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CLINICAL DRUG DEVELOPMENT PERSPECTIVES ON THE ETHICS OF HUMAN EXPERIMENTATION Edmund J.D. Lee Pharmacology Department National University of Singapore CLINICAL DRUG DEVELOPMENT PERSPECTIVES ON THE ETHICS OF HUMAN EXPERIMENTATION • Historical Perspectives of drug development • Impact on Clinical Trial Ethics Ethics of Human Experimentation Our understanding is fairly recent and makes reference to 3 documents Nuremberg Code 1947 Declaration on Helsinki 1964 Belmont Report 1978 I will follow that system which . . . I consider for the benefit of my patients, and abstain from whatever is deleterious and mischievous. From the Hippocratic oath "Among the experiments that may be tried on man, those that can only harm are forbidden, those that are innocent are permissible, and those that may do good are obligatory. It is immoral then, to make an experiment on man when it is dangerous to him, even though the result may be useful to others. Claude Bernard 1813-1878 In 1721, an epidemic of smallpox hit London and left the British Royal Family in fear. Reading of Lady Wortley Montagu’s efforts, they wanted to use inoculation on themselves. Doctors told them that it was a dangerous procedure, so they decided to try it on other people first. The test subjects they used were condemned prisoners. The doctors inoculated the prisoners and all of them recovered in a couple of weeks. So assured, the British royal family inoculated themselves and reassured the English people that it was safe. Edward Jenner Three main forms of Ethics 1. Virtue Ethics Ethics is about the doer’s moral character 2. Deontological Ethics Ethics is about obeying rules/obligations 3. Consequentialism/Utilitarianism Ethics is about good outcomes Synthesized 1832 Medical use 1869 The Creation of the Food and Drug Administration • In 1906, Upton Sinclair published the novel, The Jungle, describing the unsanitary conditions used in the processing of meat in Chicago • Following public protests the US Congress through the pure Food and Drug Act, created the Food and Drug Administration (FDA) in 1906 – Correct labeling was required for every food and drug – Testing for safety was not required The US Food, Drug, and Cosmetic Act of 1938 • More than 100 people died in the USA in 1937 after consumption of “Strep-Elixir” containing sulfanilamide & diethyleneglycol • Congress generated the US Food, Drug, and Cosmetic Act requiring scientific proof of safety for any drug before marketing The Thalidomide Tragedy • Between 1950 and 1960 thousands of children were born with congenital malformations in Europe, Canada, and Latin America. Traced to mothers consuming thalidomide during pregnancy • Pre-marketing tests in 300 individuals didn’t alert investigators to toxic effects • Consumers’ concerns reached Congress in USA generating the Kefauver-Harris amendment in 1962, requiring strict safety and efficacy control for new drugs …but were the Nazi doctors really unethical? Nuremberg Code 1947 Universal Declaration of Human Rights (UDHR) 1948 Nuremberg Code 1947 Universal Declaration of Human Rights (UDHR) 1948 Bioethicist Arthur Caplan : “The Nuremberg Code explicitly rejects the moral argument that the creation of benefits for many justifies the sacrifice of the few. Every experiment, no matter how important or valuable, requires the express voluntary consent of the individual. The right of individuals to control their bodies trumps the interest of others in obtaining knowledge or benefits from them.” Physician and ethicist Jay Katz : “if not explicitly then at least implicitly, commanded that the principle of the advancement of science bow to a higher principle: protection of individual inviolability. The rights of individuals to thoroughgoing selfdetermination and autonomy must come first. Scientific advances may be impeded, perhaps even become impossible at times, but this is a price worth paying.” 1932-1972 History of Pharmaceutical Industry Late 19th Century Beginnings of drug industry e.g. chloral hydrate Inter-war years Insulin. Penicillin. Post WW2 Exponential growth The Thalidomide Tragedy • Between 1950 and 1960 thousands of children were born with congenital malformations in Europe, Canada, and Latin America. Traced to mothers consuming thalidomide during pregnancy • Pre-marketing tests in 300 individuals didn’t alert investigators to toxic effects • Consumers’ concerns reached Congress in USA generating the Kefauver-Harris amendment in 1962, requiring strict safety and efficacy control for new drugs The Declaration of Helsinki of the World Medical Association, Finland 1964 • Most well known international regulation for biomedical research • Establishes the principles and rationale for research in human subjects • Introduces the concepts of: – Protocol approval by an independent ethics committee – Investigator to be responsible for the care of the participating subjects – Written informed consent • Content has been reviewed in Tokyo, 1975; Italy, 1983; Hong Kong, 1989; South Africa, 1996; and Edinburgh, 2000 The Declaration of Helsinki of the World Medical Association, Finland 1964 • Medical progress is based on research which ultimately must rest in part on experimentation involving human subjects. • In case of legal incompetence, informed consent should be obtained from the legal guardian in accordance with national legislation. Where physical or mental incapacity makes it impossible to obtain informed consent, or when the subject is a minor, permission from the responsible relative replaces that of the subject in accordance with national legislation. The Belmont Report 1978 • National commission appointed in 1974 by the Congress of the USA for the protection of human subjects participating in clinical research • Reviews the ethical principals in clinical research: 1. Autonomy 2. Beneficence 3. Justice Clinical Research Ethics Milestone developments: • • • • • • FDA established 1906 Nazi atrocities Nuremberg Code 1947 Kefauver Harris amendment Declaration of Helsinki 1964 Belmont Report 1979 GCP/ICH (1977 – 1996) Industrial Drug Development Human Rights In Singapore.... The present Singapore GCP Guidelines 1998 (rev 1999) is modelled along the ICH/GCP Guideline. All clinical trials have to conform to the Medicines (Clinical Trials) Amended Regulations 1998 and the Singapore GCP Guidelines 1998 (rev 1999). Administered by the HSA. Good Clinical Practice – definition (EC) A standard by which clinical trials are designed, implemented, and reported so that there is public assurance that the data are credible, and that the rights, integrity and confidentiality of subjects are protected New Drug Development Increasing costs Direct Cost Indirect Cost $231 M 250 200 $125 M 150 $87 M 100 $54 M 50 0 1976 1982 1987 1990 Year http://www.forbes.com/sites/aroy/2012/04/24/how-the-fda-stifles-new-cures-part-i-the-rising-cost-of-clinical-trials/ Three main forms of Ethics 1. Virtue Ethics Ethics is about the doer’s moral character 2. Deontological Ethics Ethics is about following rules 3. Consequentialism/Utilitarianism Ethics is about good outcomes Are our ethics defined by procedural correctness? To what extent are our ethical values shaped by the commercial realities? Cases of Scientific Misconduct in the USA • Willowbrook State School: Inoculation of hepatitis virus in mentally retarded children (1957) • Jewish chronic disease hospital: Injection of live cancer cells in terminally ill subjects (1963) • Tuskegee Experiment: Untreated syphilis in African-American people from Alabama, United States (1930–1970) Thank you