1 Introduction
1. The UK has long been a world leader in the field
of medical research. Since the birth of the pharmaceutical industry
over a century ago, only the USA has discovered and developed
more drugs, and British researchers have played a central role
in many of the breakthroughs that have revolutionised both scientific
understanding and standards of patient care in the past 100 years.[1]
More recently, this strong heritage has underpinned the development
of a life sciences industry described by the Government as "one
of the most successful globally" today.[2]
The UK's 4,500 pharmaceutical, medical technology and medical
biotechnology firms together employ over 165,000 staff, generate
annual turnover of over £50 billion and spend nearly £5
billion on research and development each year.[3]
It is perhaps therefore unsurprising that the Government has stated
its desire to make the UK "the location of choice" for
the £700 billion global life sciences industry, ensuring
that "life sciences will continue to be vibrant in the UK
and a key contributor to sustained economic growth and health
improvements".[4]
2. Clinical trials, which test the safety and efficacy[5]
of medical treatments, provide the body of scientific evidence
on which this industry is built. Human medicines cannot be sold
without permission from a licensing authority and permission will
not usually be granted unless a clinical trial has demonstrated
the medicine's success in treating the condition for which it
will be marketed.[6] Clinical
trials, in addition to generating valuable scientific evidence,
also provide patients with an important way of accessing products
that have not yet reached the market, offering hope to those for
whom existing treatments have failed.[7]
The necessity for a clinical trial to be performed before a medicine
can gain regulatory approval means that trials are also big business.
The global market for outsourced trial services[8]
alone is expected to be worth £19 billion a year by 2015
and the clinical trials market as a whole has been estimated at
£29 billion.[9]
3. Historically, the UK captured a large slice of
the market for clinical trials, enjoying in 2000 the third largest
share of global trials, behind only the US and Germany.[10]
Between 2000 and 2006, however, the UK's ranking dropped to ninth
and Britain's global share of patients in pharmaceutical trials
fell sharply as trials moved to other jurisdictions.[11]
Between 2007 and 2011, the total number of UK trials also decreased,
putting jobs at risk and making it increasingly difficult for
British patients to benefit from participation in cutting-edge
medical research.[12]
In the last two years, several efforts have been made to halt
this decline. The Government's creation of the Health Research
Authority in December 2011 was intended to streamline the process
through which researchers could obtain permission to conduct a
UK trial, making it easier to get trials up and running.[13]
In addition, the Government has stated its hope that the planned
revision of the 2001 EU Clinical Trials Directivethe key
piece of legislation regulating trials across the EUwould
make it easier to conduct a trial in the UK.[14]
4. There are also long-standing concerns that, wherever
in the world they take place, the methods and results of many
trials currently remain hidden from public view. This lack of
transparency, say campaigners, undermines public trust, breaks
the ethical pact between scientists and those participating in
trials and leads to clinical decisions being made on the basis
of incomplete evidence, potentially leading to poorer outcomes
for patients.[15] The
topic of clinical trial transparency received renewed attention
in late 2012 with the publication of Bad Pharma, a book
by Dr Ben Goldacre that accused the pharmaceutical industry of
deliberately suppressing unfavourable trial results from public
view.[16]
5. In December 2012, we issued a call for written
evidence addressing the following questions:
a) Do the European Commission's proposed revisions
to the Clinical Trials Directive address the main barriers to
conducting clinical trials in the UK and EU?
b) What is the role of the Health Research Authority
(HRA) in relation to clinical trials and how effective has it
been to date?
c) What evidence is there that pharmaceutical
companies withhold clinical trial data and what impact does this
have on public health?
d) How could the occurrence and results of clinical
trials be made more open to scrutiny? Who should be responsible?
