Other Infrastructure Required
for Research
87. Research nurses are a critical element in the
delivery of safe, well-conducted clinical trials. Chemotherapy
can be hazardous and needs to be delivered by highly trained nurses.
New, less well-characterised, experimental cytotoxic agents that
are commonly used in clinical trials amplify these hazards and
the standard of the care and monitoring must therefore be the
highest possible. Research nurses are also needed to counsel patients
entering trials. Research work cannot be said to be part of the
standard activities of cancer nurses. We have received extensive
evidence regarding the importance of the provision of specialist
cancer research nurses, and that the supply of such nurses is
far too low to be able to carry out a desirable volume of clinical
trials.[133]
88. Clinical trials require rigorous collection and
recording of data gathered from patients and their health professionals.
Large trials require the management of complex data sets, and
the provision of high quality data to trial investigators. Such
data management is best performed by trained professionals with
the latest information technology (IT) equipment. Data managers
for cancer clinical trials are also in short supply in the NHS,
as is the necessary IT equipment. This matter has been brought
to our attention on a number of occasions during our visits to
UK cancer research centres.[134]
89. Pay and career structures for essentially non-medically
qualified professionals, notably medical laboratory scientific
officers and radiographers, are inadequate and enhanced training
and recruitment programmes are required. Without such staff effective
treatment is impossible.
90. Beyond the dedicated research-specific staff
required, clinical research also places greater demands on services
that should routinely be available in NHS cancer treatment centres.
These include radiology and other diagnostic imaging technologies
(eg. CT, ultrasound , PET and MRI scans), histopathology, pharmacy,
radiotherapy and secretarial support. Unless these services are
significantly boosted over and above that which is needed for
routine cancer care, clinical trials cannot take place. Again,
we have received evidence that these treatment support services
are not widely available at a level sufficient to support the
needs of clinical research over and above the routine NHS service
load.
91. The Department of Health told us that it is "working
to improve the infrastructure for cancer clinical trials in the
UK" and that "detailed proposals are being worked up
and will be pursued through the Cancer Research Funders' Forum"
to improve the infrastructure for cancer clinical trials.[135]
There is widespread agreement that the poor state of the infrastructure
for cancer treatment and research in the NHS is a serious barrier
to clinical research. The Government must act quickly to address
this through investment in the necessary staff, training, equipment
and buildings.
ETHICAL APPROVAL
92. All clinical trials must be ethically approved.
This means that the protocols and objectives of the trial must
be examined by a local research ethics committee (LREC) to ensure
that patients participating in trials are not subject to unnecessary
procedures or risks and are given a high standard of treatment.
This is a widely accepted critical safeguard for the rights of
patient volunteers where failure to provide the best possible
treatment could risk the life of the patient and unnecessary procedures
could be associated with unpleasant, even life-threatening side-effects.
Ethical approval is also needed for the location of the institution
performing the trial, the investigator and the appropriate use
of patient information.
93. While there is no doubt about the need for rigorous
ethical approval, we do have evidence that the bureaucracy involved
is seriously holding up clinical trials. Pharmaceutical companies
testing new drugs are very keen, for commercial reasons, to make
rapid progress in clinical trials. As we have discussed earlier
(see para 75), we consider it desirable that the number of patients
recruited into clinical trials should be increased. If the procedures
for ethical approval are discouraging pharmaceutical companies
from doing trials in this country then new procedures must be
found which accelerate approval while retaining proper ethical
scrutiny. The ABPI told us that the UK was "one of the slowest
places in Europe to begin a clinical trial".[136]
It suggested that one of the reasons for this was the recent creation
of Multi-Centre Research Ethics Committees (MRECs) in each NHS
Region, which, far from meeting their purpose of accelerating
review and approval procedures, had in many cases resulted in
delay. MRECs were intended to review the trial protocol but then
approval was also required at a local level from an LREC, which
would only consider the local site, staff and the use of patient
information. The ABPI told us that the MREC system has, in reality,
increased the minimum time necessary to obtain ethical approval,
by a minimum of a month and on one occasion by as much as a year.[137]
The CRC agrees with this assessment.[138]
Part of the problem seems to be that the MRECs and the LRECs are
managed by different and geographically separate NHS departments.
