Dr Stanislaw Burzynski -- Antineoplaston Therapy -- Articles,
patents

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**Dr Stanislaw BURZYNSKI**

**Antineoplaston Therapy**

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![](burzynski.jpg)

[**http://www.burzynskiclinic.com/**](http://www.burzynskiclinic.com/)

**The Burzynski Clinic**   
9432 Old Katy Road, Suite 200   
Houston TX 77055-6330 USA

INFOLINE: 713.335.5697   
International Calls +1 713.335.5697   
Fax. (001)  713  335  5699   
Email: info@burzynskiclinic.com

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[**http://en.wikipedia.org/wiki/Antineoplaston**](http://en.wikipedia.org/wiki/Antineoplaston)

**Antineoplastons**

**Antineoplaston (ANP)** is a name coined by Stanislaw
Burzynski for a group of peptides, derivatives, and mixtures for
which he claims anti-cancer activity. These compounds have been
administered by Burzynski to cancer patients since 1976. The
clinical efficacy of antineoplastons combinations for various
diseases are the current subject of numerous FDA Phase II trials
by Burzynski and his associates. Antineoplastons are
manufactured at a facility in Stafford, Texas for
investigational use by the Burzynski Clinic, a public company
that trades as a penny stock on the OTC Bulletin Board (BZYR)

**Background**

In 1967 Stanislaw Burzynski began investigating the use of
antineoplastons after noting significant peptide deficiencies in
the blood of cancer patients as compared with a control
group[1][1]. Burzynski first identified antineoplastons from
human blood. Since similar peptides had been isolated from
urine, in 1970 Burzynski initially purified urine as a bulk
source of antinoeplastons. Since 1980 he has been reproducing
his compounds synthetically.[2] Since his initial discovery,
Burzynski has isolated dozens of peptide and derivatives, some
of which have been reportedly found to be active against cancer
with low toxicity.

The first active peptide fraction identified was called
antineoplaston A-10 (3-phenylacetylamino-2,6-piperidinedione).
From A-10, antineoplaston AS2-1, a 4:1 mixture of phenylacetic
acid and phenylacetylglutamine, was derived [3]. The active
ingredient of antineoplaston A10-I is phenylacetylglutamine [4].

Phenylacetic acid is a toxic compound that the body produces
during normal metabolism. It is detoxified in the liver to
phenylacetyl glutamine. The "antineoplaston A-10" compound is an
isolation artifact resulting from heating the urine under acidic
conditions. The "antineoplaston AS2-1" mixture is the result of
an alkaline hydrolysis of "antineoplaston A-10". All compounds
are widely available cheap chemicals.

**Treatment**

For legal reasons Burzynski currently sells his treatments only
in the context of clinical trials. Patients receiving cancer
treatment with antineoplastons must first qualify for one of the
currently available clinical trials. In order to qualify for
most of the trials, a patient must have first failed standard
treatment for the condition being treated, or it must be a
condition that is unlikely to respond to currently available
therapy and for which no curative therapy exists.
Antineoplastons may be administered intravenously or orally.
Patients who respond positively to initial treatment with
intravenous antineoplastons sometimes transition to the oral
form. Intravenous antineoplastons are administered continuously
with a portable programmable pump that the patient carries on a
shoulder strap in a canvas bag.

Treatment with antineoplastons can be very costly to patients
without insurance coverage, exceeding $100,000 for the first
year of intravenous treatment. Many insurance companies consider
antineoplaston therapy to be investigational and unproven and do
not cover the cost.[5][6]

The "antineoplastons," natural peptides and metabolites, are
not generally cytotoxic like many historical (and current)
antineoplastic agents; rather the highest usage levels carry a
very high sodium load that require careful attention to fluid
and electrolyte balance.

**Proposed mechanisms**

Antineoplastons, being investigational drugs, have never been
FDA approved as "safe and effective" in treating human cancer.
Independent tests at at the National Cancer Institute have never
been positive.[7] The Japanese National Cancer Institute has
reported that antineoplastons did not work in their
studies.[citation needed]

Burzynski suggests that antineoplastons A10 and AS2-1 both work
by inhibiting oncogenes, promoting apoptosis, and activating
tumor suppressor genes [4]. Several other mechanism of action
have been proposed.

One of the factors that allows some cancers to grow out of
control is the presence of abnormal enzymes, a byproduct of DNA
methylation. In the presence of these enzymes, the normal life
cycle of the cells is disrupted and they replicate continuously.
Antineoplastons have been shown in the laboratory to inhibit
these enzymes [8].

Recent studies have shown that inhibiting histone deacetylase
(HDAC) promotes the activation of tumor suppressor genes p21 and
p53. Phenylacetic acid contained in the AS2-1 mixture has been
shown to be a weak HDAC inhibitor[9].

**References**

1. ^ Burzynski SR (1986). "Antineoplastons: history of the
research (I)". Drugs under experimental and clinical research 12
Suppl 1: 19. PMID 3527634.   
2. ^ Ralph Moss (1996), The Cancer Industry ISBN 1881025098   
3. ^ NCI Drug Dictionary, Definitions of antineoplastons A10 and
AS2-1   
4. ^ a b S.R. Burzynski, The Proposed Mechanism of Antitumor
Activity of Antineoplastons (ANPs) in High Grade Glioma
Pathology (HBSG) Integrative Cancer Therapies 2006; 40-47   
5. ^ Aetna Clinical Policy Bulletin, Antineoplaston Therapy and
Sodium Phenylbutyrate   
6.^ Blue Cross/Blue Shield Medical Policy, Antineoplaston
Therapy   
7.^ Burzynski SR (1999). "Efficacy of antineoplastons A10 and
AS2-1". Mayo Clin. Proc. 74 (6): 6412. PMID 10377942.   
8.^ Liau MC, Burzynski SR (1986). "Altered methylation complex
isozymes as selective targets for cancer chemotherapy". Drugs
under experimental and clinical research 12 Suppl 1: 7786. PMID
3743383.   
9.^ Jung M (2001). "Inhibitors of histone deacetylase as new
anticancer agents". Curr. Med. Chem. 8 (12): 150511. PMID
11562279.

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**Patents**

**FORMULATION OF AMINO ACIDS AND RIBOFLAVIN USEFUL TO REDUCE
TOXIC EFFECTS OF CYTOTOXIC CHEMOTHERAPY**   
**US2003105104**   
Also published as:  WO03045372 (A1) //  EP1450781 (A1)
//   US2005182064 (A1) //   (A1) // 
SI21542 (A) // DE60212693T   
Abstract --  Pharmaceutical compositions effective in
alleviating or reducing the effects of fatigue and weakness
associated with cancer and cytotoxic cancer chemotherapy are
disclosed. The pharmaceutical compositions of the present
invention comprise riboflavin, effectors of the urea cycle in
free form or pharmacologically acceptable salts thereof, and
amino acids selected from the gorups of essential and
non-essential amino acids, in free form or pharmaceutically
acceptable salts thereof, suitably combined with appropriate
carriers, diluents, or excipients. Also disclosed are methods of
alleviating or reducing the effects of fatigue and weakness
associated with cancer and cytotoxic cancer chemotherapy by
administration of pharmaceutical compositions of the present
invention.

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**Toothpaste containing anticancer agents**   
**US7087219 (B2)**   
Abstract --  A novel dentifrice composition is provided for
prevention or treatment of carcinoma of the oral cavity, caries
and periodontal diseases of the oral cavity. The dentifrice
composition contains a silica abrasive and medicinal agents
useful in the treatment of human neoplastic disease. The
medicinal agent is selected from the group consisting of
3-N-phenylacetylamino-2,6-piperidinedione,
phenylacetylglutamine, phenylacetylisoglutamine, phenylbutyrate,
phenylacetate, combinations thereof and pharmaceutically
acceptable salts thereof. The components of the dentifrice
composition act advantageously to allow the composition to
remove plaque, tartar, and oral disease-causing bacteria.

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**METHOD FOR PREPARING
3-(N-PHENYL-ACETYLAMINOPIPERIDINE)-2,6-DION**   
**US4918193**   
Also published as:  SU1809830 (A3) // PH26099 (A) //
FI900129 (A) // PL163552B (B1) // KR0139204B   
Abstract ---  Disclosed is a process for synthesizing
3-[N-phenylacetylaminopiperidine]-2,6-dion, which process
comprises the steps of providing a quantity of L-glutamine,
providing a quantity of phenylacetyl halide, mixing together the
L-glutamine and phenylacetyl halide in a weakly alkaline aqueous
solution to provide an aqueous reaction mixture, adjusting the
reaction mixture to a pH ranging from about 2 to about 3, and
recovering from the reaction mixture the product
3-[N-phenylacetylamino-piperidine]-2,6-dion, and when desired
preparing the pharmaceutically acceptable salts thereof.

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**Method for the treatment of von Hippel-Lindau (VHL) disease
with phenylacetyl-derivatives**   
**US2006205818**   
Abstract -- Provided are methods of treating von Hippel-Lindau
disease (VHL). Specifically embodiments of the invention provide
methods for the treatment of a patient afflicted with VHL using
phenylacetyl-derivatives. Preferred embodiments of the invention
provide for the use of phenylacetic acid (or its sodium salt),
phenylacetylglutamine (or its sodium salt) and/or
phenylacetylisoglutamine (or its sodium salt) to treat VHL.
Other embodiments of the invention provide for the use of
phenylacetyl-derivatives for the manufacture of a medicament for
the treatment of VHL.

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**Phenylacetic acid compositions for treating or preventing
hypercholesterolemia**   
**US6987131 (B1)**   
Also published as:  EP1206936 (A2)  // DE60112872T   
Abstract --  Pharmaceutical compositions are disclosed
comprising one or more compounds selected from the group
consisting of phenylacetylglutamine, phenylacetylisoglutamine,
and phenylacetic acid, in addition to
pharmaceutically-acceptable salts, analogs, and precursors
thereof, and optionally also isoglutamine, with a
pharmaceutically-acceptable carrier, diluent, or excipient,
useful in the treatment or prevention of hypercholesterolemia
and hypertriglyceridemia. Also disclosed are methods for
treating or preventing hypercholesterolemia and
hypertriglyceridemia using the pharmaceutical compositions.

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**LIPOSOMAL ANTINEOPLASTON THERAPIES WITH MARKEDLY IMPROVED
ANTINEOPLASTIC ACTIVITY**   
**US6013278**   
Also published as: WO9742939 (A1) //  EP0906088 (A1) //
AT310505T //  EP0906088 (A0) // EP0906088 (B1   
Abstract -- A second generation of antineoplaston therapies with
markedly improved antineoplastic activity is disclosed. Among
others, members of the antineoplaston family include
phenylacetate (PN), 3-phenylacetyl-amino-2,6, piperidinedione
(CN), and hydrolysis derivatives of CN: phenylacetylglutamine
(PG) and iso-phenylacetylglutamine (Iso-PG). In part, these
increases in antineoplastic activity result from large increases
in the transport of antineoplaston compositions into cells.
Importantly and unexpectedly these increases in antineoplastic
activity also result from the capacity of the drug delivery
system to direct antineoplaston compounds intracellular
trafficking to intracellular binding sites influencing cell
viability and proliferation. Liposomal formulations of
antineoplaston compositions increase in vitro antineoplastic
activity by a factor of 750 to 1500 as compared to
administration of antineoplaston compounds given without
liposomal formulations. In addition, these liposomal
formulations enhanced cellular uptake of antineoplaston
compounds form 30 to more that 80 fold. Liposomal formulations
were also found to increase intracellular levels of the
antineoplaston CN(3-phenylacetyl-amino-2,6, piperidinedione) by
directing CN to intracellular binding sites that influence cell
viability and proliferation and block its hydrolysis. Under
conditions where free CN has no antineoplastic activity,
liposomally formulated CN can produce essentially complete and
relatively long-lasting blockade of cell growth. Cell growth was
found to be restored as intracellular levels of bound CN
decrease to undetectable levels.

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**PHENYLACETIC ACID COMPOSITIONS FOR TREATING OR PREVENTING
ATHEROSCLEROSIS AND RESTENOSIS**   
**US6127419**   
Also published as:  WO0030627 (A3) //  WO0030627 (A2)
// EP1171110 (A3) //  EP1171110 (A2)  HK1045253   
Abstract ---  Pharmaceutical compositions effective in
treating or preventing atherosclerosis and restenosis are
disclosed. The pharmaceutical compositions of the present
invention comprise one or more compounds selected from the group
consisting of phenylacetic acid, pharmaceutically-acceptable
salts thereof, pharmaceutically-acceptable precursors thereof,
and pharmaceutically-acceptable analogs thereof (e.g.,
phenylacetylglutamine and iso-phenylacetylglutamine), suitably
combined with appropriate carriers, diluents, or excipients. The
compositions also optionally contain isoglutamine. Also
disclosed are methods for treating or preventing atherosclerosis
and restenosis by the administration of pharmaceutical
compositions of the present invention.

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**SYNTHESIS OF 4-PHENYLBUTYRIC ACID**   
**US6372938**   
Also published as:  EP1404638 (A1) // WO02094756 // 
RU2003136765 (A) // EP1404638 (A0) // CN1511133 (A)   
Abstract --  A method of synthesizing compounds of Formula
(I): formula (I) by reacting aromatic compounds with
butyrolactone, followed by neutralization with base. The
reaction can be conducted in the presence of a catalyst.
Preferred catalysts are Lewis acids. A preferred product of
Formula I is 4-phenylbutyric acid, which is obtained by the
reaction of benzene with butyrolactone in the presence of
aluminum chloride, followed by neutralization with base.

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**PHARMACEUTICAL COMPOSITIONS FOR USE IN TREATING PARKINSON'S
DISEASE // METHODS FOR TREATING AIDS**   
**US5089508**   
Also published as: WO9204027 (A1) // EP0500905 (A1) // EP0500905
(A0) //  EP0500905 (B1) // ES2084181T (T3)   
Abstract --- The present invention provides methods for treating
AIDS-related diseases by administering to an afflicted host
pharmaceutical compositions containing a therapeutically
effective amount of substituted piperidinedione of the formula
or or mixtues thereof, wherein R is OH, NH2, OW, or H; X is H,
F. Cl, Bri, I, OH, OW, NO2, or NH2; Y is H, F. Cl, Bri, or I; W
is or a C1 to C12 aliphatic group; Z is an aliphatic or aromatic
group of C1 to C12; X and Y can both vary within the compound;
and pharmaceutically acceptable salts thereof. The
pharmaceutical compositions further may include R,X,Y
substituted phenylacetic acid.

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**PHENYLACETYLGLUTAMINE, PHENYLACETYLISOGLUTAMINE, AND/OR
PHENYLACETATE FOR THE TREATMENT OF NEOPLASTIC DISEASES**   
**US6943192**   
Also published as: WO0004894 (A3) //  WO0004894 (A2)
//  EP1098643 (A3) //  EP1098643 (A2) // HK1037142   
Abstract --- Herein is disclosed a method of treating neoplastic
disease, including cancer, comprising administering a
pharmaceutical composition, the pharmaceutical composition
comprising a highly concentrated aqueous solution of
phenylacetylglutamine and phenylacetylisoglutamine in a 4:1
ratio, at an infusion rate of from 100 mL/hr to 400 mL/hr. In a
further embodiment, herein is also disclosed a method of
treating neoplastic disease, including cancer, comprising
administering a pharmaceutical composition, the pharmaceutical
composition comprising a highly concentrated aqueous solution of
phenylacetate and (phenylacetylglutamine or
phenylacetylisoglutamine) in a 4:1 ratio, at an infusion rate of
from 100 mL/hr to 400 mL/hr. Herein are also disclosed the
pharmaceutical compositions used in the above methods.

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**Use of a combination of antineoplastons for the manufacture
of a medicament for the treatment of neurofibromatosis**   
**US5391575 (A1)**   
Also published as: EP0680756 (A1) //  HK1016408 //
EP0680756 (B1) // ES2139774T (T3) // AU683145B (B2)   
Abstract ---  The present invention provides methods for
treating neurofibromatosis in humans by administering to an
afflicted host pharmaceutical compositions containing a
therapeutically effective amount of a combination of (A) and (B)
in a weight ratio ranging from about 1:1 to about 1:10 (A:B);
wherein R is OH, NH2, OW, or H; X is H, F, Cl, Br, I, OH, OW,
NO2 or NH2; Y is H, F, Cl, Br, or I; W is or a C1 to C2
aliphatic group; Z is an aliphatic or aromatic group of C1 to
C12; X and Y can both vary within the compound; or
pharmaceutically acceptable salts thereof. Particularly
disclosed herein is a composition comprising a 1:4 ratio of the
sodium salts of phenylacetylglutamine and phenylacetic acid,
formulated in both oral and parenteral forms. Typically, the
patient is given the combination composition from 1 to 20 g/day
in divided doses. After several months of treatment patients
exhibit significant decrease in number and size of nodules.

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**Methods for treating viral infections**   
**WO9324123 (A1)**   
Also published as:  //  EP0601164 (A1) // EP0601164
(A4) //  EP0601164 (A0) // EP0601164 (B1) // HK1014499   
Abstract --- The present invention provides methods for treating
viral diseases in humans by administering to an afflicted host
pharmaceutical compositions containing a therapeutically
effective amount of a combination of (A) and (B) in a weight
ratio ranging from about 1:1 to about 1:10 (A:B); wherein R is
OH, NH2, OW, or H; X is H, F, Cl, Br, I, OH, OW, NO2, or NH2; Y
is H, F, Cl, Br, or 1; W is ( alpha ) or a C1 to C12 aliphatic
group; Z is an aliphatic or aromatic group of C1 to C12; X and Y
can both vary within the compound; or pharmaceutically
acceptable salts thereof. Particularly disclosed herein is a
composition comprising a 1 to 4 ratio of the sodium salts of
phenylacetylglutamine and phenylacetic acid, formulated in both
oral and parenteral forms clinically useful in the treatment of
herpes virus, HIV, human papilloma virus, rhinovirus,
coronavirus, orthomyxovirus, and paramyxovirus.

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**COMPOSITIONS AND METHODS FOR TREATING AUTOIMMUNE DISEASES**
  
**US5646182**   
Also published as: WO9325201 (A1)  GR3026681T // EP0603383
(A1) //  EP0603383 (A4) // EP0603383 (A0)   
Abstract --- The present invention provides methods for treating
autoimmune disease in humans by administering to an afflicted
host pharmaceutical compositions containing a therapeutically
effective amount of a combination of (A) and (B) in a weight
ratio ranging from about 1:1 to about 1:10 (A:B); wherein R is
OH, NH2, OW, or H; X is H, F, C1, Br, I, OH, OW, NO2, or NH2; Y
is H, F, C1, Br, or I; W is (1) or a C1 to C12 aliphatic group;
Z is an aliphatic or aromatic group of C1 to C12; X and Y can
both vary within the compound; or pharmaceutically acceptable
salts thereof. Particularly disclosed herein is a composition
comprising a 1 to 4 ratio of the sodium salts of
phenylacetylglutamine and phenylacetic acid, formulated in both
oral and parenteral forms clinically useful in the treatment of
rheumatoid arthritis, lupus erythematosus, vasculitis, insulin
dependent diabetes mellitus and multiple sclerosis.

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**Methods for treating viral infections**   
**US5244922**   
Abstract --- The present invention provides methods for treating
viral diseases in humans by administering to an afflicted host
pharmaceutical compositions containing a therapeutically
effective amount of a combination of (A) and (B) in a weight
ratio ranging from about 1:1 to about 1:10 (A:B); wherein R is
OH, NH2, OW, or H; X is H, F, Cl, Br, I, OH, OW, NO2, or NH2; Y
is H, F, Cl, Br, or I; W is or a C1 to C12 aliphatic group; Z is
an aliphatic or aromatic group of C1 to C12; X and Y can both
vary within the compound; or pharmaceutically acceptable salts
thereof. Particularly disclosed herein is a composition
comprising a 1 to 4 ratio of the sodium salts of
phenylacetylglutamine and phenylacetic acid, formulated in both
oral and parenteral forms clinically useful in the treatment of
herpes virus, HIV, human papilloma virus, rhinovirus,
coronavirus, orthomyxovirus and paramyxovirus.

