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Globalization of Clinical Trials – Promise and Reality Zvi Ladin, Ph.D. Principal Boston MedTech Advisors More Experience ► Better Results 1 Outline • Ethical principles • Historical perspective • Registration requirements • FDA acceptance of foreign clinical data • Global trends in conduct of clinical trials • Global opportunities • Global challenges More Experience ► Better Results 2 Ethics (Example #1) • New ‘block buster’ drug being • • developed • BIG profits? Need to quickly test it Some questions regarding side effects • • • Could be serious Need large number of patients for testing Too costly (and too risky?) to study in developed countries • Solution • • Go to Africa Paint as ‘humanitarian effort’ • Voilà – a ‘blockbuster’ movie More Experience ► Better Results 3 In the News (Example #2) • Federal Indictment • • • Synthes, Medical Device Maker, Accused of Improper Marketing • • A medical device maker, Synthes Inc., and four of its executives were indicted Tuesday on federal charges that they improperly promoted a bone filler for purposes not approved by the Food and Drug Administration, including encouraging its use in what prosecutors called “unauthorized” human trials. • • • • • • • Norian - $28M Synthes (parent company) - $8M Executives indicted: • By BARRY MEIER Published: June 16, 2009 Criminal misdemeanor Shipping unapproved medical device Possible prison sentence of 1 year Possible fines: Michael B Huggins, President, Synthes Spinal Division Thomas E Higgins, Senior VP, Global Strategy Richard E Bohner, VP Operations John J Walsh, Regulatory Affairs Executive Unauthorized trial of using bone filler in spinal procedures Patient population: • • ~200 patients treated 3 patients died “They put their profits ahead of responsible business practices and the truth,” Michael L. Levy, the United States attorney, said in a statement. More Experience ► Better Results 4 Understanding the Regulator • Global ethical / legal framework • Nuremberg trials • Helsinki Declaration • Local implementation • Culture • Language • Infrastructure • Economic pressures More Experience ► Better Results 5 Protection and Improvement of Public Health Information Supply Information Demand • Clear new drugs / • Treat large populations technologies expeditiously • • • Low incidence Quick studies • High severity • Limited populations • Adverse events • Lead to…. • Limited duration • Complications Limited Information • Public outcry • Adverse events (severity, incidence) Where patients come first VIOXX® (rofecoxib) More Experience ► Better Results 6 Developing a Legal Framework • 1947 – Nuremberg Code • 1964 – Declaration of Helsinki adopted – World Medical Assoc USA Europe • 1966, NEJM – Henry Beecher, MD • 1960’s – Patient consent – FDC • 1970’s – IRB review of clinical • Maurice Pappworth, MD protocols • 1972 – NIH established OPRR (Office for Protection from Research Risks) • Risks and benefits of research • 1981 – FDA requires written patient consent More Experience ► Better Results • 1967 – Human Guinea Pigs • 1960’s – Patient consent • 1970’s – MDD • Competent Authorities • Notified Bodies 7 1998 Office of Inspector General (OIG) Report – Clinical Research’s Shifting Environment • Funding – from public to private • NIH industry • Nature – from single site to multi-center • Limited information to local IRB • Size and numbers More Experience ► Better Results 8 1998 OIG Report – Revamping the IRB • Overwhelmed Local IRB • Time and expertise limiting review • New ethical issues (e.g. genetic screening) • Evaluating IRB Effectiveness • Conflict of Interest Inside the IRB • Part of the organization that gains from research • Limited Training of IRB Members and Researchers More Experience ► Better Results 9 2004 – Clinical Trial Outcry (or Example #3) • GlaxoSmithKline (GSK) Paroxetine treatment of depression in children • • Attorney General of NY sued company Allegation • Company selectively published positive partial results • Off-label promotion of drug by company • Settlement • GSK published all study results on Web • 150 Scientists and organizations signed the Ottawa statement • Mandatory trial registration • International Committee of Medical Journal Editors (ICJME) of 12 • leading medical journals – no publication of unregistered studies Ministerial Summit on Health Research in Mexico • • WHO 52 Countries More Experience ► Better Results 10 Global Goals Only 25% of