Professor Sir Richard Peto of Oxford University told us that a
recent study in Scotland "finished up having to send something
like 5,700 separate pages of detailed text on the ethics of some
study or other... just within the different centres in Scotland".[139]
94. Further approvals, such as a Clinical Trials
Exemption Certificate (CTX) in the case of companies, are required
from the Medicines Control Agency (MCA) before starting a clinical
trial. The MCA must approve the trial drug for safety. The Local
NHS Trust R&D committees, which check that the local finances
are in place, can present another hurdle. The ABPI is content
with the efficiency of the MCA's procedures but expressed concern
about the lack of regulation for the local R&D committees
which, it is argued, introduce further unnecessary delays.[140]
As a result, the ABPI told us that "some companies who are
doing multi-centre clinical trials are not putting clinical trials
in the United Kingdom involving more than four centres in order
to bypass some of the approval process".[141]
95. We recommend that the Government ensures that
ethical, safety and financial approvals for clinical trials are
administered more effectively so that trials can proceed as quickly
as possible after the submission of protocols. We believe that
for multi-centre trials ethical approval from one of the MRECs
should be sufficient. The Government should benchmark its performance
in this area against other European countries.
83 Q. 427. Back
84 Q.
312. Back
85 See,
for example, QQ. 166, 296,
312 & 472. Back
86 See
Annex 2. Back
87 QQ.
309 & 473. Back
88 See
Ev. pp. 2 & 48; QQ. 240, 309 & 462. Back
89 See,
for example, Ev. pp. 87,
156, 250 & 339; Q. 318. Back
90 Ev.
p. 98; See also QQ. 51 & 78. Back
91 See
Annex 1. Back
92 See
Annex 1. Back
93 Q.
306. Back
94 Ev.
p. 86. Back
95 Q.
482. Back
96 Q.
481. Back
97 Ev.
p. 259. Back
98 Ev.
p. 103. Back
99 Ev.
p. 86. Back
100 See
Annexes 2, 4, 5, 6 & 7. Back
101 Q.
307; See also Annex 1. Back
102 The
processes of licensing for medicines are described in our Fifth
Report of Session 1997-98 on British Biotech, HC 888-II. Back
103 Ev.
p. 337; Q. 396. Back
104 Ev.
p. 2. Back
105 Challenging
Cancer, p. 5. Back
106 Ev.
p. 104; See also: Strategic Priorities in Cancer Research
and Development, NHS R&D Strategic Review Cancer Topic
Working Group, Department of Health, 1999, p. 34. (Hereafter:
Strategic Priorities in Cancer R&D) Back
107 Strategic
Priorities in Cancer R&D,
p. 5. Back
108 Q.
539. Back
109 Q.
563. Back
110 Q.
552. Back
111 Q.
71. Back
112 http://cancernet.nci.nih.gov.
Back
113 Ev.
p. 2. Back
114 Ev.
p. 104. Back
115 Ev.
p. 104. Back
116 Ev.
p. 42. Back
117 Ev.
p. 42. Back
118 Ev.
p. 48. Back
119 Q.
192. Back
120 Ev.
p. 87. Back
121 Ev.
p. 71. Back
122 Q.
386. Back
123 Ev.
pp. 337 & 338. Back
124 Ev.
p. 154. Back
125 Ev.
p. 343. Back
126 Ev.
p. 344. Back
127 Ev.
p. 244. Back
128 Strategic
Priorities in Cancer R&D, p.
5. Back
129 Q.
539. Back
130 Ev.
p. 135; Q. 542. Back
131 Q.
59; Q. 542. Back
132 Ev.
p. 43. Back
133 See
Ev. pp. 48, 87, 105, 136 & 154. Back
134 See
also Ev. pp. 105 & 154;
Strategic Priorities in Cancer R&D, p. 34. Back
135 Ev.
pp. 4-5. Back
136 Ev.
p. 44. Back
137 Ev.
p. 43. Back
138 Ev.
p. 106. Back
139 Q.
444. Back
140 Ev.
p. 43. Back
141 Q.
191. Back