---

  

**Methods for treating AIDS**   
**US5254587**   
Abstract --- The present invention provides methods for treating
AIDS-related diseases by administering to an afflicted host
pharmaceutical compositions containing a therapeutically
effective amount of substituted piperidinedione of the formula
or mixtures thereof, wherein R is OH, NH2, OW, or H; X is H, F,
Cl, Br, I, OH, OW, NO2, or NH2; Y is H, F, Cl, Br, or I; W is or
a C1 to C12 aliphatic group; Z is an aliphatic or aromatic group
of C1 to C12; X and Y can both vary within the compound; and
pharmaceutically acceptable salts thereof. The pharmaceutical
compositions further may include R,X,Y substituted phenylacetic
acid.

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**Pharmaceutical composition comprising phenyl acetyl
glutamine,a combination of this compound with phenylacetic
acid or 3-(phenylacetylamino)piperidine-2,6-dione,a process
for isolating the latter from urine and a process for the
synthesis of 3-(pheny...**   
**US4470970 (A1)**   
Also published as: EP0069232 (A2) // DK143491 // JP58010521 (A)
// JP5058886 (A) //  JP5032548 (A)   
Abstract --- Highly purified fractions from human urine
exhibiting antineoplastic activity and processes for their
preparation are described. The fractions comprise biologically
active, small sized, low molecular weight peptides which exert
cytostatic and cytotoxic activity toward neoplastic cell
cultures and human neoplastic diseases. The fractions have been
termed antineoplaston fractions. An antineoplastic active
peptide common to each of the various antineoplaston fractions
has been isolated and identified as
3-[N-phenylacetylaminopiperidine]-2, 6-dion. A synthetic
mechanism for the preparation of
3-[N-phenylacetylaminopiperdine]-2, 6-dion is also disclosed,
involving a combination reaction between L-glutamine and
phenylacetyl chloride. Also disclosed are the hydrolysis
degradation products of 3-[N-phenylacetylaminopiperidine]-2,
6-dion which also exhibit antineoplastic activity when
administered according to the general teachings presented in
this disclosure.

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**Topical use of 3-phenylacetylamino-2,6-piperidinedione for
treatment of skin wrinkles and hyperpigmentation**   
**US4593038 (A1)**   
Also published as: EP0197358 // JP61229811 (A) // EP0197358 (A3)
// CA1262866 (A1) // EP0197358 (B1)   
Abstract ---A cosmetic composition is provided which comprises
3-phenylacetylamino-2,6-piperidinedione dispersed in a
cosmetically suitable vehicle. This cosmetic composition is
useful in the topical cosmetic treatment of skin areas affected
with wrinkles or hyperpigmentation.

---

**Purified antineoplaston fractions and methods of treating
neoplastic disease**   
**US4559325**   
Abstract --- Highly purified fractions from human urine
exhibiting antineoplastic activity and processes for their
preparation are described. The fractions comprise biologically
active, small sized, low molecular weight peptides which exert
cytostatic and cytotoxic activity toward neoplastic cell
cultures and human neoplastic diseases. The fractions have been
termed antineoplaston fractions. An antineoplastic active
peptide common to each of the various antineoplaston fractions
has been isolated and identified as
3-[N-phenylacetylaminopiperidine]-2, 6-dion. A synthetic
mechanism for the preparation of
3-[N-phenylacetylaminopiperdine]-2,6-dion is also disclosed,
involving a combination reaction between L-glutamine and
phenylacetyl chloride. Also disclosed are the hydrolysis
degradation products of 3-[N-phenylacetylaminopiperidine]-2,
6-dion which also exhibit antineoplastic activity when
administered according to the general teachings presented in
this disclosure.

---

**Purified antineoplaston fractions and methods of treating
neoplastic disease**   
**US4558057**   
Abstract --- Highly purified fractions from human urine
exhibiting antineoplastic activity and processes for their
preparation are described. The fractions comprise biologically
active, small sized, low molecular weight peptides which exert
cytostatic and cytotoxic activity toward neoplastic cell
cultures and human neoplastic diseases. The fractions have been
termed antineoplaston fractions. An antineoplastic active
peptide common to each of the various antineoplaston fractions
has been isolated and identified as
3-[N-phenylacetylaminopiperidine]-2, 6-dion. A synthetic
mechanism for the preparation of
3-[N-phenylacetylaminopiperdine]-2, 6-dion is also disclosed,
involving a combination reaction between L-glutamine and
phenylacetyl chloride. Also disclosed are the hydrolysis
degradation products of 3-[N-phenylacetylaminopiperidine]-2,
6-dion which also exhibit antineoplastic activity when
administered according to the general teachings presented in
this disclosure.

---

**Testing procedure to aid diagnosis of cancer and evaluate
the progress of cancer therapy**   
**US4444890**   
Abstract --- Antineoplastons are termed a group of plasma,
tissue and urinary peptides and amino acid derivatives capable
of modulating abnormal tissue growth, such as neoplastic
disease. Antineoplastons, when administered to persons with
neoplastic disease, have been shown to be effective against
several forms of cancer and tumors. A procedure is provided
herein for the determination of antineoplaston levels in
physiological tissues or fluids, especially plasma and urine.
The procedure involves purification of antineoplastons by high
performance liquid chromatography on silica gel followed by
resolution of antineoplastons by high performance liquid
chromatography on sulfonated polystyrene. A quantitative
determination of antineoplaston tissue or fluid levels provides
valuable data to aid clinical diagnosis of cancer. In addition,
the quantitative determination also provides a means for
monitoring the efficacy of antineoplastic therapy.

---

**No title available**   
**PL226778**

---

**NOVEL (E) -N-ALKYL-3'-HYDROXY-GAMMA-CHALCONYLIC BROMIDES AND
METHOD OF OBTAINING THEM**   
**PL344930**

---

**URZADZENIE DO CIAGLEGO SELEKTYWNEGO ROZDRABNIANIA SKAL
ZWIEZLYCH**   
**PL195585**

---

**URZADZENIE DO POBIERANIA PROB GRUNTU O NIENARUSZONEJ
STRUKTURZE I BADANIA WYTRZYMALOSCI GRUNTU W OTWORACH
WIERTNICZYCH**   
**PL192917**

---

**PURIFIED ANTINEOPLASTON FRACTIONS AND METHODS OF TREATING
NEOPLASTIC DISEASE**   
**ZA8204178**

---

**PHARMAZEUTISCHE ZUSAMMENSETZUNG ENTHALTEND
PHENYLACETYLGLUTAMIN, DESSEN KOMBINATION MIT PHENYLESSIGSAEURE
ODER 3(PHENYLACETYLAMINO)PIPERIDIN-2,6-DION,EIN VERFAHREN ZUR
GEWINNUNG DIESER STOFFE AUS URIN SOWIE EIN VERFAHREN ZUR
HERSTELLUNG VON 3(PHENYLA...**   
**AT23113T**

---

**TOPISCHE ANWENDUNG DES
3-PHENYLACETYLAMINO-2,6-PIPERIDINDIONSZUR BEHANDLUNG VON
HAUTFALTEN UND HYPERPIGMENTIERUNG**   
**AT52911T**

---

**Hreinsathar antineoplaston hlutar og athferth til
methferthar neoplastic-veiki**   
**IS2729**

---

**USE OF PHENYLACETYL-DERIVATIVES FOR THE MANUFACTURE OF A
MEDICAMENT TO TREAT VON HIPPEL-LINDAU (VHL) DISEASE**   
**EP1855665**   
Also published as: WO2006096481 (A1)  //  EP1855665
(A0)

---



**Publications**

[**http://www.burzynskiclinic.com/ph/media-corner-publications.html**](http://www.burzynskiclinic.com/ph/media-corner-publications.html)

[**http://www.burzynskiclinic.com/assets/images/Pub%20SRB\_2007\_Brainstem%20Glioma\_%20Cancer%20Therapy.pdf**](http://www.burzynskiclinic.com/assets/images/Pub%20SRB_2007_Brainstem%20Glioma_%20Cancer%20Therapy.pdf)
  
Recent clinical trials in diffuse intrinsic brainstem glioma.   
Burzynski, S.R. Cancer Therapy 2007; 5, 379-390

[**http://www.burzynskiclinic.com/assets/images/Pub%20SRB\_2007\_A%20case%20report\_Neuro-Oncology-issue4\_Oct2007.pdf**](http://www.burzynskiclinic.com/assets/images/Pub%20SRB_2007_A%20case%20report_Neuro-Oncology-issue4_Oct2007.pdf)
  
A case report of a complete response and 20-year survival of a
patient with a recurrent diffuse intrinsic brainstem anaplastic
astrocytoma.   
Burzynski, S.R., Weaver, R., Szymkowski, B. Neuro-Oncology 2007;
9:536

[**http://www.burzynskiclinic.com/assets/images/Pub%20SRB\_2007\_PB%20and%20PN\_SNO.pdf**](http://www.burzynskiclinic.com/assets/images/Pub%20SRB_2007_PB%20and%20PN_SNO.pdf)
  
Phenylacetylglutamine (PG) and phenylacetate (PN) interact
additively to produce detachment-induced apoptosis/anoikis in
glioblastoma cells.   
Patil, S., Burzynski, S.R., Mrowczynski, E., Grela, K.
Neuro-Oncology 2007; 9:482

[**http://www.burzynskiclinic.com/assets/images/Pub%20SRB\_2007\_Phase%20II%20ANP%20Brainstem%20Glioms\_Neuro-Oncol-issue2-April2007.pdf**](http://www.burzynskiclinic.com/assets/images/Pub%20SRB_2007_Phase%20II%20ANP%20Brainstem%20Glioms_Neuro-Oncol-issue2-April2007.pdf)
  
Phase II studies of Antineoplastons A10 and AS 2-1 (ANP) in
children with newly diagnosed diffuse, intrinsic brainstem
gliomas.   
Burzynski, S.R., Weaver, R.A., Janicki, T.J., Jurida, G.F.,
Szymkowski, B.G., Kubove, E. Neuro-Oncology 2007; 9:206

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2006\_Targeted\_Therapy\_for\_Brain\_Tumor.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2006_Targeted_Therapy_for_Brain_Tumor.pdf)
  
Targeted Therapy for Brain Tumors.   
Burzynski, S.R., In: Yang A.V.: Brain Cancer: Therapy and
Surgical Interventions. New York (NY); Nova Science Publishers,
Inc. 2006

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2006\_Treatment\_for\_Astrocytic\_Tumors\_in\_Children\_Ped%20Drugs.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2006_Treatment_for_Astrocytic_Tumors_in_Children_Ped%20Drugs.pdf)
  
Treatments for Astrocytoma in Children: Current and Emerging
Strategies   
Burzynski, S.R. Pediatric Drugs, 2006; 8:167-178

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2006\_Treatment\_of\_multicentric\_brainstem\_gliomas.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2006_Treatment_of_multicentric_brainstem_gliomas.pdf)
  
Treatment of multicentric brainstem gliomas with Antineoplastons
(ANP) A10 and AS2-1.   
Burzynski, S.R., Janicki, T.J., Weaver, R.A., Szymkowski, B.J.,
Khan, M.I., Dolgopolov, V.; Neurooncol. 2006; 10:466

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2006\_Complete\_response\_of\_a\_diffuse\_intrinsic\_brainstem.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2006_Complete_response_of_a_diffuse_intrinsic_brainstem.pdf)
  
Complete response of a diffuse intrinsic brainstem tumor and von
Hippel Lindau (VHL) disease to antineoplastons A10 and AS2-1
(ANP): a case report.   
Burzynski, S.R., Weaver, R.A., Szymkowski, B., Janicki, T.J.,
Khan, M.I., Dolgopolov, V. Neurooncol. 2006; 10:439

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2006\_Targeted\_Therapy\_with\_ANP\_of\_high\_grade\_brainstem\_glioma.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2006_Targeted_Therapy_with_ANP_of_high_grade_brainstem_glioma.pdf)
  
Targeted Therapy with Antineoplastons A10 and AS2-1 of
High-Grade, Recurrent and Progressive Brainstem Glioma.   
Burzynski, S.R., Janicki, T.J., Weaver, R.A., Burzynski, B.;
Integrative Cancer Therapies, 2006; 40-47

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2005\_Targeted\_therapy\_with\_ANP\_in\_children\_less\_than4.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2005_Targeted_therapy_with_ANP_in_children_less_than4.pdf)
  
Targeted therapy with ANP in children less than 4 years old with
inoperable brain stem gliomas.   
Burzynski, S.R., Weaver, R.A., Janicki, T.J., Burzynski, B.,
Jurida, G; Neurooncol. 2005; 7:300

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2005\_Long\_term\_survival\_in\_patients\_with\_glioblastoma\_multiforme.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2005_Long_term_survival_in_patients_with_glioblastoma_multiforme.pdf)
  
Long-term survival in patients with glioblastoma multiforme
treated in phase II studies with ANP.   
Weaver, R.A., Burzynski, S.R., Janicki, T.J., Burzynski, B.,
Jurida, G., Szymkowski, B. Neurooncol. 2005; 7:299

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2005\_Long\_term\_survival\_of\_high\_risk\_pediatric\_patients.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2005_Long_term_survival_of_high_risk_pediatric_patients.pdf)
  
Long-term survival of high-risk pediatric patients with
primitive neuroectodermal tumors treated with Antineoplastons
A10 AS2-1.   
Burzynski, S.R., Weaver, R.A., Janicki, T., Szymkowski, B.,
Jurida, G., Khan, M., Dolgopolov, V. Integrative Cancer
Therapies, 2005; 4(2): 168-177

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2004\_ANP\_in\_Dairy\_Products.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2004_ANP_in_Dairy_Products.pdf)
  
Antineoplastons In Dairy Products.   
Burzynski, S.R., Ilkowska-Musial, E., Klimczak M.W., Musial, L.;
Journal of Applied Nutrition, 2004; 54; 1-8

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2004\_Phase\_II\_studies\_ofANP\_A10\_and\_AS2\_1\_in\_children\_with\_a\_typical.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2004_Phase_II_studies_ofANP_A10_and_AS2_1_in_children_with_a_typical.pdf)
  
Phase II studies of antineoplastons A10 and AS2-1 (ANP) in
children with atypical teratoid/rhabdoid tumors (AT/RT) of the
central nervous system. A preliminary report.   
Burzynski, S.R., Weaver, R. Bestak. M., Janicki, T., Jurida, G.,
Szymkowski, B., Khan, M., Dolgopolov, V.; Neurooncol., 2004; 6:
427

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2004\_Long\_term\_survivals\_in\_phase\_II\_studies\_in\_patients\_with\_brainstem\_glioma.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2004_Long_term_survivals_in_phase_II_studies_in_patients_with_brainstem_glioma.pdf)
  
Long-term survivals in phase II studies of Antineoplastons A10
and AS2-1 (ANP) in patients with diffuse intrinsic brain stem
glioma.   
Burzynski, S.R., Weaver, R. Bestak. M., Lewy, R.I., Janicki, T.,
Jurida, G., Szymkowski, B., Khan, M., Dolgopolov, V.;
Neurooncol., 2004; 6: 387

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2004\_Phase\_II\_study\_of\_ANP\_A10\_and\_As2\_1\_in\_children\_with\_multicentric\_glioma.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2004_Phase_II_study_of_ANP_A10_and_As2_1_in_children_with_multicentric_glioma.pdf)
  
Phase II study of antineoplaston A10 and AS2-1 in children with
recurrent and progressive multicentric glioma. A Preliminary
Report.   
Burzynski, S.R., Weaver, R., Lewy, R., Janicki, T. Jurida, G.,
Szymkowski, B., Khan, M., Bestak, M.; Drugs R&D, 2004; 5
(6): 315-326

[**http://www.burzynskiclinic.com/assets/documents/Pub\_SRB\_2004\_Present\_State\_of\_ANP\_Research.pdf**](http://www.burzynskiclinic.com/assets/documents/Pub_SRB_2004_Present_State_of_ANP_Research.pdf)
  
The Present State of Antineoplaston Research.   
Burzynski, S.R.; Integrative Cancer Therapies, 2004; 3: 47-58.

**&c...**

---

[**http://ralphmoss.com/burzynski.html**](http://ralphmoss.com/burzynski.html)

**THE BURZYNSKI SAGA**

by Ralph Moss

Articles from seven years' worth of The Cancer Chronicles on
the trials and tribulations of Dr. Stanislaw R. Burzynski, M.D.,
Ph.D., a Houston physician and researcher:

1. Early Victory (1989)...  // 2. Dr. B. Faces U.S. Probe
(1990) // 3. Trials and Tribulations (1992) // 4. A Letter to
Morales (1992) // 5. A Patient's Son Speaks Out (1993) // 6.
Interview with an Orthodox Nurse (1993) // Rep. Porter Speaks
Out (1993) // 7. Grand Jury on the Move (1994) // 8. NCI
Director Fails to Credit Dr. B. (1994) // 9. Texas Raiders
(1995) // 10. Judge Restores License (1995) // 11. Lesson from
the Past (1995) // 12. A Visit to Houston (1996)

---

[**http://www.canceractive.com/page.php?n=1268**](http://www.canceractive.com/page.php?n=1268)

**Antineoplastons, missing Peptides and
Burzynski**

[ *icon* # 4 (2006) ]

**The work of Dr. Stanislaw Burzynski.**

AntineoFor almost 30 years one man has pioneered an alternative
therapy, originally for brain tumours but which now seems as
widely applicable to any cancer.  After threats, lawsuits
and raids on his premises he is finally being accepted into the
mainstream, with the FDA closely monitoring his work in clinical
trials and approval expected shortly. Chris Woollams reports.   
The case of the missing peptides

In 1970 a young Polish research scientist, Stanislaw Burzynski
MD, PhD, arrived as an Assistant Professor at Baylor College of
Medicine in Houston, Texas.

His prime interest - an interest that he had cultivated since
his time as a graduate student - were urinary peptides in blood
and urine (short chains of amino acids) and their anti-cancer
activities.

He had originally noticed a difference in peptide content
between the blood and urine of healthy people and that of cancer
patients. The fact that fascinated him was that normal healthy
individuals had much higher levels of certain peptides and that
these peptides not only helped in the process of communication
between cells (and thus identification of rogue cells), but were
also known to possess the ability to stop cancer growth in
vitro. Similar studies at Leeds University had shown the
presence of these peptides, but no follow-up analytical work was
done with them.

In case you dont know, peptides are short chains of amino
acids, whilst proteins are long chains of more than 50.

Quite early on in his work, he concluded that these peptides
somehow affect the unique biochemistry of the cancer cell. He
managed to isolate about 120 peptide fractions, amino acid
derivatives and organic acids for his studies. These he termed
antineoplastons, and he prepared four formulations (produced
synthetically), which were active against cancer cells.

It is now clearly understood that, in cancer, the ras gene can
cause a cancer signal to be made (genes that cause cancer are
called oncogenes). It is also known that another gene (p53)
normally suppresses tumours (and turns off the cancer process),
but somehow fails in cancer patients.

Burzynski showed that antineoplastons both turn off the ras
gene andrestimulate the p53 suppressor.  He thinks of
antineoplastons as switches turning some things off and others
back on. Antineoplastons provide the messages which tell the
genes to act.  Without enough of these crucial peptides the
risk of cancer is higher.

Antineoplaston peptides are made in various parts of the body,
but primarily in the liver and the kidneys. Two types exist:
ones with a very specific activity for specific tissues, and
others that have broad scale activity for a wide variety of
tissues.

