Does the FDA care more about safety than people with diabetes do?

Today my inbox was suddenly flooded with links to a video with some commentary about artificial pancreas technology at a conference by a representative of the U.S. FDA. The implication many people are getting after watching the video clip is that this FDA representative is implying that people are being unsafe by building their own artificial pancreas. He mentions it is consumer prerogative to build an artificial pancreas – which is correct. The implication of his analogy is that changing your car and killing yourself is similar to a DIY artificial pancreas effort.

The scary takeaway from the video, in my opinion, as well as other public comments in the past, is the implication that the FDA cares more about the potential harms of taking action than the almost certain harms of inaction. And it’s increasingly frustrating that the FDA appears to imply publicly that those of us in the #wearenotwaiting community are doing things unsafely as a result of taking action.

Safety is what drives the #wearenotwaiting movement. In my case, I refuse to sleep another night with the fear that I won’t wake up in the morning because there’s not an FDA-approved system on the market that will wake me up if my life is in danger, let alone a system that can take action and change the situation to be more safe. So I built my own (#DIYPS), because the current FDA-approved CGM devices were not (and still are not) loud enough to wake me up at night, putting me at risk of dying in my sleep. And yes, it ultimately turned into an artificial pancreas – with the same goal of ensuring I wake up every morning, safely (alive). That is my prerogative for sure.

But I fail to see why the FDA, which collectively has no particular knowledge of these systems (especially as they have no jurisdiction, acknowledged on all fronts, over what I do myself – it’s my prerogative), is making public statements implying that these types of systems are categorically unsafe.

As a matter of fact, every DIY system I’ve seen is safer than the FDA-approved standard of care available for people with diabetes. The thousands of people using Nightscout, which is currently a DIY remote view-only monitoring system? Provides more safety and security for people with diabetes, not to mention it is helping achieve better outcomes for people with diabetes than they were able to achieve before with the standard of diabetes care as it exists today. (This was originally for the most part because of restricted access to data, although while that has improved there’s still interoperability issues getting access to real-time data in the same place from the 3+ average devices a person with diabetes uses…unless they have Nightscout or another DIY tool running.) The dozens of people working on their DIY version of an artificial pancreas system (many of whom are collaborating and sharing data in the #OpenAPS community)? These systems are safer than the standard of care, which is to let an insulin pump continue to overdose you if you are dangerously low while you sleep.

(You can see some of my personal data from #DIYPS, before we closed the loop, here and more about outcomes after we closed the loop and had #OpenAPS here. My closed loop artificial pancreas system continues to work excellently nine plus months in, and you can continue to watch my outcomes as I post them to Twitter regularly using the #DIYPS and #OpenAPS hashtags. I’ve also shared the other powerful lessons that DIY tech has helped me learn about diabetes care that helps all people with diabetes, regardless of technology.)

Are there risks to DIY efforts? Yes. But there’s risks to living with diabetes regardless. And as a person with diabetes, I am well aware of the risks that I choose to take. Diabetes is a disease in which you carry around large amounts of a lethal drug in your pocket that you are supposed to inject daily in order to save your life. As a person with diabetes, we are nothing but aware of the multitude of risks of living with this chronic disease 24/7/365.

In fact, even without a DIY artificial pancreas system, I am at risk every day simply from using my FDA-approved insulin pump that does not accurately track how much insulin I am given. (Read more here about how most insulin pumps on the market calculate IOB only from boluses, and often do not provide a record let alone incorporate any temporary adjustments to your basal rates and do not in any case track the impact of suspending your pump completely.)

And as someone who has founded the #OpenAPS movement, with the goal of an open and transparent effort to make safe and effective basic Artificial Pancreas System (APS) technology widely available to more quickly improve and save as many lives as possible and reduce the burden of type 1 diabetes…..we approach it with safety first in mind, and is a big part of why the DIY part is critical and is a part of our number one priority of safety.

Not everyone will choose to go the DIY route. In fact, most people do not and I am told all the time “Oh, I would never do that.” And that’s fine! Everyone can choose what they want for themselves.

But technology has made it increasingly feasible for those of us who want to improve our own safety to do so, because the industry and the FDA are not moving quickly enough to meet our needs.

That, indeed, is our prerogative – to increase our own safety.

Context – give me my data (on my device)

Today I saw that Medtronic announced a partnership with IBM. You can read about it on Twitter, where I first saw it, or elsewhere online. There’s lots of news articles and PR about it, too, which I haven’t read yet in great detail.

My initial reaction:

Pointing out that I can't get temp basal histories on my insulin pump

Additional context:

When I reduce my insulin (either by “suspending” the pump’s activity altogether, or by reducing my basal rate with a “temp” or temporary basal rate), there’s no record of it visible on my insulin pump.

