. As the ABS representative on the Expert Advisory Group to the MHRA and the DoH, I strongly supported the indications for implant removal based on a lack of evidence of safety, alongside BAPRAS and BAAPS. These indications include symptomatic/asymptomatic rupture, or sufficient patient concern about the substandard nature of these devices, in the absence of evidence of rupture (‘preventative’ removal).
Around 95% of these implants (involving circa 40K women) have been used for augmentation, with an estimated 3K used during reconstruction. Where patients elect implant removal, the NHS will fund removal/exchange following previous reconstruction in the NHS. Private Providers will be expected to play their part in explantation/exchange, but for women unable to access this service, the NHS will undertake to carry out explantation only.
Clearly, this decision has the potential for a major impact on our referrals and workload. I have made very clear representations to the group about the potential for derailing CWTs, recommending that patients are referred outwith the 2WW.
Supported by BAPRAS and BAAPS, we are recommending the following ‘routes of referral:
1. Patients with new breast symptoms and/or clinical signs are referred to NHS breast surgeons
2. Asymptomatic patients are referred back to the private provider
3. Asymptomatic patients unable to access the private provider are referred to NHS plastic surgeons
The Expert Group will now carry out a fundamental review of the systems in place for the reporting and regulation of implant surgery, and we will continue to represent the interests of our patients and our members’.
A press release has also been issued by the Royal College of Surgeons of England, along with the ABS, BAAPS and BAPRAS
This section below is the Sir Bruce Keogh Report (NHS Medical Director) 6th January 2012
It is the report of the expert group convened under the chairmanship of Sir Bruce Keogh to review policy in relation to French PIP breast implants
Introduction
This is the interim report of the expert group convened under my chairmanship to review policy in relation to breast implants from the French company Poly Implant Prostheses (PIP). The members of the group are listed at Annex A.
The overriding concern of the group is the safety and compassionate treatment of women with PIP breast implants. In our report we:
- review the available data on the health risks from PIP implants
- conclude that there is no clear evidence at present that patients with a PIP implant are at greater risk of harm than those with other implants, and we therefore agree with the MHRA advice that there is no specific safety concern identified which requires a recommendation of routine removal of PIP implants
- recognise the anxiety of many women who received PIP implants in good faith on the assumption that they were manufactured in accordance with EC standards
- commend and endorse the decision of DH ministers that, where women have received a PIP implant as part of NHS treatment, they will be contacted to inform them that they have a PIP implant and to provide relevant information and advice; and will be offered further procedures subject to clinical need and taking full account of the wishes and concerns of the patient
- expect private sector providers to take similar action
- the available evidence is subject to considerable uncertainty and therefore we recommend the collection of additional information which will enable the group reach a more informed view.
A summary of our provisional conclusions and recommendations for further work is at Annex B.
3. The group will reconvene in about 4 weeks’ time to review any new evidence and to consider whether this advice needs to be amended.
Background
4. Breast implants are regulated under a European Union Medical Device Directive . See Annex C for further details.
5. PIP received a CE mark for their silicone gel breast implants in 2000 via the German Notified Body TUV Rheinland and started exports to the UK in that year. Between 2001 and 2009 about 80,000 implants (representing some 40,000 women) were sold in the UK and, to date, some 478 adverse incident reports have been received. This rate of incidents was not considered to be significantly different from that for other brands of implant.
6. From about 2006 onwards, concerns began to emerge among cosmetic surgeons about the performance of PIP implants . In 2008 the MRHA noted an increase in the number of reports of ruptures and raised concerns with the manufacturer and the notified body, but this was understood to be the result of an increase in sales and improvements in the manufacturer’s reporting criteria. The MHRA raised further concerns in 2009. In March 2010 the French regulator Agence Francaise de Securite Sanitaire des Produits de Sante (AFSSAPS), discovered that the manufacturer had been using industrial grade silicone instead of the medical grade specified for the CE mark. AFSSAPS revoked the CE mark and the MHRA promptly issued a medical device alert to all UK clinicians and cosmetic surgery providers, asking them to cease using the implants.
7. Toxicology tests on samples of filler material in both France and the UK suggested that there was no significant health risk to women who had already received the implants.