e) Can lessons about transparency and disclosure
of clinical data be learned from other countries?[17]
6. During the inquiry, we received written submissions
from 62 organisations and individuals and took oral evidence from
21 witnesses, including:
- Researchers, clinicians and
others involved in the running of clinical trials in the UK;
- Representatives of commercial and non-commercial
funders of UK trials, including the pharmaceutical companies GlaxoSmithKline
(GSK) and Roche;
- UK regulators and governing bodies, including
the Medicines and Healthcare Products Regulatory Agency (MHRA),
the Health Research Authority (HRA) and the Department of Health's
National Institute of Health Research (NIHR); and
- The Government, represented by Lord Howe, Parliamentary
Under-Secretary of State for Quality, Department of Health, (hereafter
"the Minister") and David Willetts MP, Minister of State
for Universities and Science, Department for Business, Innovation
and Skills (hereafter, "the Minister for Universities and
Science").[18]
We would like to thank those who provided written
and oral evidence.
7. During our inquiry, several developments affected
the regulatory landscape for clinical trials and the ongoing debate
about trial transparency. This Report therefore considers these
developments alongside the questions specified in the terms of
reference. Chapter 2 defines the term "clinical trial"
and outlines the current regulatory and governance requirements
for those based in the UK. Chapter 3 considers the reasons for
the recent decline in the UK's share of clinical trials, and offers
suggestions for how this might be put right. Chapter 4 examines
the subject of clinical trial transparency, considering the different
levels of data that can be generated by and disclosed for a clinical
trial, and evaluating recent developments designed to make trials
more transparent. Chapter 4 also considers how emerging evidence
from clinical trials can be better incorporated into clinical
practice in order to improve medical outcomes. Chapter 5 sets
out some final conclusions and recommendations.
1 Ev 98; See also, for example, "History",
Pfizer, pfizer.com; "Our history", GSK, gsk.com,
both accessed September 2013 Back
2
Department for Business, Innovation and Skills, Office for Life
Sciences, Strategy for UK Life Sciences, December 2011,
p 4 Back
3
Department for Business, Innovation and Skills, Office for Life
Sciences, Strategy for UK Life Sciences, December 2011,
p 4 Back
4
"What we do", Office for Life Sciences, Gov.uk,
accessed September 2013; Deloitte, 2013 Global life sciences
outlook, p 1 (USD values converted approximately to GBP based
on Oanda exchange rate on 29 August 2013) Back
5
Efficacy tests whether a treatment works under ideal conditions,
while effectiveness tests whether a treatment works under real-world
conditions. Generally, a treatment tested under trial conditions
tests efficacy rather than real-world effectiveness, since trial
conditions are usually to some extent artificial. Back
6
MHRA, Medicines and medical devices regulation: what you need
to know, 2008, p 5; Council Directive 2001/83/EC Back
7
Q 92 [Professor Sikora] Back
8
Outsourced clinical trial services, performed by third parties
known as contract research organisations (CROs), include activities
such as trial planning and design, patient recruitment, bioanalysis
and data analysis Back
9
"'The Clinical Trials Market Will Exceed $30BN by 2015' says
visiongain Report", PR Newswire, 5 July 2011, prnewswire.co.uk,
accessed September 2013; "Clinical trial basics: global clinical
trial market", James Lind Institute, jliedu.com,
accessed September 2013 (USD values converted approximately
to GBP based on Oanda exchange rate on 29 August 2013) Back
10
Kinapse, Commercial clinical research in the UK: A Report for
the Ministerial Industry Strategy Group (MISG) Clinical Research
Working Group, November 2008, p 19 Back
11
Kinapse, Commercial clinical research in the UK: A Report for
the Ministerial Industry Strategy Group (MISG) Clinical Research
Working Group, November 2008, p 19; Ev 79 Back
12
Ev 53, para 4 Back
13
Ev 54, paras 10-12 Back
14
Ev 53, para 6 Back
15
See Q88 [Dr Ben Goldacre]; Ev 67, para 1-3, appendix; Ev w110,
para 23; Ev 116, appendix, paras 48-51 Back
16
Ben Goldacre, Bad Pharma, 2012, Chapter 1 Back
17
"Committee to inquire into clinical trials and
disclosure of data", Science and Technology
Committee, 13 December 2012, parliament.uk/science Back
18
A full list of witnesses is provided at the back of this Report Back
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