A cancer patient has a double problem. They make far less of
certain peptides than are needed (probably because the genes
that control them are switched off by modern toxins or poor
diet); and also the cancer cell sends out messages to tell the
kidneys to excrete them, thus protecting itself.

**The FDA acts**

And then it all went pear-shaped. Burzynskis discoveries were
at first applauded and he was offered a higher post but in
Baylors Department of Pharmacologya job he turned down.

Almost immediately his research grant was not extended and he
was left outside of the system.

In 1983 he applied to the FDA for new drug permits for
antineoplastons, but was turned down. A lengthy legal battle
then took place which included the FDA raiding his offices.

Since there was no statute in Texas preventing him from
treating patients with this essentially non-toxic solution, he
set up shop for himself. However the US District Court then
banned him from shipping his product across state borders. Since
he couldnt stop patients from taking the product back to their
homes in other states, he was subjected to Grand Jury
investigation, and eventually tried on over 70 charges. One by
one he beat all of these and, 14 years later, the FDA and the
District Court gave in. An important part of the defence was
that these antineoplastons work!

**Brain tumours**

In 1991 a group of investigators from the National Cancer
Institute went to the Burzynski Research Institute in Houston
and reviewed his best 7 cases, where patients - mainly with
astrocytomas and glioblastomas - had experienced complete
responses to the drugs. The NCI recommended a Phase II
clinical trial, which began in 1993 and was overseen by such
eminent institutions as the Mayo Clinic and Sloan-Kettering
Cancer Center. However, only nine patients were assessed, and
the final report concluded that the results were insufficient to
recommend antineoplastons for wider use.

Burzynski was extremely unhappy, especially when he discovered
that the doses used had been far lower than those he was giving
his own patients. Indeed, he published a letter stating that the
levels used during the clinical trial were previously
established by him to be ineffective!

Meanwhile Burzynski undertook his own studies. In a study of 36
patients (all with brain tumours  some of highly malignant
glioblastoma multiforme) he produced the following results:

- 9 (25%) had a complete response, i.e., disappearance of the
tumour on an MRI scan.

- 7 (19.5%) had a partial response i.e. more than
50%    reduction on MRI scan.

- 12 (33.3%) were stabilized.

In his report Burzynski noted the general consensus in the
medical community is that these brain tumours cannot be cured by
chemotherapy, and the response rate is only modest. 
However he, himself, achieved a complete tumour resolution, or
over 50 percent tumour reduction, in 16 of his 36 patients.

Burzynski continues his efforts.  Currently he has over
2000 patients in full clinical trials now supervised by a more
agreeable FDA.  He has also recently won FDA approval for a
supplement for home use, but he stresses that this is not, by
any means, a replacement for formal therapy.

Burzynski is now highly confident that the FDA will fully
approve one of his oral formulations containing antineoplastons
by the end of 2007, with approval for an intravenous formulation
by the end of 2008.

**Alls well that ends well**

Currently researchers in Kurume University in Japan are also
exploring the effects of antineoplastons, not only with all
types of brain tumours, but also with colon and liver cancers.

Numerous genes have been identified and linked to a number of
cancers; others are specific to a certain type of cancer. 
Burzynski and the Japanese are studying which genes are blocked,
and which are over active with which cancers. It is early days
but the full picture may be less than ten years away and it
could have wonderful results. The highly prestigious MD Anderson
Cancer Center in Houston, confirm Burzynskis initial
antineoplaston theories, and have made it clear that there are
exciting developments in cancer cures outside of chemotherapy
nowadays.

Recently, Burzynski has developed new formulations, and
believes that far more active packages will be developed in the
future. Indeed he believes antineoplastons will eventually
become a mainstream treatment for all cancers.

At the end of the day, notwithstanding Professor Pilkingtons
work on Clomipramine, there is currently no totally effective
brain tumour chemotherapy drug, largely because the blood-brain
barrier is primarily there to prevent just such a chemical from
entering the brain. Nor is there adequate research on non-toxic,
natural therapies, but clearly these will have far better
potential to address problems within the brain. It is
increasingly felt likely by some experts that the only
successful treatment for brain tumours will be natural!

With regard to other cancers, the potential is enormous,
because generally cancer patients are deficient in certain
peptides. The only problem would be that if peptide production
cannot be restimulated (and this probably means finding a cause
for the lowered production in the first place) the peptide mixes
have to be taken by the patient for an extended period of time
with significant implications.  (Although probably far less
than, say, Herceptin and some of the other new drugs coming in).

The likelihood that Dr. Burzynski could be just another brick
in a wall of failure is very doubtful; far more possibly, he
could be on his way to a Nobel Prize with his pioneering,
non-toxic treatments and we are encouraged that the FDA is now
monitoring and reporting on his work.

We wish him well in his efforts.

The Burzynski Clinic is at:   
9432 Old Katy Road, Suite 200   
Houston Texas 77055-6330 USA   
Tel. (001)  713  335  5697   
Fax. (001)  713  335  5699   
Email: info@burzynskiclinic.com   
www.burzynskiclinic.com

---

[**http://www.alkalizeforhealth.com**](http://www.alkalizeforhealth.com)
  
[**http://www.jbs.org/tna.htm**](http://www.jbs.org/tna.htm)

**Dr. Ivy & Krebiozen, Dr. Burzynski
& Antineoplastons**

**by** **Robert W. Lee**

[ Copyright 1997, American Opinion Publishing, Inc., P.O. Box
8040, Appleton, WI 54913 ]

For more than a quarter century, Washington has waged a
high-profile "war" on cancer at a cost to taxpayers of some $30
billion. Figures recently reported in The New England Journal of
Medicine indicate how the battle is progressing: Between 1970
and 1994 (the latest available figures), the cancer rate
increased by six percent. Similarly, in 1995 the National Cancer
Institute (NCI) reported that when frequency of the disease
during the period 1975-79 was compared with that for 1987-91,
the incidence among males was up 18.6 percent, and that for
females increased by 12.4 percent.

This apparent lack of progress in coping with the dread disease
is especially disturbing when one considers the amount of time,
effort, and resources expended by the orthodox medical community
- including the American Medical Association (AMA), the American
Cancer Society (ACS), and the Food and Drag Administration (FDA)
- on frenetic efforts to delay or derail promising alternatives
to the entrenched regimen of surgery, chemotherapy, and
radiation.

Assaults on such non-traditional remedies as laetrile (the
science and politics of which were analyzed by G. Edward Griffin
in World Without Cancer) and krebiozen come readily to mind. The
most notable advocate of krebiozen, which at one time had nearly
20,000 case-history endorsements, was Dr. Andrew C. Ivy, onetime
chairman of the University of Illinois clinical sciences
department. Dr. Ivy's "establishment" medical credentials were
impeccable. He had authored more than 1,000 articles published
in scientific and medical journals, had served as a U.S.
representative at the post-World War II Nuremberg trials, and
had received bronze, silver, and gold medals from the AMA for
his achievements. Even the FDA had sought his medical testimony
on occasion for judicial proceedings.

But once Dr. Ivy began advocating an unorthodox cancer therapy,
he was promptly derided as a "quack." At the behest of the FDA,
he and three associates were indicted in 1964 on 49 criminal
counts for violations of the Food, Drug, and Cosmetic Act, mail
fraud, mislabeling, making false statements to the government,
and conspiracy related to the production and distribution of
krebiozen (which the agency had outlawed the year before). FDA
chemists claimed that krebiozen was simply a common amino acid
found in man and animals.

The subsequent trial, which lasted from April 19, 1965 to the
end of January 1966, cost taxpayers an estimated $3 to $5
million. During the trial a letter was read into the court
record by a doctor who claimed that while treating a cancer
patient he had obtained krebiozen from Dr. Ivy's laboratories,
and had administered it to a patient, but that the substance had
done absolutely no good whatsoever. Under cross-examination,
however, he eventually admitted that he had never treated such a
patient and had never used krebiozen. Asked why he had lied, he
replied that an FDA agent had written the letter and asked him
to sign it, which he did because he wanted to help the agency
put an end to "quackery." Lies and deception, needless to say,
are the very essence of authentic "quackery."

When the jury rendered its verdicts, Dr. Ivy and the others
were acquitted on all counts. Indeed, the jury added that it
believed krebiozen had merit. Yet as journalist and author
Michael L. Culbert notes in Freedom From Cancer, "the propaganda
campaign paid off, and krebiozen was left in the public mind as
another unproven cancer remedy and Dr. Ivy was
character-assassinated into the limbo reserved for pioneers who
dare operate outside of the medical-governmental axis."

Which leads us to the contemporary case of Dr. Stanislaw R.
Burzynski, founder of the Houston-based Burzynski Institute that
treats cancer patients with substances called antineoplastons.
On May 27th, after less than three hours of deliberation, a
federal jury in Houston acquitted Burzynski on the single
remaining count of the 75 for which he and his clinic had been
indicted by a grand jury in 1995. It was Burzynski's second
trial this year. The first, which began in early January,
entailed 20 days of testimony by more than 80 witnesses
regarding 34 counts of mail fraud, 40 counts of introducing
antineoplastons illegally into interstate commerce, and a single
contempt-of-court count alleging that Burzynski and his clinic
violated a 1983 federal court order precluding such interstate
dispersion of the drugs.

U.S. District Court Judge Simeon T. Lake III, who also presided
at the second trial, declared a mistrial after an evenly divided
jury deadlocked on all 75 counts. Lake then issued a directed
verdict of acquittal on the 34 mail-fraud counts, asserting that
the evidence presented by the government did not come close to
justifying a conviction. Federal prosecutors announced that they
would retry Burzynski and the clinic on the remaining 41 counts,
but on May 19th (the day before the second trial began) they
tossed in the towel on all 40 of the counts related to
interstate commerce. Since the clinic was also dropped from the
case, Dr. Burzynski alone was retried on the remaining contempt
charge. Following Dr. Burzynski's acquittal, juror Stephenie
Shapiro told reporters, "I just don't think that the state
proved their case .... It was very unanimous from the beginning.
It's not like anybody had to be talked into it."

Weeks earlier, on April 18th, L. Darlene Phillips, a juror in
the first trial, wrote to Attorney General Janet Reno to express
her disgust at "how my time and tax dollars were wasted on this
trial." She noted, "On two separate occasions the FDA had
confiscated a total of 300,000 documents (i.e., patient records,
MRI scans, progress charts, etc.) and for Dr. Burzynski to be
able to continue to treat his patients, he had to purchase a
Xerox machine, install it at the FDA office, hire someone to
make copies, and to make it even more difficult, he was required
to call a day in advance to make an appointment for copies to be
made. To this day these documents have not been returned."
Phillips also reminded Reno that Amy Lecocq, lead prosecutor for
the first trial, "violated at least six federal laws governing
subpoenas of journalists when she subpoenaed Dr. Ralph Moss, PhD
[who had written favorably of Dr. Burzynski]. When he pointed
this out to her, she withdrew the subpoena." The blatantly
illegal, broad-brush subpoena had sought to compel Dr. Moss to
produce every document in his possession - electronic, magnetic,
printed, or otherwise - relating to Dr. Burzynski.

Ms. Phillips further pointed out that "the prosecution failed
to introduce even one witness who could say anything defamatory
about Dr. Burzynski's character." She added: "One would think
after four years of preparing for this trial they would have
found at least one disgruntled patient, former employee,
business associate, or colleague who had something negative to
say about him." Phillips wondered if "our government has real
'criminals' to prosecute," and implored the Attorney General to
"put a halt to the nonsense of a retrial by our federal
government (namely the FDA) of Dr. Burzynski."

Phillips' plea fell on deaf ears: Reno refused to intervene.

Had Dr. Burzynski been convicted of all 75 counts in the
original indictment, he could have received up to 290 years in
prison and been fined in excess of $18 million. Today, for the
first time since the grand jury issued its indictment, he is a
fully free man. No longer is he under the cloud of a $100,000
bail bond, nor does he have to report to the federal courthouse
every two weeks, nor seek permission to travel out of state.

Born in Poland in 1943, Dr. Stanislaw Burzynski received his
medical degree in 1967 from the Medical Academy of Lublin,
ranking first in a class of 250. He earned a doctorate in
biochemistry the following year. It was while working on his
dissertation project that he identified certain naturally
occurring peptides (protein fragments comprised of two or more
amino acids) which he concluded might have something to do with
controlling cancer. Persons afflicted with the disease, he
noticed, typically had lower blood levels of the peptides -
which he later termed "antineoplastons" - than did healthy
individuals.

When he refused to join the Communist Party (virtually a
prerequisite for academic advancement at the time), Burzynski
was drafted into the Polish army for an indefinite period which
precluded the opportunity to conduct meaningful research on his
discovery. In 1970, with the help of influential fellow
scientists, he emigrated to the United States, where he would
eventually encounter more harassment and persecution at the
hands of the FDA and the Justice Department than he had under
Poland's Red regime.

From 1970 to 1977 he was a researcher and assistant professor
at Baylor College of Medicine in Houston, where his research was
sponsored and partially funded by the National Cancer Institute
(NCI). It was during this time that he fleshed out his theory
that the peptides he had stumbled across in human blood and
urine (he now produces them synthetically) could correct and
normalize certain types of malignant neoplastic (tumor) cells.
Thus the term "antineoplastons." "We are no longer concerned
with killing cells," he asserts, "but with changing the program
inside the defective cell so that it will begin to function
normally."

Most experts agree that we all probably develop cancer millions
of times during our lifetime. With trillions of maturing cells,
millions of errors can and likely do occur, a problem further
aggravated by exposure to thousands of chemical carcinogens, and
such physical factors as radiation, bacteria, viruses, and
unhealthy stress, that have plagued mankind throughout time.
Normal cells, Burzynski explains, specialize to serve particular
purposes. Once that specialization occurs, they no longer divide
to form new cells. They do what they have been programmed to do,
then fade and die, to be replaced by new cells.

Some cells, however, are affected by carcinogens and other
disrupting influences that cause them to become, in a sense,
both destructive and "immortal." They neither specialize nor
die, but continue dividing until they overwhelm normal cells.
The result is cancer, which Dr. Burzynski contends is
essentially a disease of cell differentiation. "It is obvious,"
he points out, "that everybody would develop cancer if we didn't
have a certain protective system in the body. This is the
biochemical protection system .... Antineoplastons correct the
program inside the cell and force it toward normal development"
by serving as "biochemical micro-switches" that turn off
oncogenes (the genes, found in all cells, that are responsible
for cell malignancy) and turn on tumor-suppressor genes that
stop them.

The concept that cells can be reprogrammed from abnormal to
normal, precluding the need to eliminate them, may explain much
of the opposition that Dr. Burzynski has encountered from
orthodox medicine and its FDA enforcement arm. The theory offers
an alternative to the surgery-chemo-therapy-radiation approach
which holds that cancer cells must be either destroyed on-site
or excised. As Dr. Julian Whittaker, MD, editor of the
newsletter Health & Healing, wrote in March of this year,
"Though the FDA is the obvious 'point-man' in the persecution of
Dr. Burzynski, the real force is coming from the cancer
treatment establishment. Just imagine all the physicians,
technology, and medical facilities that feed off chemotherapy,
radiation therapy, and surgery. They are now threatened by a
more effective and less dangerous therapy that can be
administered in a doctor's office or by patients at home."

THE NEW AMERICAN is not qualified to reach conclusions
regarding the scientific validity of Dr. Burzynski' s
antineoplaston theory. However, since opening his private clinic
in Houston in 1977, he has treated some 3,000 advanced cancer
patients, most of whom turned to him after exhausting
conventional treatments. Hundreds are convinced that
antineoplastons literally saved, or have significantly extended,
their lives, without the debilitating side effects
characteristic of such conventional therapies as radiation and
chemotherapy.

Consider, as one example, the case of Dustin Kunnari. In
February 1994, when he was two and one-half years old, Dustin
was diagnosed with an aggressive type of brain tumor called
medulloblastoma. It is the second most common brain tumor found
in children, and whether treated with conventional therapy or
left untreated entails a life expectancy of only one to four
years. Three-fourths of Dustin's tumor was removed surgically,
after which his parents, Jack and Mariann of Aurora, Minnesota,
were encouraged to enroll him in a study at the University of
Minnesota that would initially treat his cancer with
chemotherapy, then radiation. The possible side effects, they
were informed, included hearing loss, stunted growth, hair loss,
learning disabilities, sterility, and leukemia. They were,
however, assured that the success rate of such therapy reached
as high as 40 percent. But when they requested a few names of
those parents whose children had been successfully treated, so
they could confirm the results firsthand, their request was
denied.

The Kunnaris opted not to enter Dustin in the program, electing
instead to give Dr. Burzynski's treatment a try. It is called
freedom of choice, but it goes down hard with establishment
medicrats. Jack Kunnari told THE NEW AMERICAN that when they
sought to retrieve Dustin's medical records from the University
of Minnesota, they were told that in medical cases the opinions
of doctors take precedent over those of parents, and that they
could be taken to court unless they agreed to enroll Dustin in
the study. "Until the day we left for Houston, there were still
threats coming," Mr. Kunnari recalled.

Dustin's antineoplaston treatment began in April 1994. Within
six weeks an MRI (Magnetic Resonance Imaging) scan showed
complete remission of the tumor. Following another year of
treatment, another MRI indicated that the tumor was recurring.
The dosage of antineoplastons was increased, and the tumor once
again receded. According to Dustin's latest MRI on May 1 st of
this year, the tumor remains in remission. Indeed, he was
recently taken off intravenous administration of the drug and is
presently receiving only a maintenance dosage via capsules. His
parents describe him as a robust and basically healthy
six-year-old. The side effects of the therapy have been nil.

The government's prosecution of Dr. Burzynski, which raised the
specter of losing their only source for a drug they are
convinced has been of enormous benefit to their son, intensified
the Kunnaris' anguish - and their anger. "I guess we were always
aware," Jack Kunnari told THE NEW AMERICAN, "that if you go with
an alternative [therapy] there would be some opposition. But we
never dreamed it would be as intense as it has been. From the
time the first MRI showed that Dustin's tumor was gone, there
was the feeling that we had accomplished something. We stood up
for what was best for our son. We stood up to the University of
Minnesota despite the legal threats and such. It was a feeling
of such joy and appreciation. Then you get hit with these
indictments and court rulings against Dr. Burzynski." Mr.
Kunnari recalls that "we had just gone through an emotional
fight to get our son to the point where the tumor was gone,
restore him to a measure of health, and now our government was
stepping in and we had to fight it. I don't know how you can
explain the range of emotions, but I guess the best way to
describe it is a roller-coaster ride. Initially, your son has a
brain tumor, so you're down and feeling pretty bad about things.
Then you find out about this doctor and you get a feeling of
hope, the MRI looks good, and your hope increases. And then the
government steps in and says you can't have the treatment."

In a February 19, 1997 letter to Judge Lake, Dr. Robert E.
Burdick, MD, summarized his review of 17 Burzynski patients
(among 40 of his patients with brain tumors who were included in
an FDA-approved trial one year earlier) who had responded to
treatment with antineoplastons. Dr. Burdick has practiced
medical oncology for nearly three decades and is on the faculty
of the University of Washington Medical School. After noting the
"frustrations that neuro-surgeons, radiotherapists, and we
medical oncologists have regarding our ineffective treatment of
malignant brain tumors," and presenting a brief overview of the
sundry types of malignant tumors, Dr. Burdick noted that it "is
very rare, currently, to ever get a complete remission or cure
in a patient who has a malignant brain tumor using our standard
modalities of surgery, radiation, and chemotherapy. By the time
a tumor is large enough to be clinically detected, it has
involved such critical structures that to remove it surgically
would result in a patient who is left in a vegetative state or
is markedly more disabled than he was prior to the surgery."

