Facing the Challenges of the European Clinical Trials Directive – The European Organisation for Research and Treatment of Cancer Perspective

Facing the Challenges of the European Clinical Trials Directive – The European Organisation for Research and Treatment of Cancer Perspective

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The European Organisation for Research and Treatment of Cancer (EORTC) is a pan-European, non-profit, independent research organisation that develops, conducts, co-ordinates and stimulates high-quality translational and clinical research aimed at improving the standards of treatment for cancer patients in Europe.1

This mission is achieved through collaboration in the development of new drugs and other innovative approaches, and through the evaluation of more effective therapeutic strategies testing currently approved drugs, surgery and/or radiotherapy in clinical studies. Driving international cancer clinical trials in Europe constitutes the daily work of the EORTC and has always posed multiple challenges. These challenges have become magnified and more complex since enactment of the EU Clinical Trials Directive 2001/20/EC (EU CTD) due to the multinational nature of EORTC clinical trials. Issued in May 2001 and enshrined into the national legislation of all EU Member States as of May 2004, the overall intent of this Directive was to create a clinical research environment across Europe conducive to the discovery of much-needed innovative medicines while simultaneously ensuring the protection of all clinical trial participants. Four years after coming into legal force, many believe that the original goals of the Directive have yet to be fully achieved.2–6

Aim and Scope of the EU Clinical Trials Directive
The EU issues directives, a mechanism by which decisions made centrally are implemented at the Member State level. The aim of any directive is the harmonisation of fundamental principles and core procedures. However, a directive itself does not specify the means or methods for accomplishing this goal. The EU CTD 2001/20/EC is a directive on the approximation of the laws, regulations and administrative provisions of the Member States relating to implementation of good clinical practice (GCP) in the conduct of clinical trials on medicinal products for human use.7It endorses the 1996 International Conference on Harmonisation (ICH) recommendations for GCP, the foundation for the Directive and its provisions.
The fundamental aims of the EU CTD are:

  • to protect the rights, safety and wellbeing of clinical trial participants;
  • to simplify and harmonise the administrative provisions governing clinical trials; and
  • to establish a transparent procedure to harmonise the conduct of clinical trials in Europe and ensure the credibility of research results.

These are sound fundamentals. However, the Directive does not distinguish between commercial and non-commercial clinical trials – that is, between trials conducted by the pharmaceutical industry to register a new compound and trials carried out primarily by academic researchers. Under the EU CTD, all interventional clinical trials that involve medicinal products must meet new legal obligations. To the detriment of independent researchers, the Directive failed to take into consideration the unique nature of non-industry-sponsored clinical trials. Reprieve was found in recital 14 to the Directive, which specifically recognised noncommercial trials conducted by researchers without pharmaceutical industry support. However, application of the Directive remains fraught, with time-consuming, costly bureaucratic requirements.

References:
  1. European Organisation for Research and Treatment of Cancer. Available at: www.eortc.be
  2. Meunier F, Dubois N, Negrouk A, et al., Throwing a wrench in the works?, Lancet Oncol, 2003;4:717–19.
  3. Hartmann M, Hartmann-Vareilles F, The clinical trials directive: how is it affecting Europe’s non-commercial research?, PLOS Clinical Trials, 2006;e13.
  4. Hemminki A, Kellokumpu-Lehtinen PL, Harmful impact of EU clinical research directive, BMJ, 2006;332:501–2.
  5. Moulton B, Two Years Later: The Impact of the EU Directive, Applied Clinical Trials, 2006.
  6. Hearn J, Sullivan R, The impact of the ‘Clinical Trials’ directive on the cost and conduct of non-commercial cancer trials in the UK, Eur J Cancer, 2007;43:8–13.
  7. European Parliament and Council of the European Union, Directive 2001/20/EC of the European Parliament and the Council of 4 Apr 2001. OJ L 121:34-44. Available at: www.eortc.be/Services/Doc/clinical-EU-directive-04-April- 01.pdf
  8. European Commission–European Medicines Agency Conference on the Operation of Clinical Trials Directive (Directive 2001/20/EC) and Perspectives for the Future, Report on the conference held on 3 October 2007 at the EMEA, London. Available at: ec.europa.eu/enterprise/ pharmaceuticals/pharmacos/docs/doc2007/2007_11/ ec_emea_conference_on_clinical%20_trials.pdf
  9. Article 1 of the EU CTD.
  10. Meunier F, Lacombe D, European Organisation for Research and Treatment of Cancer’s point of view, Lancet, 2003;362: 663.
  11. van Vyve D, Lacombe D, Minas V, Drucker L, Insurance issues and clinical research, E-learning course insurance issues and clinical research, version July 2007. Available at: www.eclin.be/uk/home.asp
  12. Austria, Belgium, France, Ireland, Italy, The Netherlands, Poland, Portugal.
  13. Austria, Belgium, France, Italy, Ireland, Luxembourg, The Netherlands, Portugal.
  14. Fischer K, General Manager, CEO, Assign Clinical Research gmbh, Assign Group, Austria, corresponding author of Mazalin K, Fischer K, Pharmaceutical Clinical Research in Austria and Hungary, Monitor, February 2007.
  15. Raaschou Beck G, Senior Director, International QA, Global Quality Assurance, Ferring Pharmaceuticals A/S, Copenhagen, corresponding author of Raaschou Beck G, An overview of clinical studies in Denmark, Monitor, February 2007
  16. BIA–EuropaBio White Paper: Promoting consistency of implementation and interpretation of the Clinical Trials Directive across EU member States, 2006.
  17. Detailed guidance for the request for authorisation of a clinical trial on medicinal product for human use to the competent authorities, notification of substantial amendments and declaration of the end of the trial, October 2005, European Commission, Enterprise Directorate-General. Available at: ec.europa.eu/enterprise/pharmaceuticals/ eudralex/vol-10/11_ca_14-2005.pdf
  18. Ohmann C, Demotes J, Sweeney F, et al., Alternative monitoring procedures in investigator initiated trials, KKS/ECRIN/TMF Meeting Report, April 2006.
  19. Piccart M, Goldhirsch A, Wood W, et al., Keeping faith with trial volunteers, Nature, 2007;446(7132):137–8.

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