8. On 20 December 2011, following a large increase in the number of reported ruptures and concerns over a possible cancer risk, AFSSAPS wrote to European competent authorities (ie regulatory bodies) alerting them to the new data. On 23 December the French Ministry for Health announced that it was advising women, as a precautionary measure, to consider explantation . After consideration of the evidence reported within the UK and consultation with other countries known to have used PIP implants, the MHRA issued interim advice. This suggested that, on the available data, women in the UK should not be advised to seek explantation in the absence of clinical symptoms .
9. Our immediate task was to review the available data, including further information from the French authorities and to consider whether there is a need to revise the current advice in the UK.
Issues considered by the group: (i) Safety Issues
10. The first set of issues considered by the group was whether, on the balance of evidence, women with PIP implants who have no current symptoms should be advised as a precautionary measure to seek an explantation, or should be advised (as at present) to wait for the possible development of symptoms that might indicate a rupture. This involves balancing the risks associated with PIP implants, including the risks resulting from possible rupture of the implant, against the risks of undertaking explantation surgery earlier than might otherwise be necessary.
The cancer risk
11. The expert group consider that, on the available data, there is no evidence that PIP implants are associated with a higher risk of breast cancer than other silicone gel implants. This is in line with the advice of the French National Institute for Cancer (INCA) that “the number of breast cancers seen in women with PIP implants is less than the levels for the general population”.
12. In February 2011 MHRA issued a safety alert on the possible, but very low risk, link to anaplastic large cell lymphoma of silicone gel implants in general. No cases have been recorded in the UK.
The significance of the use of industrial grade silicone rather than medical grade silicone in implants
13. The composition of silicone used by PIP during the period of manufacture is not certain. However, it is clear that the material used cannot be guaranteed to have been submitted to the same rigorous toxicological testing as is required to meet the essential requirements of the Directive. We can draw no conclusions from this about its quality in the context of breast implants.
Signs and symptoms of rupture
14. Guidance on signs and symptoms of rupture has been prepared as part of our guidance to clinicians – see paragraph 29 below.
Health consequences of a rupture
15. Breast implant ruptures, or leaks of gel, may result in inflammation of the surrounding tissues. The tissue responses may be reflected by lumpiness, swelling and discomfort in the local or regional tissues. Other signs of rupture include changes in the shape, consistency and symmetry of the breast. According to the AFSSAPS data as at 28 December , some 495 women with PIP implants have suffered an inflammatory reaction, or about 1.7% of the estimated 30,000 women in France with such implants. We are not aware of any available estimates for other implants against which we could compare this figure.
16. Since the 1970 breast implants have evolved through a number of evolutionary stages/ generations. Contemporary implants contain a cohesive gel in which the polymer is cross linked and the gel “form stable”. This cohesive characteristic of the gel reduces the risks associated with rupture as the gel is “held together” and is less likely to migrate into the breast tissues or the lymphatic system. It appears that the gel within PIP implant is significantly less cohesive than other contemporary implants. The implications of this include a greater tendency to interface with the local tissue and a greater potential to generate an inflammatory response. There is also some data supporting an increased risk of in vivo transdermal irritation from PIP implants. Members of the UK professional bodies for cosmetic surgery for cosmetic surgery report anecdotal evidence that, when a PIP implant ruptures, silicone gel is more widely dispersed in surrounding tissue and the resulting explantation is more difficult and more involved. This could result in a more prolonged hospital stay with additional risks. Two case studies have been published although it appears in these two cases that there were no long-term effects on health.
17. Laboratory tests on samples from PIP implants, both in the UK and in France, have shown no significant evidence of mutagenicity (potential to cause cancerous mutations). One test reported from France found that gel from PIP implants was more likely to cause an inflammatory reaction in rodents than standard, medical grade, silicone gel.
The risk of ruptures
18. Much attention so far has been given to the issue of rupture in breast implants. The cumulative risk of rupture of a breast implant increases progressively over time. An analysis published by the FDA showed that the rupture rate for the Allergan implant is 0.5% after 2 years, rising to 10.1% (cumulative) after 10 years. For Mentor implants, the post implantation failure rate at 8 years was 13.6% (cumulative). It follows that quoting a “rate of rupture” for an implant, without specifying the time since the original implant, is unhelpful and potentially misleading.
19. There is no data on PIP implants of comparable quality to the FDA study mentioned above. We invited the sector to send us recent comparative data on PIP and other silicone breast implants (Annex D) and have concluded we can place no reliance upon these figures, which for non PIP implants are inconsistent with the FDA study by a fivefold factor. More work clearly needs to be undertaken by the sector to ensure that more reliable data can be produced in future.