Dr. Burdick noted that, "as a rough estimate, neurosurgeons do
well to cure 1 in every 1,000 brain cancer patients they operate
on. Radiation therapy slows the growth of adult tumors, gaining
perhaps one month of life and again may result in a cure of only
1 in 500-1,000 patients, those cures being in the pediatric age
group. Similarly, chemotherapy research, despite 30 years of
clinical trials, has not resulted in the development of a single
drug or drug combination that elicits more than an occasional
transient response in primary brain tumors .... In fact,
chemotherapy in brain tumors is so discouraging that in many
parts of the country patients with brain tumors are not even
offered the option of chemotherapy."

Based on his careful analysis of each of the 17 patients in the
study who responded to treatment with antineoplastons, Dr.
Burdick found that "there were 7 complete remissions, one
patient having had a second complete remission after he
discontinued antineoplaston therapy which resulted in his tumor
regrowing. There were nine partial remissions, two cases of
stable disease, and no disqualifications. The average duration
of therapy with antineoplastons necessary to obtain a complete
remission was 10 months with a range of 2 to 20 months. The
average duration of antineoplaston therapy necessary to obtain a
partial response was 8 months with a range of 1 to 14 months.
The average duration of complete remissions is 16+ months with
all six complete remissions continuing to remain in remission to
the best of my knowledge through January 1, 1997. The duration
of complete remissions ranged from 3+ months to 40+ months with
the duration of partial remissions averaging 18+ months and
ranging from 5 to 78+ months."

Summing up, Dr. Burdick told Judge Lake that he was "very
impressed with the number of complete and partial responses that
I have seen here, compared with the number of such responses
that I have seen in my own personal experience. The responses
here are also far in excess of any prior series of patients
published in the medical literature." Even after two patients
were subsequently downgraded from "partial remission" to "stable
disease," the response rate (partial or complete remissions) was
"an astounding 33% with a complete remission rate of 15%. Such
remission rates are far in excess of anything that I or anyone
else has seen since research work on brain tumors began." Dr.
Burdick asserted that it "is very clear that the responses here
are due to antineoplaston therapy and are not due to surgery,
radiation or standard chemotherapy." He concluded that research
"needs to continue on these very promising agents," to determine
such things as "the optimal dose of these agents, the optimal
route of administration, the optimal duration of treatment and
many other details too numerous to mention."

Dr. Burzynski opened his clinic in 1977. Prior to 1985, FDA
drug-approval procedures were not incorporated into Texas law,
so he was advised by his attorney that he could treat patients
with innovative medicine as long as he did not engage in
interstate commerce. In The Cancer Industry, Dr. Ralph Moss
recalls that Burzynski would have preferred to obtain FDA
approval, but the roadblocks inherent in the agency's process
were virtually insurmountable. The normal process, Moss writes,
"is for a new substance to be discovered at a major medical
center and then turned over to a drug company for development.
If the company decides it is economically feasible, it will then
battle its IND [Investigational New Drug] application through
the FDA." But even then "it is often unsuccessful."

Since none of the drug companies expressed an interest in
Burzynski's compounds, he opted to develop them himself. But
Moss writes that with virtually no capital with which to finance
a run through the FDA maze, Dr. Burzynski "was caught in a
classic catch-22 situation. If he tested antineoplastons in
humans, the FDA was sure to come down on him eventually. But if
he didn't so test them, he could never win FDA approval, since
antineoplastons, being species-specific, are not generally
effective in animal treatment experiments." The Declaration of
Helsinki, adopted in 1964 by the World Medical Assembly and
subsequently endorsed by Congress, states: "In the treatment of
the sick person, the doctor must be free to use a new
therapeutic measure, if in his judgment it offers hope of saving
life, reestablishing health, or alleviating suffering."
Burzynski decided to treat patients, compile thorough records,
finance future development of the drugs with patient fees, and
take his chances with the FDA.

The FDA first visited Burzynski's facilities in 1978. The event
was, in sharp contrast to the harassment and legal turmoil that
would follow, quite congenial. Burzynski is first to admit that
his manufacturing process at the time was rather amateurish, and
that the FDA's constructive criticisms enabled him to make
needed improvements.

At the time, most of his problems were emanating from the local
medical establishment. Moss writes: "In 1978 Burzynski became
the focus of an investigation by the Board of Ethics of the
Harris County Medical Society. The charge was using unapproved
medications of his own devising. They repeatedly called him in
for interviews and instructed him not to give any interviews to
the press." Burzynski complied with the press blackout, but in
1979 Penthouse magazine ran an article entitled "The Suppression
of Cancer Cures," which described his plight, and in 1981 ABC' s
20/20 featured a segment entitled "The War on Cancer: Cure,
Profit or Politics?" during which commentator Geraldo Rivera
asserted: "The deeper we looked into the story, the more we
realized that Stanislaw Burzynski is really not a maverick at
all. His work is very much in the scientific mainstream, that
burgeoning field of cancer research that's pin-pointing the
body's own natural materials, its own proteins, to control
irregular cell growth...."

In the wake of such national publicity, hundreds of cancer
patients began visiting the Houston clinic for treatment, and no
more was heard from the local Board of Ethics. Trouble at the
national level, however, was beginning to metastasize.

In 1983, the American Cancer Society placed Dr. Burzynski on
its "unproven methods" blacklist of practitioners with which it
disagrees. Later in the year, the FDA filed civil suit in
federal court to stop him from manufacturing, or treating
patients with, antineoplastons. An indication of the FDA's
arrogant attitude was reflected in a motion dated May 2, 1983,
in which its chief counsel for enforcement warned, "If this
court declines to grant the injunctive relief sought by the
government, thus permitting continued manufacture and
distribution of antineoplastons by defendants ... the government
would then be obliged to pursue other less efficient remedies,
such as actions for seizure and condemnation of the drugs or
criminal prosecution of individuals...." U.S. District Court
Judge Gabrielle McDonald barred Burzynski from shipping the drug
outside the state, or otherwise introducing it into interstate
commerce, but authorized him to treat patients within the state
of Texas. "Nothing contained heroin shall be construed as
restraining, enjoining or in any way prohibiting the
manufacture, processing, packing, holding, promotion, labeling,
sale or distribution of antineoplastons ... when it is
undertaken strictly and wholly intrastate," her order stated.
This partial victory for Dr. Burzynski infuriated the FDA, which
promptly moved to circumvent the court order and, it hoped,
close down the clinic. When Dr. Burzynski and some of his
patients filed suit against the agency in the hope of ending the
harassment, Judge McDonald rejected their request to allow a
jury to hear their case, but did find that the FDA had
disseminated false and misleading information about Burzynski to
prospective patients, insurance companies, and public officials.
Her October 24, 1985 ruling demanded that it stop doing so.

It was earlier that year that FDA agents raided Dr. Burzynski's
clinic and seized more that 200,000 pages of documents,
including patient records. Without the records, Burzynski was
seriously hamstrung in treating his patients. As noted earlier,
he was required to install a copier at FDA headquarters, at his
expense, and make appointments in advance to photocopy the
needed records.

In 1986, an additional 100,000 documents were subpoenaed for
the first grand jury investigation of his activities. After
scrutinizing the evidence, the grand jury declined to indict.

Judge McDonald's 1983 partial injunction stated that "the
jurisdiction of this court is retained for the purpose of
enforcing or modifying this injunction and for the purpose of
granting such additional relief that hereafter may appear
necessary or appropriate." Which meant that government
prosecutors had a civil-remedy alternative to criminal
prosecution regarding the key question (on which the other
charges were based) of whether or not Dr. Burzynski had violated
Judge McDonald's directive. As interpreted by Burzynski, the
order did not bar his clinic from providing antineoplastons to
patients from out of state who traveled to Houston to pick them
up, then returned home. He was treating such patients within
Texas, and neither he nor the clinic were shipping the drugs
elsewhere. Nor, he contended, did the court order apply in
instances where patients themselves could not, for health or
economic reasons, make trips to Houston, so had representatives
(friends, relatives, etc.) secure supplies of the drug from the
clinic on their behalf.

Judge McDonald's order did not specifically preclude such
activity, but the government argued that it was illegal for
Burzynski or his clinic to provide antineoplastons to persons
whom they knew would then travel with or ship the drugs beyond
state borders.

Federal law required that Judge McDonald's order be "of
reasonable specificity," but on this key point it was imprecise.
The government could have asked her to clarify the matter by
restating her intent, but it did not. As Gary Anderson, a juror
in the second trial, explained, "What we felt was that the order
was ambiguous. And it was our feeling that he [Burzynski] made
an attempt to do what he thought he should be doing." Indeed,
Burzynski had never tried to hide the fact that he was treating
persons from other states at his clinic. Their home addresses
were listed on the paperwork he had been submitting to the FDA
for years.

In 1990, a second grand jury was convened in yet another
attempt by the FDA to garner an indictment, but it, too, cleared
Burzynski.

In 1994, a third grand jury was convened. Again, there was no
indictment, but an Assistant U.S. Attorney assigned to the case
was dismissed after local reporters discovered that he had
subpoenaed the campaign contribution records of a local
politician who was a fervent Burzynski supporter, then leaked to
the press a false story indicating that misuse of campaign funds
was part of the ongoing investigation of Burzynski.

Up to that point, then, three separate grand juries had
scrutinized the Burzynski record and had refused to indict him
on so much as a single count. It was a remarkable series of
victories for the beleaguered physician, since, as
Representative Joe Barton (R-TX), chairman of the Subcommittee
on Oversight and Investigations of the House Committee on
Commerce, noted in a September 7, 1995, letter to Attorney
General Reno, "It is extraordinarily rare for a grand jury to
fail to indict at the request of the U.S. Attorney. As far as I
know, a grand jury failing to indict some three to four times on
essentially the same base of facts is virtually unprecedented.
It would appear that the FDA and the Justice Department are
abusing the grand jury process to harass and punish Dr.
Burzynski for persuading a federal judge that he is not
violating the law by practicing medicine within the State of
Texas."

In 1994, the FDA's oncology division granted Dr. Burzynski
permission to conduct four Phase II (efficacy) clinical trials
on antineoplastons. FDA inspectors scrutinized and approved his
manufacturing facility. It appeared that a truce between the two
sides may have been reached. Then, on March 24, 1995, Dr.
Burzynski appeared on the CBS program This Morning with three
patients whose cancers had been diagnosed as terminal years
earlier, but who now claimed to be free of the malignancies
following treatment with antineoplastons. That afternoon the FDA
again raided the Burzynski clinic, spending some seven hours
rummaging through file cabinets, drawers, and computers, and
eventually hauling off numerous boxes crammed with documents. It
was the first step on the road to a fourth (this time
successful) attempt by the FDA to secure a grand jury
indictment.

For eight months, subpoenas were issued to Dr. Burzynski, many
of his present and former employees, and other persons with whom
he had been associated or who had spoken or written favorably
about his work. It was after publishing a letter vigorously
condemning the March raid that author Ralph Moss was served with
the bogus subpoena covering every document in his possession
relating to Dr. Burzynski.

On November 15, 1995, FDA Commissioner David Kessler testified
before the Barton subcommittee. Questioned about the Burzynski
case, Kessler vigorously denied that there was a pattern of
retaliation against the physician. Five days later, the U.S.
Attorney's office in Houston announced the 75-count indictment
by the fourth grand jury.

There is no need to reprise the testimony from the enormously
expensive trial. Judge Lake's directed verdict of acquittal on
the mail fraud counts, the prosecution's decision to drop the
interstate commerce charges, and Burzynski's swift acquittal on
the contempt charge speak for themselves. It should be noted,
however, that since late 1996 the FDA, perhaps prodded by
pressure generated by the Barton hearings, has allowed the
Burzynski clinic to register patients, including those from out
of state, under dozens of study protocols qualifying them to
receive antineoplastons by mail. Which means that at the time he
was twice standing trial for contempt of an ambiguous, ancient
court order that supposedly barred him from introducing
antineoplastons into interstate commerce, he was legally
authorized to ship the drugs to patients anywhere in the
country. Jurors, at least those in the first trial, were not
told about it.

Constitutional authority Dan Smoot once observed, "A nation
which values anything - even good health - more than it values
freedom will lose its freedom." Needless to say, the best
prescription for good health is freedom - freedom to choose the
type of medical care one prefers, from the practitioners one
prefers, who provide medications and other services one prefers.
A truly free market in health care would enable innovators such
as Dr. Burzynski to make a case for their discoveries in
competition with others both within and without the "orthodox"
medical establishment, unhindered by a dictatorial government
bureaucracy that, in the name of protecting our health, often
undermines it.

**Testing Antineoplastons**

In 1991, results of an FDA-approved Phase II (efficacy) trial
involving 20 patients with varying stages of astrocytoma (the
most common brain tumor in children) were published by Dr.
Burzynski in Recent Advances in Chemotherapy. Nineteen had
received one or more prior standard therapies to which their
tumors did not respond. There was complete remission of the
tumors in four patients, partial remission in two others, while
ten others were diagnosed with "objective stabilization" (less
than 50 percent decrease in tumor size). Later, two of the ten
patients in that latter category improved to the point that one
was reclassified "partial remission" and the other "complete
remission." All told, 16 of the 20 patients stabilized or
improved, a startling result considering the severity of their
conditions when the trial began.

In September of last year, Dr. Burzynski submitted brain scans
of 29 of his clinical trial patients for review by a
neuroradiologist at the Barrows Neurological Institute in
Phoenix, Arizona. All 29 had been diagnosed as terminal when
their treatment with antineoplastons began. A subsequent report
noted complete remissions in 13 patients, partial or initial
responses in eight others, and no response to the treatment in
the remaining eight.

There are also some indications, though at present based solely
on animal studies, that in addition to treating some types of
cancer, antineoplastons may also be helpful in preventing them
from developing in the first place. Researchers at the Burzynski
Clinic and at Japan's University of Kurume Medical School both
found indications that low doses of a synthetic form of one type
of antineoplaston administered orally prevented lung, breast,
and liver cancers in the test animals. - R.W.L.

---

  
[**http://scienceblogs.com/insolence/2014/01/21/stanislaw-burzynskis-counteroffensive-against-the-fda-and-texas-medical-board-continues/**](http://scienceblogs.com/insolence/2014/01/21/stanislaw-burzynskis-counteroffensive-against-the-fda-and-texas-medical-board-continues/)January 21, 2014  
  

**Stanislaw Burzynskis counteroffensive
against the FDA and Texas Medical Board continues**

  
The year 2013 finished with serious setbacks for Stanislaw
Burzynski and his unproven cancer treatment that he dubbed
antineoplastons (ANPs) way back in the early 1970s. As you might
recall, in November, two things happened. First, the FDA released
its initial reports on its inspection of the Burzynski Clinic and
Burzynski Research Institute (BRI) carried out from January to
March 2013. They were damning in the extreme, pointing out the
shoddy operating methods of the institutional review board (IRB)
used by the BRI to approve and oversee Burzynskis clinical
trials (and I use the term loosely) of ANPs. Violations included
using expedited approvals to review single patient protocols,
something so far outside the purview of what the expedited
approval process was intended for, namely approving minor tweaks
to human subjects research protocols without requiring a full
meeting of the IRB, that the FDA called Burzynski out for it.
Other violations included failure to report serious adverse events
(SAEs) and adverse events (AEs) to the FDA and/or the IRB, failure
to follow proper informed consent procedures, failure to determine
that risks to subjects were minimized and that risks to subjects
were reasonable in relation to anticipated benefits, if any, and a
lot of other violations listed in my post on the subject.  
  
Later in November, Liz Szabo of USA TODAY published a fantastic
expose of Burzynski entitled Doctor accused of selling false hope
to families, in which, in addition to many of the violations
revealed by the FDA, it was further reported that the child whose
death in the summer of 2012 triggered the FDA investigation was
Josia Cotto, and that the child died of hypernatremia (elevated
sodium levels in the blood) caused by ANP therapy. In response to
the reports of shoddy record keeping, lack of ethics, and
contributing to the death of a child, Burzynski was his
characteristically cuddly self, referring to his critics as
hooligans and hired assassins, while claiming that they
pretend they got sick and would like to extort money from us.
When last I wrote about Burzynski in November, his empire was
struggling to strike back. Eric Merola, the film maker responsible
for two pro-Burzynski propaganda movies Burzynski: Cancer Is A
Serious Business and Burzynski: Cancer Is A Serious Business, Part
2, likened USA TODAY to everything from Nazi propaganda under
Joseph Goebbels, to slave masters, and to the Westboro Baptist
Church protesting at the funerals of gay soldiers killed in the
line of duty. Meanwhile Burzynski himself tried to answer the FDA
findings and failed miserably, nor did his poster presentation of
singularly unimpressive results at the Society of Neuro-Oncology
Meeting right before Thanksgiving help. The year ended with the
Texas Medical Board using the FDAs findings as part of the basis
of charging Burzynski with false advertising, meaning that
Burzynski will be spending a lot of time defending himself against
the TMB in 2014.  
  
Unfortunately, beginning in December, Burzynski and his allies
decided to go back to the future, so to speak (or maybe just back
to the 1990s) and resurrect the campaign that worked so well for
them the last time Burzynskis back was against the wall.
Unfortunately, this strategy, rooted as it is in using cancer
patients to lobby Congress to force the FDA to allow Burzynski to
use antineoplastons, could work. Pro-Burzynski forces, in a nod to
the past, have even hired the same lobbyist who, or so it is
claimed by the pro-Burzynski forces, so brilliantly in the
mid-1990s in persuading Rep. Joe Barton (R-TX), then the chair of
the House Subcommittee on Oversight and Investigations, to
investigate the FDAs harassment of Burzynski.  
  
If you want to understand Burzynskis new strategy to keep using
ANPs, you have but to go back and examine his previous strategy,
which was to milk dying cancer patients for every bit of human
sympathy they can evoke from lawmakers and the public. Everything
old is new again, as Burzynski replays the same strategy with
patients such as McKenzie Lowe, Liza Cozad, and Elisha Cohen.  
  
Meanwhile those of us who stand up and say no, who try to point
out that Burzynski cant save these patients, that they are being
used by him so that he can re-open his ANP clinical trials, are
pummeled with arguments like the one by Randy Barnes that we
should respect the parents choice. After pointing out that he
is not a fan of the Burzynski Clinic, and agrees with many of
the criticisms leveled at Stanislaw Burzynski and his treatments,
he asserts that Raphael Elishas parents are the only ones with
the right and responsibility to make the best decisions they can
in a horrible situation that no one who has not faced the loss of
a child can possibly understand. He then concludes:  
  
    If you choose not to sign the petition that is
fine, but please, allow the Cohens the dignity they deserve by
respecting their right to make the choices they deem fit for their
child. Publicly fighting the Burzynski Clinic in Raphael Elishas
name will only bring more pain to an already suffering family.   
  
This is the argument were up against as well, an argument that is
every bit as invalid as when it is used to defend, for example,
the family of Sarah Hershberger for relying on quackery instead of
chemotherapy to treat a deadly lymphoma. We can respect the
parents decision, to the extent that they are the parents. We can
try to understand the desperation that led them to it, even though
they are aware of all the criticisms of Burzynski. Most parents
can only imagine how they would react under similar circumstances.
Even I couldnt guarantee that I wouldnt be tempted by the
blandishments of Burzynski and his followers if I were in the same
position as the Cohens. However, sympathy and respect do not equal
agreement, nor do they require us to acquiesce and just shut up
when the Cohens grief and desperation lead them to do something
profoundly harmful to public health, to use the power of their
story to persuade lawmakers to call off the FDA.  
  