None, at all.

Suspended for 15 minutes while I’m in the shower? No record of it if I accidentally resume insulin activity before checking to see when I suspended it.

Same for if I go running and activate a reduce basal rate (again, a “temp”) of 0.3u/hour instead of my usual 1.3/hour. That’s 1u less of insulin than I normally get. If I cancel it, or if that hour ends without me noticing it?

No record at all.

Which means if my blood glucose skyrockets an hour later, it will take me much longer to catch up with insulin if I don’t realize that I’m -1u (negative one unit) below what my body is used to.

Suspending your pump for 3 hours to go swimming? Same deal. Your body has less insulin than it’s used to, but you have to manually and mentally keep track of it.

The reverse is true as well – if you are sick and your body is more resistant to insulin than usual, and you use a higher basal rate than your usual as a way to additionally correct for a high BG?

No record of the additional insulin you’re putting into your body above your baseline basal profile.

THIS IS DANGEROUS.

And yet this is the FDA approved medical device that everyone is happy that I’m using? Even with critical flaws that endanger my life every day?

And the world has a problem with patients “hacking” or otherwise finding ways to access this critical data since we can’t get it from our approved devices?

This is backwards.

Medtronic and other pump brands track how much “insulin on board” (aka IOB) you have…but this number is wrong, because it doesn’t calculate the lack of insulin if you adjust your basal rates (examples above).

This is something I’ve been doing with #DIYPS to compensate for the inaccessibility of data from my FDA-approved medical device. Instead, I have to calculate for myself the “net” IOB number that takes into account any ‘negative’ corrections from suspending or negative or positive temp basal rates. These make a huge difference in my diabetes care.

We’ve learned from talking to people about #DIYPS for a year and a half that many people don’t use temporary basal rates, even though they’re very effective to ward off future lows and highs.

Why?

For one thing, it’s because there’s no record in their pumps. It’s too hard, and too much guesswork when there’s no record.

I don’t understand why the pump companies seem to ignore this. (If someone has a pump that tracks net IOB and/or shows a history of temporary basal rates and suspension, let me know. I’m familiar mainly with Medtronic’s pumps.)

This is not ok.

So while I think there’s a lot of potential for Medtronic to do more things with diabetes data (like this or this) through this partnership with IBM’s Watson? In the meantime, I’d like them to start with something much more simple – and with guaranteed impact.

Give me, the patient, my data that I need – directly on my medical device – so I can safely take care of myself and better manage my diabetes.

(Note – I realize FDA approval cycles on pumps take a long time, and this is unlikely to get fixed in current pumps. But future pumps? This should be fixed across the industry. And in the meantime? Companies can and should make it much easier to access data from the pumps via their approved uploader methods and make it easier to read the data. Right now, it’s not even easy to see the data off your pump. Let’s change this.)

“Making” and “DIY”ing – continued

I had a conversation this week with someone in the CGM in the Cloud Facebook group, after they indicated they wouldn’t be (or maybe weren’t interested in) joining the “dev” group for #OpenAPS – and it’s a conversation I find myself having often. Here’s what I usually end up saying, when someone says they’re not a “dev” or “not an engineer” or something similar:

“I’m not a formally trained developer/coder/engineer, either… but I keep telling people, many people in this project aren’t- it’s a passion project where we learn what we need to learn to do the things we want to do. It’s fine if someone chooses not to do something, but I encourage everyone to not let labels or perceptions of traditional roles stop them from jumping in and giving it a try to see what they can learn and thus do! Especially with this awesome supportive community of people willing to help you as you go.”

This also came up when we were discussing what it takes to be a “maker” on TEDMED’s #GreatChallenges live panel today. One of my excellent fellow panelists (Cole) pointed out that pretty much everyone is a maker – whether you tweak a recipe, work with wood, or find any kind of workaround of any sort to make things work. (Which in my mind makes every single person with diabetes a “maker” and probably anyone with any disease or health care condition that they live with.)

I previously wrote about what it takes to DIY from a DIYPS and #OpenAPS perspective (and why that’s important), but I think it holds true across any aspect of diabetes or any other disease state – and definitely beyond healthcare:

Passion, persistence, and willpower needed.

So please, don’t let labels stop you from DOING. You can learn whatever tech skills you set your mind to. You can find numerous ways to solve a problem, whether it’s on your own or by partnering with someone else – and there’s plenty of people with the skills who are willing to help you learn, too.Remember, we started building #DIYPS to make louder CGM alarms. Scott and I have both learned numerous new things and new programming languages and skills along the way as we went from alarms to an alert and recommendation system to a closed loop artificial pancreas (and now people who own 4 Raspberry Pis). We didn’t come to the table with knowledge of everything we needed to know to do what we first wanted to do – and we’re definitely still learning a dozen or more things (programming languages, new software, etc.) along the way as we continue with #OpenAPS. We also didn’t know anything previously about working directly with the FDA – and now we are, on a number of projects, in order to help scale from n=1 of a DIY artificial pancreas to many n=1s around the world.