Americans think that the pharmaceutical industry is doing a “good job” – similar to reputation of….tobacco industry [Godlee, F. BMJ 2005(330):1224, 1229] More Experience ► Better Results 11 Restoring Public Trust Patient • Full disclosure • Procedure • Alternatives • Risk / Benefits • Beneficiaries • Financial interests Regulators • Study approval • • National regulatory authority Local committee • IRB • Helsinki committee • Complete and comprehensive information submittal • • More Experience ► Better Results Community • Clinical • • • Disclosure Conferences Publications • Public • • Registries Patient groups Related studies Device safety 12 Clinical Trial Registration • US FDA requirement – ClinicalTrials.gov • • • • • • • Established under FDAMA (1997) First version – February 29, 2000 Initially mandated for only drug treatment of life threatening diseases Expanded to include all US trials October 2003 – 1000th study registered Registration for non-life threatening treatments – RECOMMENDED! June 2009 • • • WHO International Registry • • 50,000 daily visitors 40 million monthly ‘hits’ Established 2004 Date US Registration WHO Registration 2003 (October) 1000 0 2004 13,000 0 2006 (June) >40,000 12,000 2009 (June 18) 74,734 50 states 167 countries > 72,000 (June 2008) Enforcement • • FDA (limited to life-threatening treatments) WHO (none) More Experience ► Better Results 13 WHO Clinical Trial Registry • http://www.who.int/ictrp/en/ • Major components of trial including: • Contact information • Sponsor / source of support • Countries • Interventions • • • • • Key inclusion / exclusion criteria Study type Sample size Recruitment status Outcomes • No requirement to report results More Experience ► Better Results 14 Time-To-Market New technologies must demonstrate enhanced outcomes and cost effectiveness to be covered. Cost Effectiveness Outcomes Outcomes Efficacy Efficacy Efficacy Safety Safety Safety 1980’s 1990’s 2000’s More Experience ► Better Results Time-To-Market Acceptance Time-To-’Market Acceptance’ is Increasing 15 FDA Acceptance of Foreign Data (IND) • Final Rule Published (effective October 27, 2008) • 21 CFR Part 312 • Non-IND foreign clinical studies • Previous Requirement • Adherence to ethical principles stated in 1989 Helsinki Declaration (World Medical Association) • Current Requirement – GCP • • Includes review and approval by independent ethical committee (IEC) Non-compliant studies • Have to be submitted • Cannot be accepted as support More Experience ► Better Results 16 FDA Acceptance of Foreign Data (PMA) • 21 Section 814.15 (last amended December 2, 1986) • Valid data • Conformance with Helsinki Declaration or local laws and regulations • Whichever accords greater protection to the human subjects • If data is sole basis for submission: • Data applicable to US population and medical practice • Competent clinical investigators • Data can be audited and validated by FDA More Experience ► Better Results 17 More Experience ► Better Results 18 Economic Drivers Increase regulation Move studies to: • Increase • Less regulated countries • Costs • Faster study initiation • Clinical environment • Lower regulatory overhead • Patient recruitment Time • Longer • Time • Investigators • Monitors • • Effort • Less expensive cost of living • Lower costs • However….. • Higher More Experience ► Better Results 19 Remember Murphy*! • Poor infrastructure • Clinical complications • Simple problems could become significant, severe and….expensive • Poor regulatory infrastructure • May limit acceptability of data • Poor study control • May jeopardize collection of data • May disqualify patients • Hence…. • Regulatory submission denial *Anything that can go wrong…will! More Experience ► Better Results 20 Global Trends in Clinical Trials Conduct Observation (Cause?) Observation (Effect?) • 1980’s – increased • Migration of clinical trials regulation in US (FDA) • to Europe FDA acceptance of European clinical data • European Union Clinical • Migration of clinical trials Trial Directive (2001) to India, Russia and China • More Experience ► Better Results Tassignon JP. The globalization of clinical trials. Applied Clinical Trials (2006) 21 Density of Actively Recruiting Clinical Sites of Biopharmaceutical Clinical Trials Worldwide (4/2007) Ref: Trends in the globalization of clinical trials, Fabio A. Thiers, Anthony J. Sinskey & Ernst R. Berndt Nature Reviews Drug Discovery 7, 13-14 (January 2008) US Registry Density is