Its not just sympathetic families being used by Burzynski to
further his cause, however. Right after the holidays, one of the
most prominent pro-quackery advocacy groups in the world, the
Alliance for Natural Health USA, launched a series of attacks and
posts urging its supporters to write to their legislators to put
pressure on the FDA to allow compassionate use exemptions for
antineoplastons (ANPs). Also included is a smear campaign against
Liz Szabo, Burzynski skeptics, and, of course, USA TODAY, all of
whom are portrayed as being in the thrall of big pharma. I do
note, with some mild amusement, that here was one article posted
on the ANH-USA website claiming that the FDA violated patient
privacy by providing Szabo with medical records of a patient
without the parents permission. If you click on the link now,
theres nothing there. The article has apparently been taken down.
there are, however, multiple links to it elsewhere, for example,
here, here, here (our old friend Merola) and here. The article
still shows up on the ANH sitemap, but theres nothing there.
Apparently, the ANH took it down, which is probably because it was
full of misinformation and lies. I only wish I had saved a
screenshot or web archive of the article. My mistake.  
Bringing it all together: The ANP Coalition  
  
Its taken nine months since Burzynski supporters revealed in a
video of the panel discussion after a screening of Eric Merolas
movie that various Burzynski patient groups were planning to form
an organization to lobby Congress for fast track approval of ANPs.
Indeed, Merola and his merry band of Burzynski sycophants were
quite open about wanting fast track approval for ANPs so that
Burzynski could then prescribe them off label for virtually any
cancer and presumably could also sell them to any doctor who
wanted to use them for whatever purpose. Of course, advertising a
drug for off label uses is against the law, which is why the FDA
takes such a dim view of it, but word of mouth and ANP-friendly
groups like the ANH would make sure that word got around fast.
Unfortunately for Stash, with the deficiencies of the procedures
of the Burzynski Clinic and BRI with respect to running clinical
trials having been laid bare in Liz Szabos article in USA TODAY,
fast track approval for ANPs for glioblastoma is, at best, highly
unlikely. So Burzynskis allies have fallen back on lobbying
Congress to lean on the FDA to allow single patient protocols,
sometimes called compassionate use protocols, to allow Burzynski
to treat patients with ANPs even though his clinical trials are
shut down. To do this, they have formed a group called the ANP
Coalition:  
  
    It is our fundamental belief that the discovery
of Antineoplastons (ANP) can and will herald a new age of medical
science and subsequent advancements in the treatment of previously
incurable diseases. This benign yet effective drug contradicts the
paradigm that cancer treatments have to be harmful to be
effective, and redirects modern medicine back to its salient
principal Primum non nocere, first, do no harm.  
  
    How does the ANP Coalition intend to accomplish
our mission?  
  
    We will accomplish our mission by focusing on
four main goals:  
  
        To educate the public
as to the importance and benefits of ANP.  
        To advocate for
patients who need access to ANP for medical conditions.  
        To expedite regulatory
approval for ANP thereby making it available to all.  
        To further research and
development of ANP.  
  
Consistent with a lot of the rhetoric used by Eric Merola and the
Burzynski Patient Group, the rhetoric on the ANP Coalition site is
apocalyptic, painting the battle as nothing less than one of good
versus evil:  
  
    This is not a time for all good men to act; it
is a time when all good people must act. We live in an age of
awareness, where technology has become the great equalizer. With
technology comes communication, and through communication we can
educate! Once armed with education, propaganda withers and dies!  
  
    This website is designed with the sole purpose
of educating the public and exposing the truth. The battle starts
here in cyber space, but the war is won in the real world, by real
people who participate in real ways. It will be won by you!  
  
    We are no longer an organization of patients
connected by a cure; we are the collective who will not allow evil
to triumph.   
  
I can provide a hint of why the rhetoric is so amped up. One has
only to look at who owns the ANPcoalition.org. The domain is
registered through Domains By Proxy, which makes one wonder why
the ANP Coalition would want to hide who owns the domain. First of
all, the pictures on the Contact page reveal several old friends,
including Ric Schiff, whose wife Laura, not coincidentally, owns a
related domain, theotheranpcoalition.org, and registered it under
her real name and also appears on the Contact page. (A screenshot
has been saved, of course.) Also there is Mary Jo Siegel and her
husband Steve. These are the people behind ANP Coalition, just as
they are heavily involved in the Burzynski Patient Group. In fact,
in July 2013, Ric Schiff was elected to the board of directors of
the BRI, which makes his involvement in this effort a massive
conflict of interest.  
  
Predictably, Elisha Cohen, Liza Cozad, and Mackenzie Lowe are
featured as the stories used to drive petitions to lawmakers and
the FDA to allow compassionate use of ANPs. In addition, there are
two new patients, of whom I havent heard before, Laura Nowosad, a
7 year old girl from Canada with a DIPG whose story is sadly
familiar to anyone who covers Burzynski:  
  
    Her parents, Janusz and Mira, are an amazing
couple whose lives got shattered in an instant. Laura is their
only child and their whole world. They couldnt believe that this
is happening to their little girl; they were hopeful that the
doctors made a wrong diagnosis and went for a second opinion.
Unfortunately, this diagnosis was confirmed. Words cannot explain
the feelings of hopelessness, frustration, and terror they felt
when they had to be faced with the truth.  
  
    Janusz and Mira are not giving up hope! They
have taken Laura to The Burzynski Clinic in Houston, Texas. This
clinic has seen significant improvement in patients facing similar
diagnosis as Laura, using alternative therapies not available in
Canada. However, the treatment is very expensive. The initial
visit costs $25,000 and each month after is $30,000.   
  
On the same page is yet another desperate family being used by
Burzynskis minions as well, that of Isaac DeHerrera, a five year
old boy whose tale is presumably so new that there isnt yet a
fundraising website that I could find or a petition to let
Burzynski treat Isaac with ANPs on a compassionate use protocol.
Im sure there will be more families added as soon as Burzynski
and his minions can find them. Clearly Ric and Laura Schiff and
Steve and Mary Jo Siegel believe that they can duplicate the
success Burzynski patients had in the 1990s, which was the last
time Burzynski was in a comparable amount of trouble, with
demonstrations featuring patients chanting, FDA go away! Let me
live another day! and the intense political pressure brought to
bear by a compliant Senator or Representative, the way they
persuaded Joe Barton to drag then-FDA director David Kessler in
front of his committee four times over two years to explain why
the FDA was harassing Burzynski. Only this time, they have the
Internet, which was only in its infancy as an organizing tool back
in 1995, which allows them to produce a Meet the Miracles
section, which, presumably, will be full of glowing testimonials
of Burzynski Patient Group patients. So far, there is only Jessica
Ressel, who was featured in the first Burzynski movie and whose
testimonial is not convincing, as I described in detail in my
review. No doubt she believes Burzynski saved her, but it is
almost certainly the case that he did not, which is the only
reason I can forgive her regurgitating Burzynski Clinic talking
points.  
  
Perhaps the most concerning aspect of the ANP Coalition is that
its hired a lobbyist named Antonio C. Martinez II:  
  
    His experience with ANP extends more than 18
years back when he represented the Burzynski Patient Group in 1995
and 1996, organizing numerous patient demonstrations and a
Congressional Hearing on February 29, 1996 before the U.S. House
of Representatives Energy & Commerce Subcommittee on Oversight
& Investigations. These efforts helped Burzynski patients
obtain access to ANP through Phase II clinical studies.   
  
This isnt cheap. Unless Martinez is serving pro bono, his hourly
rates are $250 to $400. I have no reason to doubt the claim that
he worked on organizing the Congressional Hearing in 1996 at which
Burzynski patients vented at the FDA, but I wonder. Ive read both
Richard Jaffes Galileos Lawyer: Courtroom Battles in Alternative
Health, Complementary Medicine and Experimental Treatments and
Thomas D. Elias The Burzynski Breakthrough: The Most Promising
Cancer Treatment and the Governments Campaign to Squelch It. Both
books describe the Congressional hearings in which Burzynski
patients testified from a very pro-Burzynski standpoint. I dont
recall seeing Mr. Martinezs name being mentioned even once, and a
quick flip through the indices and relevant sections of these
books did not change that assessment for me. If Martinez were so
important to the 1996 hearings, one would think that Jaffe and/or
Elias would mention him and at least briefly describe his role in
their books. They didnt, as far as I can tell.  
  
So what does the ANP Coalition want to accomplish? Its list of
demands is long and some are completely unrealistic. For example,
on its page where it tells people how they can help, it asks
people to write to Wikipedia to:  
  
    demand removal of the Burzynski Clinic
webpage, since it has been high jacked by a paid group who
identify themselves as The Skeptics, and is no longer open for
public contribution. The Wikipedia page on Burzynski Clinic is
filled with untrue statements, statements taken entirely out of
context, cherry-picked information, sources that do not qualify as
sources under Wikipedia rules, fake sourcesyou name it.   
  
The Wikipedia team has already noticed the ANP Coalitions
attempts to astroturf its article on the Burzynski Clinic.  
  
Others, however, are not unachievable. Certainly organizing
petitions and getting people to write to their lawmakers are
achievable aims, and thats what concerns me: How do we respond?
In the absence of sound scientific information showing that ANPs
almost certainly dont work and are very toxic, Burzynskis claims
notwithstanding, legislators and politicians are going to go with
the sympathetic story; i.e., the stories told by Burzynski
supporters of children with deadly brain tumors who will die soon
if they arent allowed to have ANP therapy. Thats why it
infuriates me to see how Burzynski so cynically uses patients with
deadly cancers in his battle with the FDA. Make no mistake, that
is exactly what he is doing here. He dangles false hope in front
of patients like Eliza Cozad, Raphael Elisha Cohen, and McKenzie
Lowe, and their families do the rest for him Even in the case that
a legislator understands the lack of evidence, he might well go
with a Whats the harm? attitude, not appreciating that the harm
can be appreciable given how toxic ANPs are, not to mention the
financial harm done to the family raising tens or hundreds of
thousands of dollars for an ineffective treatment. Thats why
information to show why, as much as we sympathize with the plight
of these patients and their families, legislators should not
overrule the FDAs decision regarding antineoplastons. Indeed, the
real investigation should be into why the FDA has allowed
Burzynski to get away with what hes gotten away with all these
years.  
  
I also appeal to you, our readers, for help and ideas. Visit Bob
Blaskiewiczs appeal and take action. In the meantime, lets hear
ideas for how to counter this latest initiative.  
  


---

[**http://www.sciencebasedmedicine.org/stanislaw-burzynski-the-early-years-part-1/**](http://www.sciencebasedmedicine.org/stanislaw-burzynski-the-early-years-part-1/)  
July 22, 2013  
  

**Stanislaw Burzynski: The Early Years, part
1**  
**by David Gorski**

  
Its been a week now since I got back from TAM, where Bob
Blaskiewicz and I tag-teamed a talk about a man who has become a
frequent topic of this blog, namely Stanislaw Burzynski. Ive been
meaning to come back to the topic of Burzynski, but from a
different angle. There hasnt been much in the way of news lately
other than the release of Eric Merolas most recent propaganda
documentary, Burzynski: Cancer Is A Serious Business, Part 2,
but, believe it or not, there remain lots of loose ends that I
havent covered. This time around, the angle is this: How did
Burzynski get his start? His is a story that goes back over 46
years, and in the beginning he seemed to be a promising young
academic physician and a perfectly respectable researcher. So what
happened? How did he evolve from a seemingly idealistic young
Polish physician to what he has been for many years now?  
  
I started to think about this when I was writing my post about
alternative cancer cures circa 1979, because one of the three
articles written by Gary Null and various coauthors that appeared
in Penthouse magazine in the fall that year, The Suppression of
Cancer Cures, was dedicated primarily to Stanislaw Burzynski and
his antineoplastons, which at the time were new news, so to
speak. However, Nulls article, even though it was contemporaneous
with Burzynskis having recently struck out on his own and started
his own clinic, didnt reveal everything that I was interested in
learning. Actually, the more I read, the more I realize that no
source really reveals everything that I want to know about that
time period in the 1970s and early 1980s that produced the
Stanislaw Burzynski that we know and dont love today. Available
sources all tend to be either pro-Burzynski, Burzynski himself, or
vague in the extreme about what happened. Fortunately, my research
for my TAM talk will serve multiple purposes. Since the talk was
so brief and required me to cover 40+ years of history in a mere
20 minutes, there was a lot left out. I hate to let all that
research go to waste; so Im going to use it for an intermittent
series of blog posts.  
  
While preparing for my TAM talk, I read two books from sources
friendly to Burzynski. The first was Galileos Lawyer: Courtroom
Battles in Alternative Health, Complementary Medicine and
Experimental Treatments by Richard A. Jaffe. Jaffe was Burzynskis
lawyer for a long time, and in particular he helped Burzynski beat
multiple raps in 1997, when it looked as though Burzynski might
well be convicted of insurance fraud, violations of the Food,
Drug, and Cosmetic Act, and other charges related to his
antineoplaston therapy. Of the two, this book was the most
revealing, because Burzynski wasnt the focus of the book
(although his story does take up roughly half of it). Rather,
self-aggrandizement on the part of the author clearly is, which
perhaps explains why Jaffe would say some things that he says that
are particularly unflattering to Burzynski. True, Jaffe clearly
thinks they are flattering (to him) and evidence of how clever he
was in defending the misunderstood genius that he viewed Burzynski
to be and beating the system in the mid- to late-1990s, but what
they reveal to me about Burzynskis current crop of phase 2
clinical trials is appalling. The second book is The Burzynski
Breakthrough: The Most Promising Cancer Treatment and the
Governments Campaign to Squelch It by Thomas D. Elias. This book
is more pure hagiography, a book designed to portray Burzynski as
a Brave Maverick Doctor who can cure cancers that conventional
medicine cannot. Amusingly, the latest edition boasts that there
are now clinical trial data in it, which led me to wonder why
Burzynski would provide such data to a columnist writing a
hagiography about him rather than, oh, you know, publish it in the
peer-reviewed scientific literature. However, Elias provides a bit
more detail on certain aspects of Burzynskis early years, and his
account is interesting in that it doesnt always agree with
Jaffes account. Elias also provides testimonials from several of
Burzynskis patients who were treated before the Internet era
whose stories are hard to find in detail online, for example, Tori
Moreno. (For example, nothing in the chapter on Tori Moreno leads
me to change my conclusions about how she survived.)  
  
Obviously, given that both of these books are clearly
pro-Burzynski, one has to take their claims and accounts with a
grain of salt. (Actually, the salt mines under Detroit probably
dont contain enough salt for this purpose.) Even so and even
noting that these are pro-Burzynski sources, I was shocked at the
sorts of information in the books, there for all to see. To
someone who knows cancer research, they contain some pretty
damning information. Obviously, the authors didnt see it that way
when writing them, but I do.  
The early years: Childhood  
  
In many ways, Stanislaw Burzynskis story is a prototypical
immigrant rags-to-riches story. Stanislaw Burzynski was born in
Nazi-occupied Poland in the city of Lublin on January 23, 1943,
right as the Holocaust in Poland was gearing up in earnest. The
previous year, mass killings had begun at Auschwitz-Birkenau, and
mere months before Burzynskis birth, the Sobibor and Treblinka
camps had opened. So had the Belzen camp, to which the Jews of
Lublin were deported soon after its opening. Other notable events
in the year before Burzynski was born include the beginning of
Operation Reinhard (the mass deportation of Polish Jews to
concentration camps), the beginning of the liquidation of the
Warsaw Ghetto, and many other atrocities. In 1943, the Jews of the
Warsaw Ghetto mounted their uprising, and later Himmler ordered
the liquidation of the remaining Jews in Poland.  
  
Little is known about Burzynskis early childhood and youth aside
from what Burzynski himself has told sympathetic sources like
Thomas Elias, from whose book I gleaned most of this account.
Despite the devastation going on all over Poland, Stanislaw
Burzynski was largely sheltered from the grim reality of
Nazi-occupied Poland in his early years. His mothers family was
well-off and owned an ornate family house in the old part of
Lublin built around three inner courtyards that had served as the
local Roman Catholic bishops palace in the 1800s. It was designed
in a Baroque Renaissance style, and its three-story facade bore
elaborate sculptures around all the windows. Before the war, Elias
reports, Burzynskis grandmother used its large spaces to operate
a private high school for girls. In the early 1940s, she gave her
daughter and her husband an apartment in the building.  
  
There was also a country house at the edge of the great Stary Las
Forest outside of Lublin where the Burzynskis spent a lot of their
time as well. Burzynskis father, a teacher who was the son of a
blacksmith, was apparently not well-regarded by his mothers side
of the family because he came from poverty and Poland was a very
class-conscious society at that time. His father was also
imprisoned by the Nazis because he kept teaching Jewish children,
and the local Nazis did not like that. Interestingly, after the
war, the Communists imprisoned Burzynskis father for giving
underground lessons that were apparently not politically
acceptable. His father sounds as though he were quite the man. The
son, on the other hand, was pugnacious and described himself as
getting into fights almost every day, a situation that persisted
until the fourth grade.  
  
After the war, the Communist government confiscated the Burzynski
house in Lublin and turned it into apartments, which were
distributed to whoever needed them, although the Burzynskis got to
keep their apartment. Elias also informs us that Burzynskis
brother Zygmunt was an anti-Communist fighter who was shot
fighting the government in 1948 and died of meningitis as a result
of his wound. In Elias book, Burzynski recounts these stories and
uses his childhood pugnaciousness and belief that one should never
duck a fight as a rationalization for not having moved his clinic
to Tijuana years ago, saying:  
  
    So, the idea of fighting a government was
nothing new to me when I began having troubles with the Food &
Drug Administration.   
  
And, based on the death of Zygmunt:  
  
    The idea of fighting people in authority became
natural to me. I learned that you must never let them defeat you
in your own core.   
  
In some ways, these can be most admirable traits. Virtually all
highly successful people who make a difference in the world
possess some measure of this sort of determination and willingness
to fight for what one believes. If only Burzynski had found a good
cause to which he could yoke such them. Unfortunately, he found
antineoplastons.  
The early years: The dawn of antineoplastons  
  
Despite his tendency to fight, Stanislaw Burzynski was, unlike his
brother, academically inclined. He did very well in secondary
school and entered medical school straight from there, which was
how it was done in Poland at that time. Somehow, he became
intensely interested in amino acids and peptides. Working for
chemistry professor Irana Krzeczkowski and biochemist Janina
Blaut, the young Burzynski studied peptides in wild mushrooms that
grew in the Stary Las Forest because his mentor wanted to find
uses for them in agriculture. By the time he graduated from
medical school in 1967, he had published fourteen scientific
papers, which, as we say, aint too shabby.  
  
In 1967, Burzynski was ready to work on his doctoral thesis. He
had become interested in differences in the amount and types of
peptides found in the blood and urine of renal failure patients
and cancer patients. He reported that some of these chemicals were
found at high levels in the blood of renal failure patients. He
also found that cancer patients had a low level of some of these
substances, which were not, it turned out, peptides. Ultimately,
his work in this area resulted in a thesis entitled
Investigations on amino acids and peptides in blood serum of
healthy people and patients with chronic renal insufficiency. Of
note, according to Elias, Burzynski finished his thesis in 1968,
which makes one wonder how he could have possibly gotten a PhD
based on it in such a short period of time. However, my purpose
here is not to worry about whether his PhD is legitimate, as Saul
Green has done. I dont really care if Burzynskis PhD is
legitimate or not. What I care about is what Burzynski has done
with his medical education over the last 46 years.  
  
Ultimately, in 1970, Burzynski decided that he couldnt stay in
Poland anymore. What hadnt been clear to me from all the reports
and retellings of his decision to come to the US is why he chose
to leave Poland in 1970. Whatever happened between 1968 and 1970,
Elias reports that in 1970 Burzynski was being recruited to join
the Communist Party but refused to join. This was perhaps the
first case, but definitely not the only case, where his
stubbornness caused him serious problems. Burzynski learned he was
going to be drafted into the Polish Army, where he would be sent
to wherever the Soviet Union needed him, but, thanks to the
intervention of a prominent scientist, managed to get a passport
and get out of Poland before his draft notice was delivered in
early September. He arrived, as he has said so many times, at JFK
Airport with only $20 in his pocket. Later he learned that his
position at the university had been terminated.  
  
