Thursday, February 26, 2009

The Ethics of Outsourcing

There has been a growing trend for drug companies to outsource clinical trials; the human studies that determine the safety and efficacy of medicines.

Now, as reported in the New York Times, an article about the globalization of clinical trials is raising questions about the ethics and the science of increasingly conducting studies outside the US, when the studies are meant to gather evidence for new drugs to gain approval in this country.

The article, “Ethical and Scientific Implications of the Globalization of Clinical Research,” by several Duke University researchers, suggests an ethical quagmire when drugs intended for wealthy nations are tested on people in developing countries. The authors suggest that human volunteers in foreign countries may be unduly influenced by the promise of financial compensation or free medical care to participate in clinical trials.

The report also asks whether drug research conducted in developing countries is relevant to the treatment of American patients. The authors write that drug research in developing countries, where certain populations may metabolize medications differently because of environmental factors or genetic mutations, might not be relevant for American patients.

Some critics say the authors used overly simplistic data mining to raise an alarm, without presenting hard evidence of widespread ethical or scientific problems. I also have a few observations of my own; some in agreement and some in disagreement with the Duke authors' statements.

The Duke authors are warranted in their worries about volunteers from developing nations being unduly influenced by financial compensation and free medical care. Many of these nations are poor, and the volunteers may be viewed as particularly vulnerable. However, the Declaration of Helsinki, recognizes the need for special protection in vulnerable populations; this protection comes in the source of the clinical trial protocol.

The protocol must include, among other things, information regarding potential conflicts of interest, incentives for volunteers, and provisions for treating and/or compensating volunteers who are harmed as a consequence of participation in the research study. This protocol must be reviewed and approved by an independent research ethics committee before the study can even begin. If the volunteers' health and rights would be subjected to malbeneficience or injustice in any way, then the protocol would be rejected.

Protocol reviewers must take into account the risks involved with the study and weigh those risks against the benefits. If the only benefits for the volunteer are monetary, then researchers are conducting an unethical trial. Participation in risky trials warrants a greater monetary compensation, and volunteers outside the US may be vulnerable because they will accept less money than an American would expect; however, how can one put a monetary value on someone's life?

Medical research involving a disadvantaged or vulnerable population is only justified if the research is responsive to the health needs and priorities of this population and if there is a reasonable likelihood that this population stands to benefit from the results of the research.

I also agree that volunteers may be unduly influenced by free medical treatment. It may be enticing to participate if the volunteer is offered free medical treatment; especially for patients who would never have received treatment at all. However, do the risks of the trial outweigh the benefits of a check up or treatment?

Duke authors also brought up the topic of relevance. Relevance may be a factor when studying safety and efficacy in different age groups, but I feel that, in many instances, relevance is a non-factor because we are all humans. However, populations that are underrepresented in medical research should be provided appropriate access to participation in research.

For example, in many clinical studies based in the US, the majority of participants are Caucasian. However, aren't there many other races/ethnicities represented in the US population? What if the Duke authors are correct, and a drug may have a different effect on African Americans because of mutations such as Sickle Cell Anemia? Wouldn't it prove to be beneficial to go outside the US and enroll subjects of that race/ethnicity?

The authors also questioned the relevance of testing outside the US because they feel that certain populations may metabolize medications differently because of environmental factors. If we are to believe this statement, then should we perform separate clinical trials within the US for Americans in Hawaii (tropical rainforest climate) as well as for Americans in Alaska (subarctic/tundra climate)? Where does it end?

The authors also seem to treat all foreign countries alike. Research conducted in some places outside the United States, like Canada and Sweden, might be perfectly relevant to American patients. For example, a clinical trial of the Merck drug Gardasil, a vaccine against the human papilloma virus, was conducted in Costa Rica, where there is a high incidence of the disease.

Whatever the interpretations, the use of offshore clinical trials is growing, and physicians must be conscious of the ethical, legal and regulatory norms and standards for research involving human subjects in their own countries as well as applicable international norms and standards; and no national or international ethical, legal or regulatory requirement should reduce or eliminate any of the protections for research subjects.

3 comments:

Bill Curry said...

You raise some good points. While there are many ethical questions relating to this topic, I am focusing on the drug maker's responsibility to perform clinical trials that will accurately gauge the safety and efficacy of their drugs for their future customers. I would argue that, while we are all human, there are great differences between America and some third world countries as far as life expectancy and other health factors. If a country has a life expectancy of 50 and we have one of 75, it is safe to say we are testing these drugs in a population utterly unrepresentative of the American population. The question then becomes does that make clinical trials prohibitively expensive? It depends on whether it is a phase-I, -II or -III trial. If a drug has made it to phase-III trials, it is likely that the drug will be approved in some form. Thus, phase-III trials should not be prohibitively expensive, since the company will likely be bringing in revenue from the drug. Perhaps there could be some kind of compromise, where phase-I trials are allowed in countries with dramatically different public health conditions, phase-II trials could be done in other countries with public health conditions closer to ours, and phase-III trials could only be done in an ICH (International Conference on Harmonization-- http://www.ich.org/cache/compo/276-254-1.html ) country.

Lisa Menard said...

I response to Bill's suggestions concerning my article:

Your comments are well taken, and I agree that there are differences among populations and that it is the drug maker's responsibility to perform accurate clinical trials; however, I do not agree with your idea of a compromise....you had suggested that Phase I trials could be tested on the third world subjects; this would actually create even greater ethical issues. Phase I trials are tested on a very small number of subjects because the focus is on safety of the product because, prior to phase I, the product has only been tested in animals. This would mean that, not only are drug companies being cheapskates by testing in "vulnerable" populations, but they are also avoiding harming Americans by testing on these third world subjects. Very nice try Bill, but critics of outsourcing would have a major field day with that idea.

Bill Curry said...

Actually, as I understand it, Phase I doses are small in comparison to Phase II and III doses. Efficacy is not what is tested in Phase I trials. That is why the doses are smaller. Phase I trials are primarily concerned with ADME (Absorbtion, Distribution, Metabolism and Excretion). Safety is a consideration in all three phases, and safety is not a greater concern in Phase I. Unless I am mistaken, there is actually generally less risk with Phase I trials than there is with Phase III trials. Thus, the implication is the opposite of what you contend. The more dangerous trials would actually be conducted on the Americans, and the less dangerous trials would be conducted on the "vulnerable third world" populations.