EORTC position on the place for transparency in the clinical trials regulation



Similar documents
Strong support. Remaining concerns

The EU Clinical Trial Regulation A regulator s perspective

Joint Position on the Disclosure of Clinical Trial Information via Clinical Trial Registries and Databases 1 Updated November 10, 2009

The European Clinical Trials Framework Update on the Draft Clinical Trials Regulation

White Paper The EU Clinical Trials Regulation Main Changes and Challenges

Clinical Trial Transparency. What is available?

The role, duties and responsibilities of clinical trials personnel Monitoring: rules and recommendations

Federal agency for medicines and health products

EFPIA Principles for the Development of the EU Clinical Trials Portal and Database

Adoption by CHMP for release for consultation November End of consultation (deadline for comments) 31 March 2011

This is meant to be a narrative rather than a critical summary I have a lot of questions about the proposal but I will look into these separately.

Submission of comments on 'Policy 0070 on publication and access to clinical-trial data'

The EU portal and database

LEBANESE MINISTRY OF HEALTH DIRECTIVE

Clinical research: where are we with the new (Paediatric) RC trial Regulation

Guidance for the format and content of the protocol of non-interventional post-authorisation safety studies

How to search the EU Clinical Trials Register

EMA Update Clinical Trials

Official Journal of the European Union. (Acts whose publication is obligatory)

PHV- 4 version 1 ELECTRONIC ADVERSE DRUG REACTION REPORTING

R&D Administration Manager. Research and Development. Research and Development

The Importance of Following the PROTOCOL in Clinical Trials

INTERNATIONAL FRAMEWORK FOR ASSURANCE ENGAGEMENTS CONTENTS

Submission of comments on 'Policy 0070 on publication and access to clinical-trial data'

Template for essential information to be provided for proposals including clinical trials / studies / investigations

This survey addresses the broader, organizational context in which Big Data projects operate. A companion survey addresses individual projects.

CLINICAL RESEARCH PROTOCOL CHECKLIST

The Clinical Trials Regulation EU No 536/2014: and Phase I trials

Principles for Responsible Clinical Trial Data Sharing

The New EU Clinical Trials Regulation: The Good, the Bad, the Ugly

History and Principles of Good Clinical Practice

Guidance for Industry and FDA Staff FDA Acceptance of Foreign Clinical Studies Not Conducted Under an IND Frequently Asked Questions

Response of the German Medical Association

Guideline on good pharmacovigilance practices (GVP)

Early Phase Clinical Trials: Public Access to the EU Database Repository

Singapore Clinical Trials Register. Foo Yang Tong Director Clinical Trials Branch Health Products Regulation Group HEALTH SCIENCES AUTHORITY

TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP

EU Clinical Trials Regulation Regulation EU 536/2014

Assessment Report for CDM proposed standardized baseline (Version 01.0)

European Regulatory Newsletter July - September 2013

EMA Clinical Laboratory Guidance - Key points and Clarifications PAUL STEWART

PRE-TEST/POST-TEST FOR THE RESEARCH ETHICS TRAINING CURRICULUM. Please indicate if the following statements are True (T) or False (F).

The New EU Clinical Trial Regulation Potential Impacts on Sites

RECOMMENDATION ON THE CONTENT OF THE TRIAL MASTER FILE AND ARCHIVING

INTERNATIONAL STANDARD ON ASSURANCE ENGAGEMENTS 3000 ASSURANCE ENGAGEMENTS OTHER THAN AUDITS OR REVIEWS OF HISTORICAL FINANCIAL INFORMATION CONTENTS

Guidelines for preparing Standard Operating Procedures (SOP) for Institutional Ethics Committee for Human Research

ICRIN Seminar on EU Regulation of Clinical Trials

Background Definition Why do we need it? The process of obtaining informed consent A brief overview of special situations Conclusion

INTERNATIONAL PHARMACEUTICAL PRIVACY CONSORTIUM COMMENTS IN RESPONSE TO THE CALL FOR EVIDENCE ON EU DATA PROTECTION PROPOSALS

Operational aspects of a clinical trial

Quality Monitoring Checklist

Subject: No. Page PROTOCOL AND CASE REPORT FORM DEVELOPMENT AND REVIEW Standard Operating Procedure

RESEARCH GRANT Sponsored by the Pedal-with-Pete Foundation

CHILDREN AND ADULTS SERVICE RESEARCH APPROVAL GROUP

The new European clinical trials regulation Dr. N.Gökbuget

EU Change Control Process for Change Requests in the Entire Area of Electronic Submissions for Human Medicinal Products Version 2.