20. There are a number of other difficulties in comparing risks of rupture for PIP and other implants:
i. much of the available information is subject to potential under-reporting. Although the manufacturers are required to report all serious adverse events (including rupture), notifications from providers in the UK to the regulator are voluntary. Cosmetic surgery providers will only be aware of problems if patients come back to them for follow-up, and many patients may seek advice elsewhere (including the NHS). We believe that under-reporting seriously affects the validity of current PIP data and some comparative data about similar implants;
ii. it is not clear whether all PIP implants have been affected by the use of substandard silicone to the same extent. For instance, it has been suggested that PIP continued to use medical-grade silicone in the implants supplied to Australia, so the apparently reassuring data from the Australian regulator may not be a valid guide to risks in the UK;
iii. some ruptures – perhaps as many as 2 in 3 – do not result in clinical signs or symptoms, and can only be detected by scanning or by explantation (removal). Ruptures reported after explantation, such as the recent data on PIP implants from the French regulators, cannot therefore be compared directly with data from routine reporting on other implants.
21. On the currently available information, the group considers that the statistical evidence on the rate of ruptures for PIP implants compared with other implants is incomplete and this risk cannot be assessed accurately. For this reason it is unable to come to any view on comparative rupture rates. We attach the data received at Annex D.
Risks associated with explantation
22. As noted above, a full assessment of the safety aspects of PIP implants involves balancing the risks associated with leaving the implants in place against the risks of undertaking explantation surgery earlier than might otherwise be necessary. In this context, it is worth bearing in mind that all breast implants have a finite life – data from the FDA suggest that 1 in 5 cosmetic breast implants, and 1 in 2 breast implants following reconstruction surgery, are explanted or replaced within 10 years.
23. Women who receive breast implants are, in general, a very healthy sector of the population. Advice from the Royal College of Anaesthetists is that the risk of anaesthetic mortality in healthy adults is of the order of 1 in 100,000 to 1 in 250,000 . If all 40,000 women in the UK with PIP implants had explantation surgery, the estimated excess deaths would therefore be about 0.4 or less. The available literature confirms the view of members of the expert group that there are no significant risks of morbidity associated with explantation per se over and above the risk of the original operation.
Issues considered by the group: (ii) practical clinical issues
24. Whatever the objective evidence on safety, many women with PIP implants will understandably be very worried about the possible implications for their health. In itself, this anxiety is a form of health risk and must be addressed with understanding and compassion by those responsible for their treatment.
25. Women who received PIP implants will have been informed about the risks associated with breast implants in general, in line with current best practice guidance . They will however have assumed, in good faith, that the material to be used in the implants was medical grade silicone, in line with the CE mark. Now that we know that a substantial proportion of PIP implants have used industrial grade silicone, we believe that there is a duty of care on the part of the providers of surgery to offer these women whatever is reasonably needed to reassure them that they will not suffer long-term health effects as a result of the deception by PIP.
26. A minority of women with PIP implants have received these implants as a result of reconstruction surgery carried out by the NHS, eg following surgery for breast cancer. Ministers have already made clear that:
• All women who have received a PIP implant from the NHS will be contacted to inform them that they have a PIP implant and to provide relevant information and advice. If in the meantime NHS patients seek information about the make of their implant then this will be provided free of charge;
• Women who wish to will able to seek a consultation with their GP, or with the surgical team who carried out the original implant, to seek clinical advice on the best way forward;
• If the woman chooses, this could include a non-urgent examination by imaging to see if there is any evidence that the implant has ruptured;
• The NHS will support removal of PIP implants if, informed by an assessment of clinical need, risk and the impact of unresolved concerns, a woman with her doctor decides that it is right to do so. The NHS will replace the implants if the original operation was done by the NHS.
27. The group endorses this offer. It expects providers in the private sector to take similar steps (as one major provider, the Nuffield Hospital Group, has already signalled) .
28. Clinicians, in advising women, should make clear that (on current evidence) explantation would be a precautionary measure rather than because of a definite risk to health.
29. Guidance to GPs and surgeons, on the clinical indications that an urgent referral might be needed in relation to concerns about any implant of this type, is attached at Annex E.
30. Where patients find that their private sector provider is no longer in practice, the group considers that in the event of their approaching the NHS and where the clinical need has been identified, only non-urgent removal – rather than removal and replacement – should be offered.
