klausrose Consulting, Pediatric Drug Development & More, Riehen, Switzerland.
Clin Ther. 2014 Feb 1;36(2):163-77. doi: 10.1016/j.clinthera.2014.01.009.
Diagnosis of childhood cancer is no longer an automatic death sentence, but it has not lost all of its horror. Drugs, surgery, radiation, and clinical trials have advanced our capacity to handle these cancers, but pediatric cancers still face challenges. Pediatric pharmaceutical legislation was introduced in the United States in 1997 and has triggered many clinical trials that have helped us better understand what drugs do to a child's body and vice versa. Following the US precedence, the European Union introduced its own legislation. The US legislation was designed to generate additional pediatric data and balances between mandatory requirements and voluntary incentives. The US legislation was designed to mandate full registration of all new drugs for children whenever there is any potential pediatric use.
The purpose of this article is to discuss unintended negative consequences of the legislation of the European Medicines Agency (EMA).
We analyzed the effects of the EU pediatric legislation with respect to the history of the emergence of modern drugs, pediatric clinical pharmacology, and the development of drugs for pediatric malignancies.
No new drug can be registered in the European Union without a detailed pediatric investigation plan (PIP) approved by the EMA's Pediatric Committee (PDCO). This has moved the discussion of the pediatric aspects of drug development to an earlier stage and has increased public awareness. It also has brought industry and pediatric oncologists closer together. However, in a review of >100 PDCO PIP decisions in childhood cancer, we found a lack of balance between the legitimate desire to include children in drug development and the common sense needed in the complex worlds of drug development and pediatric oncology. Many decisions appeared to have been based on both exaggerated assumptions about the frequency of childhood malignancies and the feasibility of the clinical trials proposed.
Pharmaceutical companies are being forced into long-term commitments to clinical trials before efficacy in adults has been demonstrated. Pediatric clinical oncology trials are being driven by regulatory "tunnel vision" and not by therapeutic benevolence, epidemiologic data, or feasibility. As a result, children with cancer are being monopolized for PDCO-triggered, often unfeasible trials that are not always in their best interests and seldom produce useful therapies. Because clinical trials are global, this affects children with cancer worldwide. Until now, carefully worded concerns about these negative consequences have been published in specialty journals. It is time to start a broader debate on how to move forward.
儿童癌症的诊断不再是自动死刑,但它并没有失去所有的恐怖。药物、手术、放疗和临床试验提高了我们处理这些癌症的能力,但儿科癌症仍然面临挑战。美国于 1997 年引入了儿科制药立法,并引发了许多临床试验,这有助于我们更好地了解药物对儿童身体的作用,反之亦然。效仿美国的做法,欧盟也出台了自己的立法。美国的立法旨在生成更多儿科数据,并在强制性要求和自愿激励之间取得平衡。美国的立法旨在规定只要有任何潜在的儿科用途,就必须对所有新儿童药物进行全面登记。
本文旨在讨论欧洲药品管理局(EMA)立法的意外负面影响。
我们分析了欧盟儿科立法对现代药物出现历史、儿科临床药理学和儿科恶性肿瘤药物发展的影响。
没有 EMA 儿科委员会(PDCO)批准的详细儿科研究计划(PIP),任何新药都不能在欧盟注册。这将药物开发儿科方面的讨论提前到了一个更早的阶段,并提高了公众的意识。它还使行业和儿科肿瘤学家更加紧密地联系在一起。然而,在对 >100 项儿科癌症 PDCO PIP 决策进行审查后,我们发现,在将儿童纳入药物开发的合法愿望与药物开发和儿科肿瘤学的复杂世界中所需的常识之间,存在着不平衡。许多决定似乎基于对儿童恶性肿瘤的频率和所提议临床试验的可行性的夸大假设。
制药公司在成人疗效得到证实之前,就被迫对临床试验做出长期承诺。儿科临床肿瘤学试验受到监管“管窥”的驱动,而不是出于治疗善意、流行病学数据或可行性。因此,儿童癌症患者被垄断用于 PDCO 触发的、往往不可行的试验,这些试验并不总是符合他们的最大利益,也很少产生有用的治疗方法。由于临床试验是全球性的,这影响了全世界的癌症儿童。到目前为止,关于这些负面影响的措辞谨慎的担忧已在专业期刊上发表。现在是时候就如何向前推进展开更广泛的辩论了。