TUTORIAL on ICH E9 and Other Statistical Regulatory Guidance. Session 1: ICH E9 and E10. PSI Conference, May 2011

HUMAN RESEARCH PROTOCOL SUBMISSIONS 4

Adventist HealthCare, Inc.

Clinical evaluation Latest development in expectations EU and USA

Guideline on good pharmacovigilance practices (GVP)

GUIDELINES FOR PILOT INTERVENTIONS.

[Informed Consent Form for ] Name the group of individuals for whom this consent is written. Explanation Example

How To Weigh Data From A Study

Background. Audit Quality and Public Interest vs. Cost

EphMRA Adverse Event Reporting Guidelines 2015

FSC INTERNATIONAL STANDARD

Yale University Open Data Access (YODA) Project Procedures to Guide External Investigator Access to Clinical Trial Data Last Updated August 2015

E2C(R2) Implementation Working Group ICH E2C(R2) Guideline: Periodic Benefit-Risk Evaluation Report Questions & Answers

Lifecycle CMC Management: ICH Q12 Progress to date

Clinical Trial Data Transparency Environment & Expectations EMA Policy - Clinical Trials Regulation

Risk management plans an overview

GUIDELINES ON MEDICAL DEVICES EVALUATION OF CLINICAL DATA : A GUIDE FOR MANUFACTURERS AND NOTIFIED BODIES

Guidelines for AJO-DO submissions: Randomized Clinical Trials June 2015

Regulatory Risk Analysis in the European Union, United States, and Canada

Submission of a clinical trial for access to ECRIN services Notice to the Applicant

Identification. Preparation and formulation. Evaluation. Review and approval. Implementation. A. Phase 1: Project identification

Clinical trials regulation

Document Title: Project Management of Papworth Sponsored Studies

Guidance on the preparation of an Annex XV dossier for the identification of substances of very high concern

Clinical Research Professional Certification & Preparing for the CCRP Exam

Procedural Standards for Refugee Status Determination under UNHCR s Mandate

Hertsmere Borough Council. Data Quality Strategy. December

EMA policy on publication of Clinical Data. SFdS - Journée Annuelle du groupe Biopharmacie & Santé

Aim of today s meeting/teleconference

Comment Form: WHO Statement on Public Disclosure of Clinical Trial Results. Suggested Amendment

Patient Handbook on Stem Cell Therapies

Annex A. Levels 1 5 of the Clinical Research Coordinator Track in the Clinical Research WSQ Framework

Clinical Trial Protocol Development. Developed by Center for Cancer Research, National Cancer Institute Endorsed by the CTN SIG Leadership Group

INTERNATIONAL STANDARD ON REVIEW ENGAGEMENTS 2410 REVIEW OF INTERIM FINANCIAL INFORMATION PERFORMED BY THE INDEPENDENT AUDITOR OF THE ENTITY CONTENTS

Initial Provisions for CHAPTER [ ] Regulatory Cooperation

Clinical trials for medical devices: FDA and the IDE process

Clinical trials in developing countries submitted to EMEA for regulatory purposes

The Study Site Master File and Essential Documents

* * * Initial Provisions for. CHAPTER [ ] - Regulatory Cooperation

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

CLINICAL TRIALS SHOULD YOU PARTICIPATE? by Gwen L. Nichols, MD

Quick Response (QR) codes in the labelling and package leaflet of centrally authorised 1 medicinal products

Pediatric Research Networks A Plan for a Collaboration in Europe. Daniela Gunz Head Clinical Trial Operations Switzerland June 9, 2011

EUROPEAN CENTRAL BANK

Transcription:

EORTC position on the place for transparency in the clinical trials regulation EORTC fully supports the need to increase transparency of clinical trials. Appropriate transparency within the clinical trials regulation would: 1. inform the general public, patients and scientists about the results of clinical research being done in the EU and increase the confidence of the general public in clinical research; 2. provide feed-back on trial results regardless of whether these are positive, negative, or inconclusive, or if the clinical trial could not be completed (providing the main reasons for this), and provide the scientific community with essential background information to foster the next generation of clinical trials; 3. enable independent re-evaluation of the results of pivotal clinical trials or any other clinical trial requiring such independent re-evaluation. The clinical trials regulation proposal released by the European Commission suggests that a public summary of trial results should be made one year after the end of the clinical trial. Clinical trial protocol or the statistical analysis plan and their updates are made public through the EU database during initial authorization of the clinical trial or resulting from the approval of amendment. The ENVI report proposed by the rapporteur Mrs. G. Willmott and amendments proposed by other MEPs also suggest making either lay summary of results, ICH E3 format report with line listings of patient data or full raw data of all clinical trials publicly available. It is important to understand that not all of these proposed formats would be conducive to the achievement of the specified aims. The table below provides a comparative overview of the three proposed formats (summary report, ICH E3 report or full row data set of a clinical trial) to assess whether these formats fit the purposes of the clinical trials regulation. The appropriateness of each of the public formats is considered separately.

Is the proposed format appropriate to fit the purpose*? Type of data / possible use Summary of results ICH E3 report Volume of information < 100 pages several hundred pages Learning about trial output when made public (patients, scientists ) Background information for the next trial Reproducing published trial results Yes, missing lay summary Yes, sometimes too little information Not possible Cumbersome Not as easy, cumbersome, too much information If attempted, it would not be reliable Performing additional analysis Not possible If attempted, it would not be reliable Is format globally useful for the defined purpose(s)? Purpose 1 Purpose 2 Purpose 3 *see three purposes defined on Page 1 YES PARTIALY PARTIALY Raw data Example of one trial of 550 patients: 24138 forms, 1.7 10 6 data items Not possible without re-analysis Cumbersome (requires reanalysis) Possible, but data should be available in the right format Possible, needs good methodology, data should be available in the right format YES Risk assessment of the public release of the information. Type of data / risks Summary of ICH E3 report Raw data results Can patients potentially be No Yes Yes identified? Will the use be in compliance with the scope of patients consent? Yes Not necessarily (no control) Possible misuse by public What is the risk of misuse of data from the patients perspective Misunderstanding of results Extrapolation of results & different conclusion (unreliable) Low High High Not necessarily (no control) Inappropriate methodology & unreliable conclusions

From the above tables, it clearly appears that although the summary of trial results in the current format does not provide sufficient information and does not include a lay summary, the ICH E3 report provides large amounts of data in a cumbersome format with the potential risk of jeopardizing patient confidentiality and producing (by unidentified users) unreliable or inconclusive results. Therefore, to inform the general public and scientific community about clinical trial results in a way that minimizes the risk of data misuse, the EORTC would like to propose compromise amendments (see below). The below amendments clarify the format of the clinical trial report, which should be more than just the summary of results, but not to the extent as seen in the ICH E3 format. To enable independent re-evaluation of the results of pivotal clinical trials or any other clinical trial requiring such independent re-evaluation, sharing of raw data is necessary. However, the precise modalities and mechanisms of such data sharing should be assessed carefully with all stakeholders, including EMA. It should be considered to include within these modalities, among others, the need to request the access to the data with an explanation on who will access the data, why and how data will be used. These delicate modalities should not be set within the regulation (as proposed within the ENVI amendment 150). ENVI 150: (37a) Within two years after the adoption of this Regulation, the Commission should submit the European Parliament an evaluation of the management of raw data, and the feasibility of introducing an open access for independent scientists to raw data from all clinical trials. Compromise amendements Compromise amendement 1 (Replaces ENVI 21) Article 2 paragraph 2 point 30 a (new) Transversal amendment clinical trial report instead of summary of results ; concerns ENVI: 469 on article 29, 2a(new), article 34.3 (see compromise amendment 2), article 34.5, (30a) Clinical trial report : a report containing the full protocol and any annexes or subsequent modifications and dates thereof, lay summary of a clinical trial, a statistical analysis plan and the summary of results. Justification: not all clinical trials will support a drug registration dossier. Many trials aim to gain further knowledge about treatments or to improve treatment strategy. There is no need for these trials to produce a report in the ICH E3 format which contains a lot of potentially identifiable patient data (which cannot be made public in compliance to the current EU data protection legal framework) and brings no added value as compared to other possible formats. Clinical trials report should be publically available,