in per country inhabitant (in millions; based on 2005 population censuses); darker orange/red denotes a higher density. The trial density and average relative annual growth rate in percent is shown for selected countries. The countries in grey had no actively recruiting biopharmaceutical clinical trial sites as of 12 April 2007. More Experience ► Better Results 22 Shifting Environment – Regional Distribution of Trial Types North America [%] Trial Type Western Europe [%] Oceania [%] 4/2007 4/2008 4/2007 4/2008 4/2007 4/2008 Early 62.4 23.9 21.1 18.4 4.2 24.6 Confirmatory 55.6 61.0 23.9 59.9 3.8 65.0 PostMarketing 52.7 15.2 33.0 21.7 2.3 10.3 Trial Type Eastern Europe [%] Latin America [%] Asia [%] (4/2007 to 4/2008) Middle East [%] increased compliance in 2008? Africa [%] 4/2007 4/2007 4/2007 4/2008 4/2007 4/2008 4/2007 4/2008 4/2007 4/2008 Early 6.7 21.4 2.5 70.8 1.7 12.2 0.7 17.3 0.7 17.9 Confirmatory 7.4 67.5 3.9 13.4 3.6 72.3 0.9 65.4 0.9 67.3 PostMarketing 4.6 11.2 2.8 9.9 2.9 15.5 0.9 17.4 0.8 14.9 Ref: Trends in the globalization of clinical trials, Fabio A. Thiers, Anthony J. Sinskey & Ernst R. Berndt Nature Reviews Drug Discovery 7, 13-14 (January 2008) More Experience ► Better Results 23 Economic-Based Distribution of Clinical Trials Global Distribution of Clinical Trials Latin America (WHO Database – 10/2008) • Streamlined laws make Latin America attractive to sponsors • October 2008 – 20% growth in the number of international clinical trials over four years • 3.1% of all active trials in low-income countries • 6.8% of all active trials in low – middle-income countries • 90.6% of all active trials Country Open Trials Brazil 323 in OECD countries Mexico 292 Colombia 107 (Organization of Economic CoOperation and Development) Ghersi D and Pang t. The Lancet; (2008) 372(9649):1531-1532 More Experience ► Better Results 24 Global Trends • Harmonization • Global Harmonization Task Force (GHTF) • Harmonize medical device regulations world-wide • Founding members (1992) • Regulatory authorities from Australia, Canada, EU, Japan and US • Five task forces, including one focused on clinical investigations • EU (March 2009) – European requirement for proof of clinical effectiveness (in addition to safety) • Global acceptance (and requirement) of GCP compliance • New FDA rule More Experience ► Better Results 25 Global Opportunities • Potential Advantages of Foreign Clinical Studies (advertisement by an Indian CRO) • Diverse population • Genetically • Culturally • Socio-economically • Large numbers of target patients • Quicker studies • Regulatory approval • Medical infrastructure • Language • Costs More Experience ► Better Results 26 Global Challenges – I • Regulatory Approval • • Economic / social progress leads to increased regulation • India – consideration of registration requirement linked to regulatory oversight • India + China – Association of journal editors established policies on trial registration Medical Infrastructure • Addressing adverse events • Access to healthcare system • Access to specialists • • Addressing complications Training investigators More Experience ► Better Results 27 Global Challenges – II • Language • • Translation • Communication with patients, investigators Validated questionnaires (e.g. QOL) • Culture • • • Patient – clinician relationship Collecting medical history (family, personal) Medical tests • Geography • • Time Distance • Support More Experience ► Better Results 28 Global Limitations • Review clinical plan with target regulators • • In trial country In target market • Applicability of Clinical Data • Will target market accept trial data? • Regulators? • Clinical market? Ethics and Profitability • Validity of ‘Pooling’ Data • Cost Information • Will it have any bearing on target market? • Cost – Effectiveness Analysis • Is reimbursement an issue? More Experience ► Better Results 29 Ethical Dilemmas (to ponder) • Patient Enrollment • • • Monetary incentive Clinician / patient trust (pressure?) Full disclosure (risks, benefits, incentives) • Study Conduct • • • • Payment to investigators Patient access to healthcare Information dissemination to patients Protocol requirements (tests, travel) • Post-study • Availability of treatment More Experience ► Better Results 30 Contact Zvi Ladin, Ph.D Principal Boston MedTech Advisors, Inc. 990 Washington Street Dedham, MA 02026 Ph 781.407.0900 Fax 781.407.0901 [email protected] www.bmtadvisors.com More Experience ► Better Results 31