You can do this. Bring your passion, and go do great things!

#WeAreNotWaiting, are you?

Why the DIY part of OpenAPS is important

I had the chance to talk about DIYPS and OpenAPS during a demo session in DC last week. (Thank you to Gary from Quantified Self and Marty from the National Academy of Sciences for making this possible!)

I walked away with several insights:

  1. Many people don’t know about diabetes; fewer have a realization of current diabetes tech. In several cases as I was describing the closed loop artificial pancreas, people stopped me and were wowed – but not by the closed loop. They were impressed by the CGM.
  2. Others think that this type of technology is already out on the market.

So, I believe we have a long way to go in communicating and advocating for this type of technology. We know it’s behind where it should be – and we want it to catch up. That’s a big part of the OpenAPS goals to help the FDA, device companies, and everyone involved move a little faster than they might otherwise, because #WeAreNotWaiting.

But here’s the other question I was often asked: “How many people have you given this to?”

I frequently embarked on an explanation of how we can’t “give” away #DIYPS or the OpenAPS implementation – in fact, we can’t and won’t give away the code, either. Some of that is because the FDA says no – and some of it is common sense and principles that both Scott and I hold.

Here’s why I think it is so important to keep the DIY in DIYPS and each OpenAPS implementation that is in progress:

  • You need to have a deep understanding of the system before even considering using it on yourself. You need to know what it’s trying to do in all situations, including the fringe cases (the “this is unlikely to happen but if it does…”), so that you know when it’s working – and when it’s not – whether it’s 3pm in the afternoon at work, or 3am and you wake up and find something is not right and the system is not working.
  • You need to go step by step and test and ensure at each stage that it is working as expected – both in a “this is what it should be doing” and “it is giving out the correct amount of insulin”. Remember, insulin is a lethal drug. It’s also a lifesaving drug. It’s important to remember both of these things and balance the risks accordingly.

From the conversations I’ve had with people interested in learning more or getting a DIYPS-type system for themselves, they fall into two categories:

  1. “How can I buy it from you?”
  2. “What do I need to do to make one?”

Given my above reasoning, the second question is my favorite. The first one scares me, if someone does not then switch to the #2 question. Many people do go from #1 to #2, which is great.

DIYPS, for me, and OpenAPS implementations, for others, are works in progress. They’re not perfect. They’re better than what’s out there (like sleeping through alarms when you’re low at night), but they also have big risks. And it’s important to know, and respect these risks, and understand the limitations of the system, before being able to take advantage of this type of system – and to build the system with appropriate safeguards. (This is one of the reason we have OpenAPS, for example, designed to accept multiple failure points – like walking out of range, loss of connectivity, etc.)

The ability to buy a “black box” type system where you don’t know exactly how it works, but you trust that it works? That will be coming from the major device manufacturers in several years – hopefully sooner rather than later, and that’s something that OpenAPS will hopefully help make happen more quickly.

So to answer the #2 question, what do you need to make a DIYPS or OpenAPS of your own?

I’ll answer the technical aspects of this question in another post, but the first thing I always say is: “The willingness to build and test and test and test some more before ever considering using it on yourself.”

#DIYPS & #OpenAPS

Since I‘ve been using #DIYPS for over a year and also had the closed loop version running for more than two months with excellent results, I get several questions every week about how/when we’re going to make it available to other people. #DIYPS is an individual implementation that we built, and because of FDA regulations it’s not something we can give to another person to use. (Not to mention it’s not been tested for more than n=1, etc.) But, both Scott and I are passionate about moving diabetes technology forward for all, and so this week we kicked off the OpenAPS project.

#OpenAPS is our initiative to build on the #DIYPS closed loop work and eventually make this type of technology available (and faster than the market and traditional research is otherwise moving) for more people with diabetes. We aim to encourage other independent researchers to build their own closed loop implementations based on the OpenAPS reference design, and share their results and help us improve the design further. We are also working toward clinical trials that will enable more people to test and use the system during the research phase, but without having to code and build their own implementation of a closed loop artificial pancreas system. And all of this will be done in an open, transparent way so people can ask questions, monitor progress, and get involved at various stages.

The Open Artificial Pancreas System (#OpenAPS) is an open and transparent effort to make safe and effective basic Artificial Pancreas System (APS) technology widely available to more quickly improve and save as many lives as possible and reduce the burden of Type 1 diabetes.