and therefore should not, contain any information that may lead to an identification of individual patients (it should only contain tables and aggregated data). The level of information provided should, however, enable the public to corroborate the presented results. Compromise amendement 2 (Replaces ENVI 51, 528, 529, 530, 531, 532, 533, 534, 535, 536, 537, 539, 540 & 545) Article 34 paragraph 3 3. Within two years from the end of any clinical trial, the sponsor shall submit through the EU portal the clinical trial report, whether the results are positive, negative, or inconclusive. If the clinical trial has prematurely ended, the information concerning the reasons for this premature end should be submitted. The summary of trial results shall be made in compliance with Annex III a. The summary of trials results should only contain tabulated, aggregated or anonymous data. The Commission shall be empowered to amend this annex by adopting delegation act in accordance with the article 85. Where for scientific reasons it is not possible to include results of all analyses planned in the protocol within two years, an updated clinical trial report shall be submitted as soon as new results are available. In this case, the protocol shall specify when the results are going to be submitted. This clinical trial report submitted via the EU portal should be made public. Justification: Reports of all results should be published: positive or negative. The report should also be made for trials abandoned prematurely for reasons other than safety. Summary of results in this case should explain reasons for the premature end and justification when applicable. Two years is better than one year. Indeed the best way to make trial results public is to publish them in a peer-reviewed journal. It is not appropriate to make results public before even having a reasonable chance to publish them. It is frequently not possible to perform the analysis and to have results published within one year because of objective constraints outside the authority of the sponsor. On the other hand, two years is still a reasonably acceptable time to have results published through the means and for the purposes covered by this regulation. It should also be acceptable that such a clinical trial report is public even for trials with drugs for which marketing authorization has not been granted yet. Reporting for inconclusive and prematurely stopped trials covers also all cases of trials which would be stopped because drug development has been stopped. Elements of the Annex III, when taken together with the protocol and statistical analysis plan, constitute a reasonable compromise between summary of results only and a full report as per ICH E3 standards. ICH E3 report should, instead, be acceptable if produced anyway by some sponsors (to avoid duplication).

The amendment to the third paragraph of the text is justified by the fact that some clinical trials contain secondary endpoints that can only be analyzed long time after the end of the trial. Taking the example of cancer clinical trials, the primary endpoint is frequently progression-free survival, but the secondary endpoint is frequently overall survival. Once trials end and all patients finish protocol treatment and protocol follow-up, primary analysis is performed and the trial report is produced. The information on whether patients are still alive will continue to be collected for much longer periods, and the overall survival analysis will only be possible years after the trial ends. Submission of the clinical trial report should be a single submission to the portal; it is up to the portal to make it publically available to the EU database (This database will replace EudraPharm) Compromise amendement 3 (Replaces amendement ENVI 731) Annex IIIa Content of the summary of the results of clinical trials The summary of the results of the clinical trials referred to in Article 2, paragraph 2, 30 a (new) is part of the clinical trial report and shall contain information on the following elements (if not already included in the trial protocol or its appendixes): 1. Trial information: a) Study identification b) Identifiers c) Sponsor details d) Paediatric regulatory details e) Result analysis stage f) General Information about the trial g) Population of trial subjects with actual number of subjects included in the trial 2. Subject disposition: a) Recruitment b) Eligibility c) Pre-assignment Period d) Post Assignment Periods 3. Baseline Characteristics: a) Baseline Characteristics (Required) Age b) Baseline Characteristics (Required) Gender

Justification: c) Baseline Characteristics (Optional) Study Specific Characteristic 4. End Points: a) Endpoint definitions b) End Point #1* Statistical Analyses c) End Point #2, Statistical Analyses *Information shall be provided for as many end points as defined in the protocol. 5. Adverse Events: a) Adverse events information b) Adverse event reporting group c) Serious Adverse Events d) Non-serious adverse event 6. More Information: a) Global Substantial Modifications b) Global Interruptions and re-starts c) Limitations & Caveats Proposed list of elements should ensure the general public and scientific community are adequately informed about clinical trial results. Note: The proposed amendments are compatible with amendments ENVI 131, 169, 170, 171, 446 and 447 and should be acceptable without any modification. There are no other amendments which propose making trial results and/or data public and/or transparent.