Issues considered by the group: (iii) equalities implications
31. We have considered whether the public sector equality duty in s149 of the Equality Act 2010 is relevant to our deliberations, and whether anyone sharing a ‘protected characteristic’ listed under that legislation will be subject to special disadvantage. Protected characteristics include age, disability, gender, gender reassignment status, marriage and civil partnership status, pregnancy and maternity status, race, religion or belief, and sexual orientations.
32. We have concluded that there is no evidence to support a conclusion that anyone sharing a protected characteristic as described above is subject to special disadvantage.
Further work
33. Further information is needed in particular on the risks associated with the rupture of PIP implants and the resulting inflammatory reaction. The group will be reconvened to review these issues and to consider whether any change is needed to our advice.
34. As a second stage, the Secretary of State has asked me to prepare a report on the lessons learned from this issue including:
i current arrangements for the monitoring of the safety of breast implants and other implantable devices, including the proposal from professional organisations to re-establish the breast implant registry which the department discontinued in 2007;
ii the regulation and governance of the cosmetic surgery industry.
35. I propose that this further review should be undertaken by a reconstituted review group, including the organisations represented in this expert group with additional membership from the independent healthcare industry, the CQC and the NPSA.
Sir Bruce Keogh
NHS Medical Director
January 6 2012
Provisional Conclusions and Recommendations for Further Work
The expert group:
• Considers, on the available data, that there is no evidence that PIP implants are associated with a higher risk of breast cancer than other silicone gel implants.
• Finds it clear that the composition of silicone used by PIP during the period of manufacture cannot be guaranteed to have been submitted to the same, rigorous toxicological testing as is required to meet the essential requirements of the Directive. We can draw no conclusions from this about its quality in the context of breast implants.
• Agrees that more work clearly needs to be undertaken by the sector to ensure that more reliable data on silicon breast implants can be produced in future.
• Considers that the statistical evidence on the rate of ruptures for PIP implants compared with other implants is incomplete and this risk cannot be assessed accurately. For this reason it is unable to come to any view on comparative rupture rates.
• Believes that there is a duty of care on the part of the providers of surgery to offer these women whatever is reasonably needed to reassure them that they will not suffer long-term health effects as a result of the deception by PIP.
• Endorses the offer made by Ministers to women with PIP implants who have received these implants as a result of reconstruction surgery carried out by the NHS, eg following surgery for breast cancer.
• Expects providers in the private sector to take similar steps.
• Considers that in the event of private sector patients approaching the NHS and where the clinical need has been identified, only non-urgent removal, rather than removal and replacement should be offered.
• Has concluded that there is no evidence to support a conclusion that anyone sharing a protected characteristic as described in the Equalities Act 2010 is subject to special disadvantage.
• The group will be reconvened after further information is received to review the risks associated with the rupture of PIP implants and the resulting inflammatory reaction and to consider whether any change is needed to our advice.
In addition, a further review will be undertaken by a reconstituted review group, including the organisations represented in this expert group with additional membership from the independent healthcare industry, the CQC and the NPSA, to consider:
• current arrangements for the monitoring of the safety of breast implants and other implantable devices, including the proposal from professional organisations to re-establish the breast implant registry which the department discontinued in 2007; and
• the regulation and governance of the cosmetic surgery industry.
CLINICAL GUIDANCE FOR GPs AND SURGEONS
Patients: Any patient with breast implants is advised to check the details of their implant with their surgeon or clinic.
GPs consulted by patients with PIP implants should explore the patient symptoms and examine the breast and locoregional lymph nodes.
Patients with local signs and symptoms should be referred for a specialist opinion.
Signs will include
• Lumpiness of the breast
• Lumpiness/ swelling of the regional lymph nodes
• Change in shape of the breast
• Deflation of the breast
• Redness
• Tenderness of the breast
• Swelling of the breast
Symptoms may include
• Pain
• Hyperaesthesia
Guidance for GPs for NHS specialist referrals
Patients with PIP implants who experience lumpiness within the breast and lymph nodes : In cases where there is concern regarding the nature of the lumpiness, referral should be made to a rapid access breast service. In cases where the practitioner is happy that the lumps are associated with the implant or gel, referral should be made to the regional reconstructive breast surgery department
Patients with changes in shape or feel of the breast, for instance discomfort, deflation or asymmetry should be referred to their regional breast reconstructive unit. These patients do not require fast track referral.