We believe that we can make safe and effective APS technology available more quickly, to more people, rather than just waiting for current APS efforts to complete clinical trials and be FDA-approved and commercialized through traditional processes. And in the process, we believe we can engage the untapped potential of dozens or possibly hundreds of patient innovators and independent researchers and also make APS technology available to hundreds or thousands of people willing to participate as subjects in clinical trials.

At the end of the process, we hope to have produced an FDA-approved #OpenAPS reference design and reference implementation that can be used by any medical device manufacturer with minimal regulatory burden. We believe this will in turn allow manufacturers (and the academic research teams they work with) to turn more of their attention to designing and testing more advanced APS systems, and thereby accelerate the pace of innovation toward new and improved Type 1 diabetes treatments, and eventually a cure.

In the mean time, it will make basic overnight closed loop APS technology widely available to anyone with compatible medical devices, thereby reducing the burden of Type 1 diabetes on everyone who lives with the disease.

I’ll continue to post here often with data and updates from my experience & work with #DIYPS, which I’m continuing to use. But I also encourage you to bookmark OpenAPS.org if you’re interested in watching that work move forward, too – and as always, we’ll be on Twitter with #DIYPS and #OpenAPS as @DanaMLewis and @ScottLeibrand (and you can email us for #DIYPS or #OpenAPS info at Dana@OpenAPS.org and Scott@OpenAPS.org).

Why #DIYPS N=1 data is significant (and #DIYPS is a year old!)

As I’ve said many times, last year we set out to create a louder CGM alarm system. By adding “snoozes” so I didn’t drive my co-investigator crazy, we realized I might as well enter what I was doing, and be precise about it (aided by some quick bolus and quick carb buttons that made data-entry not the chore that it sounds). Thus, we had the data and the brains to realize that this made for some great predictions; much better than what you usually see in diabetes tools because they rely only on your insulin sensitivity factor (ISF) and correction rate, but don’t take into account carbs on board and their impact over time, etc.

(If you’re new to #DIYPS, read about the beginnings of it here. For more on this idea of carbs on board and the carbohydrate absorption rate and how significant it is for people with diabetes, read about that here.)

After I had spent 100 days using #DIYPS, Scott and I stopped to look and see what the impact was. For the long version, read this post about the results and the direct comparison to the bionic pancreas trial data that was available then. The short version: #DIYPS reduced my eAG and a1c significantly, reduced lows, reduced highs – aka my time in range was improved from 50% to regularly 80+%.

I have asked myself (and others have asked), are these results sustainable? Are these improved outcomes truly because of #DIYPS? It’s definitely worth noting I never changed what or how I ate. (I ate 120 grams of pizza (for science! ;)) several times to test the system, but I didn’t eat less or any healthier or otherwise change my diet.)
I can’t attribute these outcomes directly to #DIYPS alone, but I do believe they’re highly correlated. It’s hard to separate other contributing factors like the fact that I have more boluses per day using #DIYPS (which other studies have shown decreases a1c); or the fact that I spend less time high/low because with #DIYPS I actually can wake up at night and take action before I’m high or low.
So, it’d be hard to study specific factors and say “it’s all #DIYPS”. But, I’m pretty sure it’s mostly #DIYPS. Regardless, here’s the updated data about the sustainability of the results I’ve seen with #DIYPS over the past year:
Why this is significant
#DIYPS is currently n=1 (meaning one person is the study’s subject). But what is significant is that I have year’s worth of data and actual lab-tested a1cs that shows the outcome of this type of artificial pancreas work. And it (to date, but coming soon  / OMG this week!) hasn’t even been closed loop – I’m still the “human in the loop” making decisions and pushing buttons on my pump.Compared to the bionic pancreas and other artificial pancreas study trials where they have a few days and a few more (usually n=20 or so) subjects; they can look at the decrease in lows and highs and improved eAG…but they can only project what the a1c improvement is going to be.We’ve shown the improvements in lab-tested a1cs – see my graph above?

It all adds up
Scott and I are not the only ones working on a closed loop. The community of developers connected to the Nightscout community has nearly two hands full of people who are working independently on device interoperability to close the loop by freeing our data from devices and enabling us to work with our own algorithms regardless of which hardware device we use to support our diabetes management.When all of these n=1 studies add up, it matters. At some point in the near future, after we’ve closed the loop with #DIYPS (ah! this week! :)) and others have as well, we may have more n=1 hours on closed loop artificial pancreas systems than the (traditional) “researchers”. Scott and I are hoping that we can not only show the world how open source innovation and new regulatory paradigms can deliver safe and effective results for people living with T1D faster than traditional medical device development and traditional regulation; but that we can also change how all successful medical device companies approach interoperability, and how traditional medical researchers do research – possibly in partnership with patient researchers like us.