Burzynski stayed with an uncle in The Bronx but soon managed to
get a job at the Baylor College of Medicine in the Department of
Anesthesia, then headed by Georges Ungar, a Hungarian refugee with
whom he hit it off. Ungar was famous for proposing that memory
resided in peptides made by the brain, and he tried to transfer
memory by transferring those peptides from one mouse brain to
another. Its a hypothesis that seemed to be supported by his
experiments at the time but faded from favor as more research
failed to support it. Burzynski split his time between working on
Ungars project and working on his own peptides, which he had
finally dubbed antineoplastons. He even managed, with the help of
an investigator at M.D. Anderson, to secure an NIH grant in 1974.
These years were productive for Burzynski, and he and Ungar
published a lot of papers. Burzynski apparently killed a lot of
rats in his time at Baylor doing Ungars research, which is
something I can totally relate to, having dispatched hundreds of
mice myself while doing angiogenesis research in the 1990s.
Basically, rats were trained at tasks by the hundreds, after which
they were killed and the peptides from their brains isolated.
These peptides were then injected into the brains of other rats in
order to see if the knowledge could be transferred with the
peptides. Fun times!  
The long, slow ethical slide  
  
It was in Stanislaw Burzynskis later years at Baylor that,
arguably, the seeds of what he has become today were planted. In
1973, after three years of study, Burzynski had managed to pass
the medical board examinations and obtain his Texas medical
license. However, as Ive pointed out before multiple times, he
had no U.S. specialty training in oncology. In fact, he doesnt
appear to have had any specialty training even in internal
medicine, and an internal medicine residency is a prerequisite to
doing an oncology fellowship and becoming a fully-trained
oncologist. One thing I couldnt figure out from either book or
any of my other reading is how Burzynski got a license to practice
medicine in Texas. Usually, getting such a license requires at
least a year of postgraduate medical training (usually an
internship) in addition to medical school and passing the national
medical board examinations. I can only speculate that whatever
postgraduate clinical training Burzynski might have done in Poland
must have counted, because I cant find any reference to him doing
any clinical training after arriving at Baylor. Thats not really
the most important issue here, but it is a curiosity to me as a
physician.  
  
Its also indicative of the extreme arrogance that Burzynski
exhibited at the time. Elias recounts how in 1976 Burzynski
thought that because he had obtained his medical license in 1973
he was then qualified to be the principal investigator for the
first clinical trial of antineoplastons. He didnt want to let
anyone else be in charge of such a trial, even though it is
obvious to me that at the time Burzynski was completely
unqualified to run even a small phase I oncology trial. Its
rather instructive to look at what happened here from three
different perspectives, the narrative in Elias book, the
narrative in Jaffes book, and the description in Gary Nulls
Penthouse article. Oddly enough, for being nearly contemporaneous,
Nulls article mentions very little about Burzynskis time at
Baylor and why he ultimately left, at least nothing more than I
discussed when I originally considered this article.  
  
So what did happen? From what I can gather from Elias and Jaffe, a
confluence of events conspired to push Burzynski towards his fate.
Yes, Im exaggerating a little, but not much. As I discussed
before, Burzynski successfully got an NIH grant in 1974, but was
unable to renew it in 1976; it expired in 1977. In 1976,
apparently internal politics led to Ungars ouster from the
Department of Anesthesia. According to Elias, the new boss of
anesthesiology (as Burzynski was quoted as putting it) was
Lawrence Schumacher, who wasnt interested in peptide research and
didnt think much of Burzynski. He also, arguably quite
appropriately, didnt think that Burzynskis research was the sort
of research that was appropriate to a department of anesthesia. So
Ungar ended up taking a job at the University of Tennessee, and
Burzynski had trouble renewing his grant. Apparently, if Burzynski
is to be believed, the new cancer research center at Baylor wanted
to hire him and even offered him a $30,000 start-up package
(respectable at the time), but it also imposed two conditions that
were unacceptable to him. First, it wanted the rights to his
antineoplaston discovery. This has been common practice at
universities for a long time. If an investigator discovers
something patentable while working for a university, usually the
university will patent it and share a significant cut with the
inventor. Burzynski, however, didnt want to share. Similarly,
although Ungar offered Burzynski a position in Tennessee,
Burzynski did not want to follow his friend there because he was
afraid that the University of Tennessee would want his
antineoplastons, too.  
  
There was another condition, too, and its a problem that tells me
that from a very early time in Burzynskis career he didnt play
by the rules. However, it was more than that. Not only did he not
play by the rules, but he didnt much care for those pesky
regulations and ethical codes designed to protect human subjects.
Heres where Elias and Jaffe diverge. According to Jaffe, shortly
after he got his medical license Burzynski started a private
practice on the side, and that practice became fairly lucrative.
According to Jaffe, Burzynski joined someone elses practice part
time. Actually, Elias is inconsistent on this issue, at one point
implying that it was Burzynskis private practice and at another
point saying that Burzynski worked for someone named Dr. Walker.
Whatever the case was, both agree that before he even tried to
undertake clinical trials of antineoplastons at Baylor, Burzynski
had been giving ANPs to patients at his private practice. Just how
long he had been doing that was not clear from either account, but
it was clear that he did it before undertaking clinical trials.
Indeed, that was why Baylors requirement as a precondition for
his taking a position at the cancer research center that Burzynski
give up his private practice that was such a sticking point to
Burzynski, as Elias describes:  
  
    Despite the enhanced prestige, secure salary
and tenure that could have been his had he gone along with the
proposed changes, Burzynski hesitated. He didnt like the idea of
subjecting himself to the authority of an institution. As long as
he had a private practice, he believed he could use whatever
medications he thought most effective, subject only to the consent
of his patients.   
  
In any case, in late 1976, Burzynski applied to the Baylor
Institutional Review Board to be able to begin a clinical trial of
antineoplastons but was turned down. Both Elias and Jaffe claim
(no doubt because Burzynski told them this) that the reason
Baylors IRB turned Burzynski down is because he didnt have an
IND. An IND is an investigational new drug application, which
the FDA requires before it will approve a clinical trial of an
experimental drug. In both accounts, Burzynski laments that Baylor
turned him down and that he couldnt get an IND because, according
to him, IRB approval was required to get an IND, leading to what
he referred to as a circular process that dogged him for several
years. Reading these accounts, I cant help but think that there
must have been more going on. For example, Im not sure how much
different it was in 1976, but in general the FDA requires the
following information for an IND:  
  
    The IND application must contain information in
three broad areas:  
  
        Animal Pharmacology and
Toxicology Studies  Preclinical data to permit an assessment as
to whether the product is reasonably safe for initial testing in
humans. Also included are any previous experience with the drug in
humans (often foreign use).  
        Manufacturing
Information  Information pertaining to the composition,
manufacturer, stability, and controls used for manufacturing the
drug substance and the drug product. This information is assessed
to ensure that the company can adequately produce and supply
consistent batches of the drug.  
        Clinical Protocols and
Investigator Information  Detailed protocols for proposed
clinical studies to assess whether the initial-phase trials will
expose subjects to unnecessary risks. Also, information on the
qualifications of clinical investigatorsprofessionals (generally
physicians) who oversee the administration of the experimental
compoundto assess whether they are qualified to fulfill their
clinical trial duties. Finally, commitments to obtain informed
consent from the research subjects, to obtain review of the study
by an institutional review board (IRB), and to adhere to the
investigational new drug regulations.  
  
In other words, an investigator doesnt need to get IRB approval
before applying for an IND. The investigator has to promise he
will have the study that ultimately derives from an IND will be
reviewed by an IRB, obtain informed consent from patients, and
adhere to the FDAs IND regulations. I can, however, see many
reasons why an IRB might be reluctant to give its approval for a
study using a treatment like ANPs. For one thing, in 1976
Burzynski had no animal data to speak of. In fact, the question of
animal studies is an interesting one. Both Elias and Jaffe recount
a story in which ANPs didnt work in animal tumors, and Burzynski
has been quoted in multiple places as claiming that ANPs are
species-specific and that ANPs derived from human blood and urine
dont work in animal tumor models. This is in contrast to what
Null reports in his near-contemporaneous account, in which he
stated that in tissue culture and animal models Burzynskis ANPs
worked specifically against certain types of cancer, all with
no toxic side effects. It makes one wonder whether the species
specificity was an excuse developed later to explain the lack of
animal data.  
  
Whatever the case, its not surprising that an IRB would balk.
From what I can tell from every account Ive read, in 1977 there
just wasnt enough preclinical data to justify a clinical trial,
nor was it even clear yet exactly what ANPs were, as Burzynski
hadnt yet identified all the constituent chemical compounds were
that made them up. Worse, ANPs were derived from urine, which
opened up the possibility of infectious agents being transmitted
from ANP preparations made from human urine. Moreover, in 1977, as
far as I can tell, Burzynski didnt have the capability to isolate
sufficient quantities of ANPs to treat patients, having told Elias
that he required 30 L of urine per day per patient. It wasnt
until the early 1980s that Burzynski learned how to synthesize
ANPs, and that was after he had left Baylor.  
  
After Baylors IRB rejected his application, Burzynski tried the
Park Plaza Hospital, which was affiliated with Baylor. Park Plaza
turned him down. Ultimately, the IRB at Twelve Oaks Hospital,
which is where he treated his first patients with ANPs, approved
his application. At this stage, Jaffes account is more
illuminating, because it demonstrates just how scheming Burzynski
was at the time. He had lawyers investigate whether he could give
ANPs to patients at his clinic and how he could avoid getting into
trouble. Their advice to him was that, because Texas at the time
didnt have a mini-FDA act, in which only FDA-approved drugs
could be given to patients, the only way he might get in trouble
with the law administering ANPs was if he were to ship them across
state lines and thereby fall under the federal Food, Drug, and
Cosmetic Act and the FDAs authority. Basically he was told that,
as long as he was making ANPs in his own laboratory and giving
them only to his own patients, it should be legal under Texas law.  
  
Jaffe also recounts some amusing anecdotes of Burzynskis early
years after leaving Baylor. Back then, he really did isolate ANPs
from blood and urine. Apparently before he left Baylor, he got
ANPs mainly from blood:  
  
    For the previous few years, he had been
obtaining antineoplastons from human blood in an unusual way. He
got his raw material from the blood of his friends and
acquaintances. He would go to parties and public gatherings with
IV lines and bottles and beg and cajole his friends and colleagues
to donate blood for his research.  
  
    After a while, he noticed he was getting fewer
and fewer invitations to parties, and, when his friends would see
him on campus or the street, they would turn and walk away
quickly, pretending they didnt see him.   
  
This sounds a lot like Andrew Wakefield and his experiments,
doesnt it?  
  
After he went into practice for himself, Burzynskis need for raw
materials skyrocketed, and the only feasible way to get them was
from urine. To get it, Burzynski arranged to install urine
collectors in public parks and the state penitentiary system. Most
amusingly of all, apparently Burzynski collected urine from
Gilleys Bar, where Urban Cowboy was filmed. One wonders whether
John Travolta contributed to some of those early antineoplaston
batches.  
Back to the future  
  
In my next installment in this series (which probably wont be
next week), Ill discuss some of Burzynskis legal battles, up to
and including his epic battle in the 1990s that led to his
indictment in late 1995 on insurance fraud and violation of the
Food, Drug, and Cosmetic Act and his ultimate acquittal based on a
hung jury in early 1997, as well as how the Burzynski Patient
Group was formed and used to bring pressure on the FDA and Texas
Medical Board to rule in Burzynskis favor, all with the help of
some very powerful politicians, such as Representative Joe Barton
of Texas. At some point, Ill also look at the clinical trial
statistics that Elias promised on the cover of his book. However,
I will conclude by pointing out exactly what it is that Jaffe said
that he really shouldnt have. Its of a piece with Burzynskis
history in that shows how, 20 years later, Burzynski wasnt really
interested in doing clinical trials. They are and always have been
a means to an end: To let him give ANPs to patients unmolested by
the authorities.  
  
Jaffe in essence boasts about this in his book. Because Rep. Joe
Barton had put such enormous pressure on the FDA through his
Congressional hearings and bad publicity replete with crying
cancer patients lamenting how they would die if Burzynski were
shut down, in 1997-1998 the FDA was going to relent and let
Burzynski apply to undertake clinical trials. In response,
Burzynski put together a clinical trial known as CAN-1, which was
basically a retrospective study of all the patients Burzynski had
treated with ANPs up to that point in 1997. Listen to how Jaffe
described it:  
  
    So we decided to hit the FDA with everything at
the same time. All of his current patients would be covered in a
single clinical trial which Burzynski called CAN-1. As far as
clinical trials go, it was a joke. Clinical trials are supposed to
be designed to test the safety or efficacy of a drug for a
disease. It is almost always the case that clinical trials treat
one disease.  
  
    The CAN-1 protocol had almost two hundred
patients in it and there were at least a dozen different types of
cancers being treated. And since all the patients were already on
treatment, there could not be any possibility of meaningful data
coming out of the so-called clinical trial. It was all an
artifice, a vehicle we and the FDA created to legally give the
patients Burzynskis treatment. The FDA wanted all of Burzynskis
patients to be on an IND, so thats what we did.   
  
This is Burzynskis lawyer writing here. I thank him for his
candor, particularly since he describes how the dozens of other
clinical trials, 61 of which still show up on the
ClinicalTrials.gov website, came into existence. According to
Jaffe, it was not because Burzynski was so interested in knowledge
and finding out whether ANPs work. It was because he already
believed they worked and wanted to keep treating patients without
interference:  
  
    CAN-1 allowed Burzynski to treat all his
existing patients. That solved the patients problems, but not the
clinics. A cancer clinic cannot survive on existing patients. It
needs a constant flow of new patients. So in addition to getting
the CAN-1 trial approved, we had to make sure Burzynski could
treat new patients. Mindful that he would likely only get one
chance to get them approved, Burzynski personally put together
seventy-two protocols to treat every type of cancer the clinic had
treated and everything Burzynski wanted to treat in the
futureMiracle of miracles, all of Burzynskis patients were now
on FDA-approved clinical trials, and he would be able to treat
almost any patient he would want to treat!   
  
And for patients who didnt fit into one of these seventy-three
clinical trial protocols (CAN-1 plus the other seventy-two), there
were always single-patient INDs, otherwise known as compassionate
use protocols. I also cant help but wonder what the alt-med
believers who support Burzynski would say if I were to say about
my cancer center something like, A cancer center cannot survive
on existing patients. It needs a constant flow of new patients.  
  
Yes, from a very early time in the late 1970s to twenty years
later in the 1990s to this very day, for Stanislaw Burzynski,
clinical trials are but a means to an end, and that end is not
scientific knowledge or to determine whether or not they work
against cancer. The end is to allow Burzynski to treat cancer
patients with ANPs. He is, after all, the Brave Maverick Doctor
fighting the system, as he thought of himself as fighting the
system in Communist Poland. From what Ive been able to discern,
to him government laws and regulations are not designed to protect
patients but to keep him from curing them. So getting around them
by any means necessary is not only justified but mandatory. The
question becomes: Does Burzynski still believe himself to be the
man who has cured several forms of cancer, or does he now know
that ANPs almost certainly dont work and are definitely not some
sort of miracle cure?  
  


---

  
[**http://www.sciencebasedmedicine.org/revealed-by-the-fda-the-results-of-the-most-recent-inspection-of-the-burzynski-clinic/**](http://www.sciencebasedmedicine.org/revealed-by-the-fda-the-results-of-the-most-recent-inspection-of-the-burzynski-clinic/)  
November 11, 2013  
  

**Revealed by the FDA: The results of the
most recent inspection of the Burzynski Clinic**  
by David Gorski

  
After posting the talks that Bob Blaskiewicz and I gave at TAM
this year, I realized that its been a while since Ive written
about the topic of those talks, namely Stanislaw Burzynski, the
Houston cancer doctor who inexplicably has been permitted to
continue to administer an unproven cancer treatment to children
with deadly brain cancers for nearly 37 years now. Beginning in
1977, when he left Baylor College of Medicine and opened up the
Burzynski Clinic, Burzynski has administered a cancer therapy that
he calls antineoplastons to patients. After nearly four decades
and several dozen phase II clinical trials started, he has never
published a completed phase II trial. The only evidence hes
published consists mainly of cell culture studies, case reports,
and couple of preliminary reports of his phase II clinical trials.
Of course, Burzynskis lawyer, Richard Jaffe, even dismissively
admitted that these clinical trials are designed solely to allow
Burzynski to keep giving antineoplastons.  
  
So Burzynski operated from the late 1990s until summer 2012,
charging exorbitant case management fees to enroll patients in
his clinical trials, working with a credulous filmmaker who wanted
to make a movie about himtwiceand flouting regulations designed
to protect human subjects involved in clinical trials. Meanwhile,
he branched out to personalized gene-targeted cancer therapy,
which he promoted through Suzanne Somers; to AminoCare, which is
basically antineoplastons sold as an antiaging nostrum (or, as
Burzynski puts it, a genetic solution to aging); and to selling
an orphan drug as a prodrug for antineoplastons.  
  
So what happened in the summer of 2012? Apparently, there was a
treatment-related death of a child, which led the FDA to issue a
partial clinical hold on the Burzynski Clinic that prevented him
from enrolling any new children on his clinical trials, although
he could keep treating existing patients and enroll new adult
patients. That partial clinical hold was extended to adults in
January 2013, at which time the FDA arrived at the Burzynski
Clinic to investigate. It was an event that was included at the
tail end of Eric Merolas second propaganda film about Stanislaw
Burzynski and represented as, in essence, jackbooted fascists
trying to keep the cure for cancer from The People. None of this
stops credulous reporters from writing misleading articles with
titles like Young mother with brain cancer given just a year to
live BEATS the disease and gets married after having controversial
treatment in the US, which is a story about Laura Hymas, a woman
whose good fortune is most likely not due to Burzynski. Not long
before that, there was another credulous article featuring another
Burzynski patient, Hannah Bradley, as one of four patients treated
for cancer with alternative therapies who are allegedly doing
well. Again, Hannah Bradleys good fortune is highly unlikely to
be due to Burzynskis nostrums.  
  
All of this is why those of us who follow Burzynski have been
waiting with the proverbial bated breath to find out what the FDA
concluded. Just before the government shutdown the first shoe
dropped, when the FDA released a warning letter to the Burzynski
Research Institute (BRI). Then last week, the second shoe dropped,
when the FDA released the original forms describing its findings
regarding the inspection. The findings are, to put it mildly,
damning in the extreme. In fact, now, more than ever, I wonder how
on earth Burzynski has been allowed to continue to run clinical
trialsor even practicefor so long. The findings include massive
deficiencies in the Burzynski institutional review board (IRB),
the committee responsible for making sure that regulations
designed to protect human subjects in research are adhered to.  
Stanislaw Burzynski versus human subjects protections: Human
subjects protections lose  
  
Before looking at the new FDA findings, lets recap what is known
about Burzynskis IRB. First, we know that the IRB is headed by
Carlton F. Hazlewood, PhD, who just so happens to be on the board
of directors of the Burzynski Research Institute. As I noted
before, given that the Burzynski Clinic has been trying for
decades to commercialize antineoplastons, this is a profound
conflict of interest. I also ask you to think of it this way
again: What would Burzynskis defenders say if they found out that
a sitting member of the board of directors of Merck, for example,
was serving on the IRB that oversees Mercks clinical trials?
Having Hazlewood serve on the BRI IRB is the same thing. True,
its not quite as bad as having the principal investigator of a
study chair the IRB overseeing his studies, as Mark Geier has
done, but its pretty bad. Again, one wonders how Burzynski
supporters would react if pharmaceutical companies or even
research institutes trying to commercialize a discovery made by
their investigators allowed high ranking leadership sit on their
IRBs.  
  