Surgeons: Surgeons and hospital specialists reviewing patients with PIP implants should carefully assess the patient for the possibility of rupture or leak. Those patients who have evidence of implant rupture should be advised regarding the implications of implant removal/ exchange. If it is felt that the risk benefit ratio favours explantation/ exchange then this procedure should be advised. For NHS patients the patient may be offered re-implantation. For patients from the private sector who have been unable to secure help from their original provider, the NHS will offer implant removal where it is felt to be clinically appropriate, but no re-implantation will be offered.
This guidance may change after consultation with relevant parties.
Guidance for GP referrals for private patients
General Practitioners may be approached by patients who underwent their surgery in the private sector. These patients should be advised to contact their original provider. It is expected by the expert group and the professional bodies represented on it that these providers will offer the same service as the NHS without cost to the patient.
Ongoing review
Where a patient decides, after consultation with her GP or specialist, not to have an explantation, she should be followed up on an annual basis. This review would normally be carried out by the GP (for NHS patients) or by the clinic which carried out the original implant (for private patients).
ANNEX C: REGULATION OF MEDICAL DEVICES
There are over 90,000 types of medical device on the market in the UK. These are regulated under the provisions of the European Medical Devices Directives.
Medical device regulation differs substantially from the regulation of medicines. The safety of medical devices is assessed by independent third party organisations. The licensing of medicines is undertaken by state regulators such as the Medicines and Healthcare Products Regulatory Agency (MHRA).
All medical devices such as breast implants require a CE mark of conformity
before they can be marketed in Europe. For all but the lowest risk devices the CE mark must be authorised through assessment by an independent third-party organisation, known as a notified body. There are over 80 of these notified bodies across Europe.
Each notified body is appointed and audited by the Competent Authority (regulatory authority) in their respective country. A manufacturer can select any notified body across Europe irrespective of location, provided that their field of expertise covers the device being considered. Once a CE mark is applied the medical device can be sold in all EU countries without further controls.
The regulations are implemented by a Competent Authority in each member state. In the UK this is the MHRA. The role of the Competent Authority is to implement the provisions of the directives, to appoint and control notified bodies and to monitor and investigate adverse events occurring in their country. In the UK this involves investigating both mandatory serious adverse event reports from manufacturers and adverse events reported voluntarily by healthcare professionals and members of the public. As a result of these investigations MHRA will take further action as appropriate including recalling faulty products (safeguard action) and offering advice to the health service through Medical Device Alerts.
ANNEX D: PIP IMPLANT DATA SUPPLIED BY UK COSMETIC SURGERY PROVIDERS TO MHRA BY 5PM ON 5 JANUARY 2012
For cautions on the interpretation of the data, see paragraphs 18 – 21 in the report.
The following tables set out the data returned by providers to the MHRA before 5pm GST on 5 January 2012. Further data received will be taken into account
BMI Healthcare
Date of first implantation 2002
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 230 1
2nd year 192 1
3rd year 166 0
4th year 381 0
5th year 141 0
6th year 88 1
7th year 44 1
8th year 58 6
9th year 11 4
10th year 0 0
County Durham and Darlington NHS Foundation Trust
Date of first implantation
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year 72
2nd year 94
3rd year 121
4th year 118
5th year 110
6th year 35
7th year 0
8th year 0
9th year 0
10th year 2011 0
Harley Medical Group
Date of first implantation Jan-00
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 11837 4
2nd year 11160 28
3rd year 8838 72
4th year 6010 79
5th year 3875 60
6th year 2024 53
7th year
8th year
9th year
10th year
IHAS – Court House Clinics
Date of first implantation 20/01/2004
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 3
2nd year 12 1
3rd year 20
4th year 20
5th year 27 1
6th year 22
7th year 37
8th year
9th year
10th year
IHAS – Make Yourself Amazing
Date of first implantation 29/07/2007
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 0 0
2nd year 0 0
3rd year 1 0
4th year 3 0
5th year 44 4
6th year 0 0
7th year 0 0
8th year 0 0
9th year 0 0
10th year 0 0
IHAS- Aspen
Date of first implantation 2000
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 36 0