Last year, a certain friend of mine had discussed the problems
with Burzynskis IRB before, and these notes simply amplify and
add detail to the problems that were already known. These notes
suggest how Burzynski uses his IRB to get around some of the
restrictions that were placed on him using antineoplastons. As you
might recall, the Common Rule demands that all clinical trials by
investigators whose institutions receive federal funding or that
are being done in order to win FDA approval for a drug or device
must be overseen by an IRB, whose purpose is to protect the human
subjects who take place in the trials. This is an absolutely
essential purpose of the IRB, its key reason for existence. It is
not there to evaluate the science, except to the extent that badly
designed clinical trials based on bad science endanger human
subjects. Its purpose is to make sure that the risks and benefits
of clinical trials are reasonably balanced, make sure that
patients entering clinical trials receive adequate informed
consent, and to keep an eye on the trial as it is being carried
out, evaluating adverse event reports and, if necessary, shutting
the trial down if there are too many or if one group starts doing
too poorly relative to the other.  
  
These are duties and functions that the Burzynski Clinics IRB
utterly failed to carry out over the years. Before I take a look
at the FDA warning letter and its accompanying notes, lets go on
a stroll down memory lane and recap some of the violations that
the FDA has found in the past, gleaned from a a letter to the
Burzynski Clinic Institutional Review Board from 2001; a report of
a site visit to the Burzynski Clinic by the FDA Southwest
Regional/District Office, Dallas District; and a warning letter
from the FDAs Human Subjects Protection Team, Division of
Scientific Investigations, Office of Compliance, dated 2009:  
  
    Enrollment of subjects into antineoplaston
study protocols prior to the protocol-specified interval following
prior chemotherapy and/or radiation therapy.  
    Failure to report all serious adverse events
(SAEs) and adverse events (AEs) to the agency and/or IRB.  
    Failure to follow proper informed consent
procedures.  
    Failure to maintain adequate drug
accountability records.  
    Discrepancies between case report forms and
source documents.  
    Failure to keep a copy of the study protocol
and informed consent form.  
    Failure to receive and/or require progress
reports from the principal investigator for the study.  
    Failure to receive and/or require a final
report from the principal investigator for the study prior to
removal from the IRBs active list of studies.  
    Failure to assure that FDA approval was
obtained by the principal investigator for the study prior to the
treatment of a patient under a special exception.  
    Approval of special exceptions via expedited
review.  
    The IRB approved research without determining
that the following criteria were met: That risks to subjects were
minimized and that risks to subjects were reasonable in relation
to anticipated benefits, if any, to subjects, and the importance
of the knowledge that may be expected to result.  
    The IRB failed to prepare, maintain, and follow
written procedures for conducting its initial and continuing
review of research.  
    The IRB failed to ensure that informed consent
would be sought from each prospective subject or the subjects
legally authorized representative.  
    The IRB failed to ensure that no member
participated in the initial or continuing review of a project in
which the member had a conflicting interest.  
    The IRB failed to conduct continuing reviews.  
  
The latest round of findings from the FDAs most recent
investigation eight months ago reads like an acid flashback of
investigations past. According to the FDA warning letter based on
this FDA Form 483, covering the inspection dates from January 22
to February 7, 2013, heres what the FDA dinged Burzynski for this
time. The CliffsNotes version is this:  
  
    The IRB failed to follow FDA regulations
regarding expedited review procedures [21 CFR 56.110(b)].  
    The IRB approved research without determining
that the following criteria were met: risks to subjects were
minimized [21 CFR 56.111(a)(1)]; risks to subjects were reasonable
in relation to anticipated benefits, if any, to subjects, and the
importance of the knowledge that may be expected to result [21 CFR
56.111(a)(2)].  
    The IRB failed to determine at the time of
initial review that studies involving children are in compliance
with 21 CFR part 50, subpart D, Additional Safeguards for Children
in Clinical Investigations [21 CFR 56.109(h)]. This is a repeat
violation from our 2010 inspection.  
    The IRB failed to prepare, maintain, and follow
written procedures and maintain adequate documentation governing
the functions and operations of the IRB [21 CFR 56.108(a), 21 CFR
56.108(b), and 21 CFR 56.115(a)(6)].  
  
More detailed observations can be found in the Form 483.
Basically, the Burzynski Clinic and BRI ran roughshod over human
subjects protection. Most of the violations are fairly simple,
even for lay people, to understand. For example, not making sure
that patients enrolled on clinical trials meet the inclusion
criteria, not reporting adverse events in a timely fashion, and
not removing patients with adverse events from the study quickly
are all fairly self-evident violations and not difficult to
explain. Its fairly easy to understand why failing to remove a
patient who suffers an adverse event that the protocol says should
be a reason to remove the patient from the protocol is a
violation. One violation, however, is not as easy to understand
for those not involved in clinical trials and therefore deserves a
bit more discussion. Im referring to Burzynskis apparent abuse
of the expedited approval process through his IRB. This seems to
be the theme that ties together much of what is reported in this
warning letter to the BRI; so I feel the need to explain a bit, in
order to put it all into some context.  
  
Quite reasonably, the Office for Human Research Protections
(OHRP), the office in the Department of Health and Human Services
that oversees IRBs, does not require the same sort of approval
process for every sort of human subjects research. Not every study
that involves human subjects research is a randomized clinical
trial. For instance, in the case of human subjects research that
involves pre-existing samples that have been de-identified can be
exempted from full IRB review and oversight because, well, there
are no human subjects to be endangered, even through linking of
their identities to a specimen demonstrating a disease. Lots of
research gets done this way, for example analyzing or staining
pre-existing samples looking for a biomarker or a change in
expression of a protein. Ive done projects like this. This is
commonly known as Exemption 4, and there are several other exempt
categories.  
  
However, Burzynski doesnt abuse the exemption process, which,
lets face it, would be very hard to abuse for the most part. What
he appears to have abused is the expedited approval process. The
expedited review process generally involves approving things like
minor revisions to research protocols and informed consent forms.
Expedited generally means just that: Expedited. A full IRB
review is not done, and a streamlined, faster process is used.
Expedited approval can also be used for protocols that fall under
categories that the Department of Health and Human Services (HHS)
deems to be minimal risk, described thusly on the University of
Kentucky website:  
  
    Expedited procedures can only be used to review
a study if the only involvement of human subjects fits one or more
of the categories specified in the federal regulations and if all
of the procedures present no greater than minimal risk.  
  
    The IRB reviewer confirms that all of the
research activities fit in one or more of the expedited
categories. If the research includes activities that do not fit in
the categories, the study is not eligible for expedited review
even if the research involves minimal risk.  
  
    The Department of Health and Human Services
defines minimal risk to mean the probability and magnitude of
harm or discomfort anticipated in the research are not greater in
and of themselves than those ordinarily encountered in daily life
or during the performance of routine physical or psychological
examinations or tests [45 CFR 46.102(2)(i)].  
  
    Investigators are asked to provide a risk
assessment, but it is the IRB reviewers responsibility to
determine whether the research meets the federal definition.  
  
    The IRB reviewer must consider two questions:  
  
        Is the probability of
the harm or discomfort anticipated in the proposed research
greater than that encountered ordinarily in daily life or during
the performance of routine physical or psychological examinations
or tests?  
        Is the magnitude of the
harm or discomfort greater than that encountered ordinarily in the
daily life or during the performance of routine physical or
psychological examinations or tests?  
  
    If the answer is yes to either of these
questions, then the research does not meet the definition of
minimal risk.   
  
A list of the types of research that can be approved through
expedited review can be found on the OHRP website. These include
things like blood draws, prospective collection of biological
specimens by noninvasive means (one could collect urine specimens,
for instance, under a protocol approved through the expedited
review process), and research involving data that has already been
collected. Heres a hint: Approving single patient protocols for
an investigational drug that is not FDA-approved does not fall
into any of the categories for which expedited review is
appropriate, particularly when so many of the patients involved
are children and particularly when the drug being tested can cause
severe hypernatremia. Basically, from my reading, Burzynski seems
to be using the expedited review process to treat patients with
antineoplastons who do not qualify for any of his numerous phase
II trials, and until last year he was getting away with it. Again,
one of the great mysteries is: How?  
  
But thats not all. The second Form 483 answers a question that
many of us interested in Burzynski have wondered about for a very
long time.  
One mystery solved: What happened to all those complete responses?  
  
There are two central mysteries about Stanislaw Burzynski that I
would really, really like to see answered, and, hopefully, I will
see them answered soon. The first is, of course: How has he gotten
away with it for so many years? The second is: What are his real
results? Im not referring to the results Burzynski and his
sycophants claim, but the real results? People like Paul Goldberg
and others have been reporting for years that Burzynskis results
dont seem to match his claims, with cancer experts who have seen
some of his actual data reporting that Burzynskis data can never
be useful to show true merit or lack of merit of his drug because
of an absence of rigorously reported results and independent
verification and what we have here are bad trials that could
never get past peer review of any clinical trials cooperative
group. Indeed, even back in the 1990s, serious adverse reactions
were reported, mostly due to the hypernatremia. Now, thanks to
these additional two FDA reports (here and here), we finally see a
glimmering of light through the shroud of secrecy overlying the
Burzynski Clinic.  
  
Much of what is contained in these additional reports overlaps
what I discussed before, but there is one kind of violation that
does not. Its a truly egregious violation that I find very
difficult to comprehend, given how much it goes against every
tenet of clinical research and clinical trials that Ive been
taught and learned over the years. It appears on this Form 483,
where its discussed under Observation 1, and this other Form
483, where its discussed under Observation 1? and Observation
2. The brief versions are stated either as Failure to monitor
the progress of an investigation under your IND; an
investigation was not conducted in accordance with the signed
statement of investigator and investigational plan; or failure
to prepare or maintain adequate case histories with respect to
observations and data pertinent to the investigation. What does
this mean? Basically, it means that the BRI misclassified tumor
responses to therapy and adverse reactions. Worse, records that
would allow the validation of responses to therapy are missing.  
  
Before I get more specific, let me just briefly review what I mean
by tumor response. Whenever a drug is given to treat a tumor, the
response is the degree of tumor shrinkage that occurs in response
to the treatment. In general, there are four categories of results
defined and reported in clinical trials of new chemotherapeutic
agent:  
  
    Complete response (CR): The tumors shrink away
to the point that they are no longer detectable by physical
examination, imaging studies (MRI, CT scan, etc.), or tumor
markers. Obviously, this is the best possible result. This is
further divided into a pathological complete response, which means
that there are no detectable tumor cells in the resected tumor
specimen. Obviously, when this happens, it is a very good thing
and a very good prognostic sign. Sadly, it is not seen that often
in clinical trials.  
    Partial response (PR): This is usually defined
to mean that the tumors shrink by more than 50% (or, in the case
where tumor volume cannot be measured easily, tumor markers fall
by more than 50%) in response to therapy but remain detectable.
More recent definitions have at times loosened this criterion to
include tumors that shrink by 30% or more. Whatever the specific
criteria used, a certain degree of tumor shrinkage, or evidence of
tumor regression, defined before the clinical trial, must be
observed.  
    Stable disease (SD): The tumors either shrink
by less than the criteria for a PR or remain the same size. In
some trials, this definition may be broadened to include tumors
that increase in size slightly during therapy by less than,
depending on the trial, 0-25%, although Ive personally always
been suspicious of calling any detectable growth above random
variation in imaging measurements stable.  
    Progressive disease (PD): Tumors increase in
size on therapy and/or new metastatic tumors appear. This is
obviously strong evidence that in that patient the therapy did not
work.  
  
How tumor response is measured varies according to the tumor. Most
commonly RECIST criteria are used. For brain tumors, there are
criteria other than RECIST that are often used, such as the
Macdonald criteria or its update, the RANO criteria. Other methods
are being developed, as well. Obviously, there are pros and cons
associated with each method. However, when you write a clinical
trial, you have to pick one, stick with it, and use it
appropriately to classify clinical trial subjects as either having
CR, PR, SD, or PD. If these FDA reports are to be believed,
Burzynski failed to do that. Worse, he either destroyed, or
allowed to be destroyed, the original primary records used to make
these determinations.  
  
For example, the FDA notes that:  
  
    a. For 18 of 27 (67%) of subjects, the
investigator did not comply with the protocol requirements for
assessing the efficacy endpoint of tumor response and recorded
inaccurate assessments for tumor response in study records. For
example:  
  
        Study [REDACTED]:
Subjects 005297 and 007197 were inaccurately classified as
Complete Response (CR). Subjects 004721 and 008765 were
inaccurately classified as Partial Response (PR). Subjects 005974,
011373, 012184, 012206, and 12252 were inaccurately classified as
Stable Disease (SD).  
        Study [REDACTED]:
Subjects 06389, 11819, and 13660 were inaccurately classified as
CR. Subjects 21428 and 23399 were inaccurately classified as PR.  
        Study [REDACTED]:
Subject 009990 was inaccurately classified as CR. Subject 004881
was inaccurately classified as PR.  
        Study [REDACTED]:
Subject 006239 was inaccurately classified as PR. Subject 004240
was inaccurately classified as SD.  
  
    b. You did not have a QA monitor properly
monitor CRFs [case report forms] and subject records. The
investigator destroyed critical subject case history records
(target tumor measurement worksheets) or misplaced case history
records (original subject CRFs) for all subjects.   
  
Elsewhere, the FDA investigators note:  
  
    Your MRI tumor measurements initially recorded
at baseline and on-treatment MRI studies for all study subjects
were destroyed and are not available for FDA inspectional review.
  
  
The other Form 483 goes into a little more detail. Unfortunately,
much of what Id really, really like to know is redacted,
specifically how each of these patients didnt meet one or more of
the criteria for the given response level to which Burzynski
assigned them. Be that as it may, theres plenty of damning
information in these reports. For example, there are more examples
of Burzynskis failure to report adverse events (i.e.,
complications or bad things that happened to subjects being
treated according to his protocols) in a timely fashion as
required by the OHRP and the FDA. For example:  
  
    You failed to monitor as required by Section 16
of your Monitoring Plan. The investigator did not report adverse
events (AEs) experienced by study subjects, including 18 cases of
hypernatremia.   
  
Now lets look at what I mean when I said that Burzynski
misclassified AEs. AEs are graded according to a system known as
the Common Terminology Criteria for Adverse Events (CTCAE). The
CTCAE is nothing more than a list of AEs and SAEs (serious adverse
events) commonly encountered in oncology. Each AE term is defined
in the CTCAE and accompanied by a grading scale for severity. The
AE terms are also organized by System Organ Classes defined by the
Medical Dictionary for Regulatory Activities. The CTCAE is a long
list, which can be downloaded as a Microsoft Excel spreadsheet,
and its been updated several times. The most recent update is
v.4.0, released in May 2009. Most of the AEs discussed by the FDA
were from before that, so that CTCAE v.3.0 was being used to
classify them. AE grades generally range from grade 1 (minor),
grade 2 (moderate), grade 3 (severe), grade 4 (potentially
life-threatening), to grade 5 (death).  
  
Hypernatremia as I have discussed many times before, is a sodium
concentration in the blood that is too high. If the hypernatremia
is bad enough, it can be life-threatening. These reports document
at least two subjects whose hypernatremia was graded a 2 when it
should have been graded a 4. Of course, these two subjects pale in
comparison to the number of patients whose hypernatremia either
wasnt reported or wasnt reported for a long time. For example:  
  
    You failed to protect the rights, safety, and
welfare of subjects under your care.  
  
    Forty-eight (48) subjects experienced 102
investigational overdoses between January 1, 2005 and February 22,
2013, according to the Weekly List of Hospitalizations/SAE
[REDACTED] Overdose [redacted]/Catheter Infection report. Overdose
incidents have been reported to you on a weekly basis during your
Monday, Wednesday, and Friday staff meetings. There is no
documentation to show that you have implemented corrective actions
during this time period to ensure the safety and welfare of
subjects.   
  
This last sentence bears repeating: There is no documentation to
show that you have implemented corrective actions during this time
period to ensure the safety and welfare of subjects. So what we
have here is a report finding that not only did Burzynski fail to
report in a timely fashion a lot of SAEs, but that he tended to
downplay the severity of the ones that he did report. Some AEs
werent reported until as much as seven years later. Subjects also
werent removed in a timely fashion for toxicity. For instance,
one protocol stated that subjects would be removed after a third
episode of Grade 3 or 4 toxicity or any single Grade 4 toxic
effect that is truly life-threatening or is not easily and
rapidly reversible. Of course, one wonders how the IRB could have
approved such wording, as there is no distinction between truly
life threatening and life threatening in the definition of Grade
4 toxicity. One patient had seven instances of Grade 3 or 4
toxicity but was not terminated from the trial until over a month
after the seventh.  
  
Other violations, although not as egregious, were nonetheless
still quite bad. For instance, the informed consent didnt include
a statement of any additional costs to the subject that might
result from the research. Several examples of patients who signed
the informed consent days to weeks before they signed the billing
agreement were presented. In addition, the Burzynski Clinic didnt
keep adequate records of its stocks of antineoplastons and could
not account for how much was used by subjects. The number of bags
of antineoplastons unaccounted for are truly staggering. One
subject had 159 bags unaccounted for. Others ranged from one to 23
bags unaccounted for. Record keeping this sloppy would shut down
nearly any clinical trial in and of itself.  
  
The most serious violations of regulations designed to protect
human subjects are clearly: (1) the BRI IRBs misuse of the
expedited approval process as an excuse to treat any patient
Burzynski wanted to treat; (2) failure to keep original records to
document baseline tumor measurements and tumor response; and (3)
failure to report AEs and SAEs properly. However, there are a
whole bunch of other lesser, but still serious, violations, so
many that I find it hard to fathom.  
  
**The central mystery of the Stanislaw Burzynski saga**  
As a translational researcher who frequently works with clinical
investigators, I just cant figure out how Burzynski keeps getting
away with it. Either the FDA is more impotent than I had thought,
or Burzynski has some serious pull with some powerful people. If
my university received even one report like one of the previous
FDA reports about Burzynski, it would be quite possible that all
federal research funding to the university for biomedical research
would be suspended until the university fixed the problems to the
satisfaction of the OHRP and FDA. Yet the FDA has found Burzynski
to be deficient in numerous areas of human subjects protection
multiple times over the last decade. These latest FDA Form 483
reports tell us nothing new, really, other than that Burzynskis
claims of complete responses are very likely nonsense.  
  
If theres one thing Ive learned over the years about Brave
Maverick Doctors, its that they often come to believe that the
rules dont apply to them. They crave the respectability of
science, of course, but they are too impatient or too arrogant to
play by the rules of science. Unfortunately, that often includes
the rules designed to protect human subjects in clinical trials.
Weve seen it before with Mark and David Geier, who formed their
own IRB stacked with their cronies. Weve now seen it with
Stanislaw Burzynski, who formed his own IRB. In the world of these
Brave Maverick Doctors, the IRB apparently exists not to protect
human subjects, but is instead viewed as a formality to funnel
patients into whatever they want to do to treat them.  
  
Ive said it before, and Ill say it again, though: The central
mystery behind Burzynski is how hes gotten away with what hes
gotten away with for nearly 37 years. It is the single question
about Burzynski whose answer I want to know more than the answer
to any other question about him before I shuffle off this mortal
coil. Why does the FDA keep investigating him, finding serious
violations, and giving him, in essence, a slap on the wrist? Since
2000, hes been investigated multiple times, and hes received FDA
warnings for his violation of human subjects regulations. True,
this is the first time since the 1990s that the FDA has taken
substantive action against him, issuing a partial clinical hold
that appears unlikely to be lifted any time soon, if ever. Still,
Im worried. If Burzynski comes up with a response that satisfies
the FDA, he could conceivably have his same old bogus trials
resurrected yet again. Why doesnt the FDA shut down any clinical
trials done by the BRI and Burzynski Clinic permanently? Why
doesnt it at least shut down the BRI IRB, which would have the
effect of shutting down the Burzynski Clinic because no reputable
IRB would ever approve the clinical trials that Burzynski
proposes? To get its scientifically dubious clinical trials
approved, Burzynski needs an IRB run by an old crony of his from
Baylor (Carleton Hazelwood) who just so happens to be the chairman
of the board of the BRI, a massive conflict of interest. Any other
IRB with so many repeated violations and such a massively obvious
conflict of interest would be shut down. Any other research
institute with so many violations of FDA regulations would not be
allowed to do clinical trials of any kind.  
  
Yet the BRI persists. No matter how many times the FDA
investigates it, no matter how many warning letters the FDA sends
it, the BRI continues. In the 1990s, a powerful Congressman, Rep.
Joe Barton, put serious pressure on the FDA through public
hearings, the public dressing down of then-FDA director David
Kessler, and who knows what behind-the-scenes pressure tactics to
let Burzynski open clinical trials of antineoplastons. As
Burzynskis own lawyer put it, those trials were all an artifice,
a vehicle we and the FDA created to legally give the patients
Burzynskis treatment. Since the FDA folded in response to
Bartons pressure in the 1990s, I havent heard news of Barton
applying pressure to the FDA again over its investigations of
Burzynski. True, the Republicans were in the minority during four
years of the period since then, but even after they won the House
back in 2010 I havent heard of any political pressure being
brought to bear on the FDA. So I wonder: Is the FDA still so cowed
from its previous experience that it cant just pull the plug and
shut Burzynski down completely?  
  
It boggles the mind.  
  


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[**http://www.usatoday.com/story/news/nation/2013/11/15/stanislaw-burzynski-cancer-controversy/2994561/**](http://www.usatoday.com/story/news/nation/2013/11/15/stanislaw-burzynski-cancer-controversy/2994561/)

**Doctor accused of selling false hope to
families**  
**A questionable cancer cure**  
**Liz Szabo, Rene Alston, Keith Carter, Karl
Gelles, Tory Hargro and Jerry Mosemak, USA TODAY**

  
USA TODAY investigates Houston doctor Stanislaw Burzynski, who has
been treating the terminally ill with unconventional treatments
for 36 years. While supporters see him as a hero, critics say he
exploits the vulnerable.  
  
    Liz Szabo, Rene Alston, Keith Carter, Karl
Gelles, Tory Hargro and Jerry Mosemak, USA TODAY  
  
USA TODAY investigation finds experts questioning why Houston
doctor is allowed to continue to offer his alternative cancer
treatment with antineoplastons.  
  
LINDEN, N.J.  On the last day of his life, Josia Cotto's parents
gave him a choice.  
  
The 6-year-old boy had been fighting an inoperable brain tumor for
10 months. When his mother, Niasia Cotto, found him in his bed,
unresponsive and unable to open his eyes, "we knew there was
nothing else that we could do," she said.  
  
An ambulance took Josia to a hospice room at a local hospital. His
parents covered him in a soft, blue-and-white blanket, hugged him
and held his small hand for the last time.  
  
"We told him the choice was his, whether to keep fighting or be in
peace with God," said his mother. "He chose."  
  
Josia's parents would have paid any price to save him.  
  
A Texas doctor, two months, earlier, had given them one: $25,000
upfront, by cash or check.  
  
Clinging to hope, the Linden, N.J., couple took Josia to see
Stanislaw Burzynski, a Houston doctor claiming to be able to do
what no one else can: cure inoperable pediatric brainstem tumors.  
  
Virtually any other doctor might have recited the same sad
statistics: Although doctors can now cure 83% of pediatric cancers
in the U.S., there is usually no hope for kids with Josia's tumor.
Perhaps 5% survive five years.  
  
A look at a doctor's cancer claims.(Photo: Jerry Mosemak, USA
TODAY)  
  
Burzynski  an internist with no board certification or formal
training in oncology  has said publicly that he can cure half of
the estimated 200 children a year diagnosed with brainstem tumors.
The Cottos were told that treatment could cost over $100,000,
mostly out of pocket, because insurance plans often refuse to
cover Burzynski Clinic treatments.  
  
Burzynski, 70, calls his drugs "antineoplastons" and says he has
given them to more than 8,000 patients since 1977.  
  
He originally synthesized these sodium-rich drugs from blood and
urine  the urine collected from public parks, bars and
penitentiaries. Although they've been made in a lab since 1980,
they still carry a distinctive and unpleasant odor. And while the
experimental drugs have not been approved by the Food and Drug
Administration, Burzynski has described them like the holy grail
of cancer therapy: safe, natural and highly effective. He has also
prescribed them as a treatment for AIDS, lupus and other
conditions.  
  
Some patients are convinced that he saved their lives.  
  
Mary Jo Siegel of Ventura, Calif., says she believes Burzynski
cured her lymphoma. James Treadwell from Coronado, Calif., credits
Burzynski with curing his brain tumor. Jenny Gettino of Syracuse,
N.Y., says Burzynski cured her daughter of an infant brain tumor.  
XXX Burzynski0828  
  
James Treadwell, of Coronado, Calif., is a proponent of
alternative cancer treatments by doctor Stanislaw Burzynski. He
was treated for a brain tumor.(Photo: Robert Hanashiro, USA TODAY)  
  
Yet the National Cancer Institute says there is no evidence that
Burzynski has cured a single patient, or even helped one live
longer. He has not backed up his claims by publishing results from
a randomized, controlled trial  considered the gold standard of
medical evidence  in a respected, peer-reviewed journal.  
  
And Burzynski's drugs pose a risk of serious harm, including coma,
swelling near the brain and death, according to the NCI and
informed consent documents that patients sign before beginning
treatment. While Burzynski has touted his treatments as an
alternative to chemotherapy, a 1999 NCI study found that
antineoplastons can cause many of the same side effects as
conventional chemo: nausea, vomiting, headaches, muscle pain,
confusion and seizures.  
  
Many blame the system for failing to protect patients.  
  
"He's a snake oil salesman," says pediatric oncologist Peter
Adamson, a professor of pediatrics and pharmacology at Children's
Hospital of Philadelphia. "This has gone on for so many years,
it's really unbelievable."  
  
For 36 years, critics say, Burzynski has been selling false hope
to desperate families at the most vulnerable time of their lives.  
  
"When you want so hard to believe something, you end up listening
to your heart and not your head," says Lisa Merritt of Armuchee,
Ga., whose husband, Wayne, was treated briefly by Burzynski in
2009. The couple say that Burzynski misled them about the type of
treatment that would be offered, as well as the cost. Burzynski,
she says, is "the worst kind of predator."  
  
There are many reasons why Burzynski has been able to stay in
business so long. He has benefited from state laws that limit the
Texas Medical Board's authority to remove his license, as well as
the ability of terminally ill patients to collect damages. His
devoted followers are willing to fight for him. He also has
exploited the public's growing fascination with alternative
medicine and suspicion of the medical establishment.  
  
At times, Burzynski also has had an especially influential ally:
the Food and Drug Administration.  
  
FDA CHANGES COURSE  
  
Although "there were some stormy relations with the FDA" in the
past, Burzynski said in an interview, "now, we have a productive
relationship."  
  
For years, the FDA tried to prevent Burzynski from prescribing
unapproved drugs.  
  
In 1995, a federal grand jury indicted Burzynski on 75 felony
charges, including criminal contempt, mail fraud and violations of
the Food, Drug and Cosmetic Act. As a condition of his bail, a
judge ordered him to stop prescribing antineoplastons. For a time,
it looked as if Burzynski might never treat another patient.  
  
Dozens of Burzynski's patients flocked to Washington to defend
him, arguing that taking away antineoplastons was akin to a death
sentence. Siegel, who credits Burzynski with curing her lymphoma
22 years ago, has testified on his behalf five times  once at his
criminal trial and four times at hearings on Capitol Hill.  
  
Facing both a political and public relations firestorm, the FDA in
1996 abruptly changed course. It offered to allow Burzynski to
continue treating patients, but only through an official trial.  
  
"With one stroke of the pen, the FDA made legal what it had
previously said was illegal," says Burzynski's attorney, Richard
Jaffe.  
  
Yet even Jaffe has acknowledged that the trial  now in its 17th
year  was more about politics than science. In his 2008 memoirs,
Galileo's Lawyer, Jaffe called it "a joke."  
  
"It was all an artifice, a vehicle we and the FDA created to
legally give the patients Burzynski's treatment," Jaffe said.  
  
"With political help, you can get the FDA to say yes," says
Siegel, 63.  
  
The indictments led to two trials. In 1997, one of Burzynski's
criminal trials ended in a hung jury; the other, an acquittal.  
  
Today, the FDA refuses to comment on Burzynski.  
  
NO NEW DRUG APPLICATION  
  
Even his staunchest supporters wonder why Burzynski's drugs are
nowhere close to receiving FDA approval.  
  
"He's curing cancer," says Siegel, who co-founded the Burzynski
Patient Group to spread the word about his therapies. "So why, why
won't the FDA approve it?"  
  
Like many of Burzynski's supporters, Siegel suspects that the
medical community and drug industry are aligned against him.  
  
"Why does a doctor who can produce such extraordinary results
continue to be attacked today?" Siegel asks. "The reason is
because Dr. Burzynski and his patented discovery pose the greatest
threat to an entrenched medical monopoly."  
  
In fact, the FDA hasn't had a chance to approve Burzynski's drugs.
He has never officially asked.  
  
Although Burzynski said he has completed 14 intermediate-phase
studies, he has yet to file a new drug application, the final step
toward getting a drug approved.  
  
That hasn't stopped Burzynski from using his relationship with the
FDA to recruit patients.  
  
Stacey Huntington says she took her daughter to see Burzynski last
year partly because the FDA's oversight made his therapies seem
safer and more promising. "My fear took us to Houston, and the
hope he gave us made us proceed," says Huntington, of Chehalis,
Wash.  
  
In an interview, Burzynski said developing new drugs is complex
and takes time.  
  
Yet the FDA has approved 108 cancer drugs since Burzynski began
his trial.  
  
Cure rates for one type of pediatric brain tumor  medulloblastoma
 are now 85%, according to St. Jude Children's Research Hospital
in Memphis. Doctors can cure 95% of kids with Hodgkin lymphoma (a
cancer of the lymph system), acute lymphoblastic leukemia (a blood
cancer) and retinoblastoma (an eye tumor).  
  
Fran Visco, president of the National Breast Cancer Coalition,
describes the FDA's tolerance of Burzynski as "outrageous."  
  
"They have put people at risk for a long time," says Visco, an
attorney and breast cancer survivor. "That's completely
unacceptable. How can anyone look at these facts and believe that
there is a real clinical trial going on ... rather than just using
the FDA and the clinical trial system to make money?"  
  
Burzynski dismisses criticism of his work, referring to his
detractors as "hooligans" and "hired assassins."  
  
As for criticism from former patients, Burzynski says, "We see
patients from various walks of life. We see great people. We see
crooks. We have prostitutes. We have thieves. We have mafia
bosses. We have Secret Service agents. Many people are coming to
us, OK? Not all of them are the greatest people in the world. And
many of them would like to get money from us. They pretend they
got sick and they would like to extort money from us."  
  
History will vindicate him, Burzynski says, just as it has
vindicated other persecuted medical "pioneers," such as Louis
Pasteur. In the future, Burzynski says, everyone will use his
therapies, and the cancer treatments used today  such as surgery,
chemotherapy and radiation  will be regarded as barbaric. "There
will be a time when people will see the light," he says, "and our
treatments will be used by everyone."  
  
FDA IMPOSES NEW RESTRICTIONS  
  
The FDA's patience with Burzynski apparently wore out after Josia
died.  
  
In a report sent to the FDA after the boy's death, Burzynski's
staff acknowledged that his last blood sample, taken the day he
passed away,showed a blood sodium level of 205 millimoles per
liter, a level that is typically fatal. Burzynski's staff blamed
that reading on a "false laboratory report based on a contaminated
sample."  
  
Yet hypernatremia is one of antineoplastons' most common side
effects, known to doctors for two decades.  
  
One of Burzynski's own informed consent documents  the form that
patients sign before they begin treatment  put the risk at 21%.  
  
On July 30, 2012  six weeks after Josia's death  the FDA forbade
Burzynski from giving antineoplastons to any new children.  
  
Six months later, the FDA expanded its "partial clinical hold,"
forbidding Burzynski from giving the drugs to new adult patients,
according to the Burzynski Research Institute's 2013 filing to the
Securities and Exchange Commission. About 10 patients who were
already receiving antineoplastons were allowed to continue, to
avoid interruption of care.  
  
According to FDA inspections performed after Josia's death,
Burzynski has failed to report at least 18 hypernatremia cases.  
  
The FDA publicly announced the restrictions on Burzynski's
clinical trial for the first time in September.  
  
According to the FDA, the Burzynski institutional review board 
an outside body charged with protecting patients  failed that
most basic duty. In a letter announcing the restrictions, the
agency said it has "no assurance" that the board was "adequately
protecting the rights and welfare of the human subjects."  
  
The FDA based its decision on "objectionable conditions" and a
"continuing pattern of deficiencies found during the last three
inspections," the letter said.  
  
FDA inspectors also faulted Burzynski personally, as principal
investigator of the study, according to inspections conducted from
January to March. Copies of these reports were obtained through a
Freedom of Information Act request. Addressing Burzynski, the
inspectors wrote, "you failed to protect the rights, safety and
welfare of subjects under your care."  
  
Inspectors charged Burzynski, as principal investigator, with a
variety of other serious offenses, some dating to 2001. Among
them:  
  
 Inflating success rates in 67% of cases, by inaccurately
reporting how tumors responded to treatment.  
  
 Destroying patients' original records.  
  
 Failing to report "unanticipated problems" to the institutional
review board  sometimes for six or seven years.  
  
In the inspections conducted this spring, officials noted four
cases from 1998 or 1999 in which patients were hospitalized for
serious issues  such as pneumonia, lack of consciousness or
bleeding in the skull  that Burzynski researchers failed to
report until 2005. The FDA found similar problems in a 2001
inspection, when officials noted that Burzynski failed to report
problems such as pneumonia, blood infections and pancreatitis, a
life-threatening inflammation of the pancreas.  
  
 Failing to protect patients from overdosing.  
  
Forty-eight patients suffered a total of 102 drug overdoses from
2005 to 2013.  
  
While the overdoses made some of these patients excessively
sleepy, one had a seizure and another was hospitalized in
intensive care with a breathing tube.  
  
This represents a continuing problem, dating to reports of
overdoses in inspections as early as 2001.  
  
Burzynski's review board also repeatedly rubber-stamped his
requests to give patients antineoplastons outside of a clinical
trial, the FDA's September letter suggests. In some cases, those
decisions were made without consulting patients' medical records,
or were made not by oncologists, but by a single member of the
board, a "water rehabilitation" specialist with no medical
training.  
  
Although researchers do sometimes provide experimental drugs
outside of clinical trials, exceptions should be rare, with
perhaps one or two cases per trial, Adamson says. In Burzynski's
case, these "compassionate use" exceptions were common, FDA
records show.  
  
Enrolling patients for compassionate use can be lucrative.
Although researchers cannot charge for experimental drugs,
Burzynski does bill patients for related supplies and services.  
  
In Burzynski's defense, Jaffe notes that inspection reports
represent preliminary findings. The FDA has not yet issued final
conclusions.  
  
And Burzynski has taken issue with many of the FDA's findings.  
  
In his written response about the FDA's claims that he inflated
his success rates, Burzynski said that he "complied with all
criteria for evaluation of response and made accurate assessments
for tumor response."  
  
As for overdoses, Burzynski said in an interview that his staff
works hard to train patients and their families to administer
antineoplastons correctly.  
  
None of the overdoses was fatal, he said.  
  
"The amount of medication that these patients receive is not
dangerous," Burzynski said. "At worst, they would sleep for a few
hours."  
  
Visco, the breast cancer advocate, says she's encouraged to hear
that the FDA has put Burzynski's trial on hold.  
  
"It is about time that the FDA stepped in to stop Burzynski from
subjecting more patients to harm," she says. "I do not know why it
took so long."  
  
BURZYNSKI STILL HAS OPTIONS  
  
The FDA can't put Burzynski out of business. No matter what
happens to his trial, Burzynski holds a license to practice
medicine in Texas.  
  
So does his son, Gregory Burzynski, a doctor who's helping to
carry on his father's business. As vice president of the Burzynski
Clinic, his son, 34, works closely with his father and "oversees
many operations" of the clinic, according to its website.  
  
These days, doctors at the Burzynski Clinic are looking beyond
antineoplastons. They mostly prescribe chemotherapy.  
  
That's a huge shift. During Burzynski's criminal trial in the
1990s, patients who rallied to his defense carried signs reading,
"Say No to Chemo."  
  
But the Texas Medical Board, which has repeatedly tried and failed
to put Burzynski out of business over the years, still questions
Burzynski's care.  
  
The board charged Burzynski in 2010 with violating state medical
standards by prescribing legal cancer drugs in "random" and
unapproved combinations, with no known benefits but clear harms.  
  
Burzynski got those charges dropped in 2012, by successfully
arguing that he didn't sign any of the prescriptions in question.  
  
Burzynski is scheduled to go before the medical board again in
January, based on a complaint filed by Stacey Huntington, whose
daughter was treated with antineoplastons for a brain tumor. At
the meeting, a board panel "will hear the case and make
recommendation to the full board about what disciplinary action,
if any, is appropriate."  
  
Huntington, who paid Burzynski nearly $34,000 for about six weeks
of care, says she's concerned about both billing irregularities
and the quality of her daughter's treatment. Her daughter, Abra
Hall, 27, developed a life-threatening blood infection called
sepsis after leaving the clinic to continue treatment at home. The
infection developed in a catheter in Hall's chest, which was used
to administer the antineoplastons, Huntington says. One month
after developing sepsis, Hall was hospitalized again with a lung
infection. Hall also developed serious complications from high
doses of steroids, Huntington says.  
  
Huntington says she decided to speak out to prevent other families
from being taken advantage of.  
  
"When you get a diagnosis of cancer, you are pretty vulnerable,"
she says. "I think they take advantage of that."  
  
COTTOS NOT SURE WHAT TO THINK  
  
Niasia and Jose Cotto hold a photo of son Josia in their Linden,
N.J., home on Oct. 12. The boy died of a brain tumor.(Photo: Todd
Plitt, USA TODAY)  
  
No one told Josia's parents about any of this.  
  
Not Burzynski. Not the FDA.  
  
Jose and Niasia Cotto had no idea that their son's death prompted
an investigation by the FDA, until they were contacted by USA
TODAY.  
  
The Cottos had long believed that Burzynski could have cured their
son if only they had taken Josia to see him first, before giving
him radiation and chemotherapy. They had even hoped to launch a
non-profit, A Life for Josia Foundation, to help other children
with cancer gain access to Burzynski's treatment.  
  
Now, they don't know what to think.  
  
Although more than a year has passed since they lost their son,
the Cottos say they see reminders of him everywhere. Niasia, 32,
says she feels his presence in simple things, such as the light of
a bright star on a dark night.  
  
"He's still with us," says Jose, 33. "I know God had his plan and
his purpose for Josia."  
  
Doctor Stanislaw Burzynski makes his way to the federal courthouse
for jury selection in his 1997 criminal trial, as supporters
demonstrate outside the courthouse Jan. 6, 1997, in Houston.
Burzynski pleaded innocent to a 75-count federal indictment that
charged him with mail fraud and violating Food and Drug
Administration regulations in the use of antineoplastons,
experimental substances he created to treat cancer. One of his
criminal trials ended in a hung jury. In the other, he was
acquitted.  David J. Phillip, AP  
  



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