2nd year 40 0
3rd year 43 0
4th year 11 0
5th year 4 0
6th year 3 0
7th year 1 0
8th year 3 0
9th year 2 0
10th year 0 0
IHAS – Bridgewater Hospital
Date of first implantation 17.05.2007
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 6
2nd year 2
3rd year
4th year
5th year
6th year
7th year
8th year
9th year
10th year
Linia Cosmetic Surgery
Date of first implantation 2.04.2003
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 0 0
2nd year 0 0
3rd year 21 3
4th year 147 6
5th year 148 1
6th year 150 8
7th year 104 1
8th year 277 2
9th year 0 0
10th year 0 0
Mid-Cheshire Hospitals NHS Foundation Trust
Date of first implantation
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year
2nd year
3rd year 1
4th year
5th year
6th year
7th year
8th year
9th year
10th year
Mid-Essex Hospital Services NHS Trust
Date of first implantation
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year 0
2nd year 0
3rd year 0
4th year 0
5th year 0
6th year 0
7th year 0
8th year 0
9th year 0
10th year 0
11th year 0 1
New Victoria Hospital
Date of first implantation 1998
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 5 0
2nd year 5 0
3rd year 7 0
4th year 14 0
5th year 22 0
6th year 2 0
7th year 0 0
8th year 0 0
9th year 0 0
10th year 1 0
NHS Herefordshire West Mercia
Date of first implantation
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year
2nd year
3rd year 1
4th year
5th year
6th year
7th year
8th year
9th year
10th year
North Tees and Hartlepool NHS Foundation Trust
Date of first implantation 2000
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year 2 1
2nd year
3rd year
4th year
5th year 1
6th year
7th year 11
8th year
9th year
10th year
11th year 3
12th year 2
Royal Cornwall Hospitals Trust
Date of first implantation
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year
2nd year
3rd year 1
4th year 1
5th year 1
6th year
7th year
8th year
9th year
10th year
Spire Healthcare
Date of first implantation 1999
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 1 0
2nd year 18 1
3rd year 108 1
4th year 113 1
5th year 158 2
6th year 278 10
7th year 308 15
8th year 273 4
9th year 131 4
10th year 32 1
The Christie NHS Foundation Trust
Date of first implantation N/A
Post-operative year Number of Implants How many women have had explants due to rupture during this post implant year?
1st year 0 0
2nd year 0 0
3rd year 0 0
4th year 0 0
5th year 0 0
6th year 0 0
7th year 0 0
8th year 0 0
9th year 0 Not Determined
10th year 0 Not Determined
Transform
Date of first implantation 2004
Year of post-operative experience Number of women with this post operative experience How many women have had explants due to rupture during this post implant year?
1st year 2939 2
2nd year 1232 1
3rd year 52 6
4th year 21 17
5th year 27 17
6th year 5 42
7th year 5 45
8th year 17
9th year 0
10th year 0 0
University Hospitals Coventry and Warwickshire
Date of first implantation Never
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year
2nd year
3rd year
4th year
5th year
6th year
7th year 1
8th year
9th year
10th year
University Hospital of South Manchester
Date of first implantation 2000
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year 1 0
2nd year 0
3rd year 0
4th year 0
5th year 0
6th year 0
7th year 0
8th year 0
9th year 1 0
10th year 2 0
The Trust does not use PIP implants. The Trust operated on patients with PIP implants for removal.
University College London Hospitals NHS Foundation Trust
Date of first implantation 1998
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1998 2
1999
2000 1
2001
2002 2
2003
2004
2005
2006
2007
University Hospitals of Morecambe Bay NHS Foundation Trust
Date of first implantation N/A
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year
2nd year 1
3rd year
4th year
5th year
6th year
7th year
8th year
9th year
10th year
Warrington Hospitals NHS Foundation Trust
Date of first implantation 2006
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year
2nd year
3rd year 1 1
4th year
5th year 1 1
6th year
7th year
8th year
9th year
10th year
Yeovil District Hospital
Date of first implantation Jan-07
Post-operative year Number of women How many women have had explants due to rupture during this post implant year?
1st year
2nd year
3rd year
4th year 1 1
5th year
6th year
7th year
8th year
9th year
10th year
ANNEX E: CLINICAL GUIDANCE FOR GPs AND SURGEONS
Patients: Any patient with breast implants is advised to check the details of their implant with their surgeon or clinic.
GPs consulted by patients with PIP implants should explore the patient symptoms and examine the breast and locoregional lymph nodes.
Patients with local signs and symptoms should be referred for a specialist opinion.
Signs will include
• Lumpiness of the breast
• Lumpiness/ swelling of the regional lymph nodes
• Change in shape of the breast
• Deflation of the breast
• Redness
• Tenderness of the breast
• Swelling of the breast
Symptoms may include
• Pain
• Hyperaesthesia