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Squire, Sanders & Dempsey L.L.P. www.ssd.com Roadmap to Emerging Regions: Clinical Trials in Developing Countries International Clinical Trials Conference New York, 26 February 2009 Written By: Cristiana Spontoni Partner Squire, Sanders & Dempsey L.L.P. Brussels Presented by: Michael A. Swit, Esq. Vice President The Weinberg Group Inc. San Diego, California

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Page 1: Squire, Sanders & Dempsey L.L.P.  Roadmap to Emerging Regions: Clinical Trials in Developing Countries International Clinical Trials Conference

Squire, Sanders & Dempsey L.L.P.

www.ssd.com

Roadmap to Emerging Regions: Clinical Trials in Developing Countries

International Clinical Trials ConferenceNew York, 26 February 2009

Written By:Cristiana SpontoniPartnerSquire, Sanders & Dempsey L.L.P.Brussels

Presented by:Michael A. Swit, Esq.Vice PresidentThe Weinberg Group Inc.San Diego, California

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US and EU Data on Trials in Emerging Regions

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The Global Landscape

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69,175 clinical trials are being carried out in 161 countries1

Majority of trials are conducted in the U.S. and Western Europe

Increasingly being conducted in Central & Eastern Europe, Latin America and Asia

Trials increasingly outsourced to Clinical Research Organizations

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Globalization of Trials: European Data

According to the EMEA, around one quarter of patients recruited in pivotal trials submitted in MAAs to EMEA between 2005 and 2008 were recruited in:

• Latin America

• Asia

• CIS

• Africa

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Recurrent Themes in Global Trials

• Good central coordination but flexibility to local requirements/habits/culture (eg, CTA templates)

• Sound use of resources: CRO, PIs, Sites: how much should be delegated and how much should be kept under control (eg, negotiating/entering CTAs, filing for regulatory approvals)

• All the more true in emerging economies…

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Advantages and Challenges

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Advantages Of Emerging Economies

• Limited costs: drugs, hospitalisation, travel and other general expenses, basic support services

• Higher number of patients, especially naive patients (i.e., patients who never received a treatment)

• Large patient populations with diseases of both developed and developing countries (e.g., HIV/AIDS)

• Multi-ethnic/multiracial populations

• Wide spectrum for diseases

• Potential new markets (e.g., China)

• Competent/motivated PIs

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• Conducting trials in emerging regions poses a number of challenges:

– Different treatments and standard of care

– Differing levels of clinical research experience and sophistication

– Different capabilities of CROs in the region

• Requires greater direct management efforts

• Many apparent similarities in challenges requiring different responses

Clinical Trials in Emerging Regions

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• Regulatory– Trial Designs– Regulatory Authorities and IRB/ECs– Translation requirements– Import/Export licenses

• Legal– Contracts/Clinical Trial Agreements– Insurance requirements– Intellectual property issues

• Other– CRO Partnering– Site/Investigator Identification– Adherence to Good Clinical Practice– Assuring the Ethical Conduct of the Trial– Quality Control issues– Cultural and infrastructure considerations

Challenges of Conducting These Clinical Trials

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An ordinary day in an ordinary global trial-- Some real life experiences --

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Practical Challenge: Control of Temperature

• “Control of storage and transportation temperatures is essential in maintaining the quality of medicines and in helping to protect patients from sub-standard or ineffective medicines that may result from inadequate control” (J. Taylor, Quality and Standards Manager, MHRA)

• Increased risks for biotech products, vaccines, blood products, semi-solids, chemically unstable at certain temperatures, and of course, study drugs.

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Let’s Get a Fridge!

• Sponsor wants to perform a study at site x

• Site x does not have a way of keeping Study Drug at appropriate controlled temperature

• Let’s get a fridge there!

OK BUT…

• Can sponsor sell/donate the fridge?

– To whom? Under what circumstances? Do we need a written contract? Do we need to get prior authorizations? From whom?

• What if Site is a public hospital?

• What if we are talking about very expensive medical devices?

• Can the fridge be imported in country x?

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Legal Challenge: Study in 21 Jurisdictions in the EMEA Region

• Can a CTA be entered by a non-local Sponsor?

Answer:- Yes, BUT -- in one jurisdiction, still need to go through local entity or mediator- Yes BUT -- in Israel, sites often will object to contracting with a non-Israeli entity- Yes BUT -- certain regulatory procedures will have to be performed by local entities either because it is required by law (e.g., Ukraine) or because -- that’s the way we do things here  (Middle East)

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Legal Challenge 2: What’s the Right Price?

• Sponsor sells x vials of Study Drug to a non EU European country

• Custom authorities google name of Study Drug and find its price in the US: 10,000 USD

• Custom authorities apply a custom duty considering that value of the Study Drug

• Should Sponsor pay?

• What’s the practice in other countries?

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Ethical Challenge: Unusable Data

• Violations result in unusable data: in requesting marketing authorisation, a company submits a file to the EMEA, which includes the description of the trial performed. In examining the file, the EMEA evaluates the respect of GCP, the granting of informed consent and the approval by ECs.

– Illustrates just how important compliance with GCP will be

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The Emerging European Jurisdictions and Their Rules

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The Rules in Emerging EU Jurisdictions

• Estonia, Hungary, Latvia, Lithuania, Czech Republic, Slovakia, Slovenia, Poland, Bulgaria, Romania, Malta, Cyprus: now all EU countries

• Directive 2001/20/EC on clinical trials applies:

- GCP standards- Uniform regulatory requirements- BUT: local challenges still remain

• Highly educated and competent investigators

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The EU Directive on Clinical Trials

• Same rules (in principle!) across 27 jurisdictions

• Commercial + Non-commercial trials

• Phases I,II,III,IV

• All trials except “non-interventional” trials

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• Industry, Government, Research Council, University, …

• Does not need to be EU-based but must appoint EU-based representative that bears civil and criminal liability as EU-based sponsors

• Sponsor can delegate (NOT transfer!) sponsor responsibilities to third parties (e.g., CROs) BUT sponsor bears ultimate responsibility

The Sponsor

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• Informed consent

• Special consideration for children and incapacitated adults

• Data protection:

– Directive 95/46/EC regulates strictly any processing or transfer of data outside the EU

– Medical data qualifies as “sensitive”

– The US is considered not a “safe place” for the purpose of data protection

Protection of Trial Subjects

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Commencement of Trials in the EU

• 60 days max 1 x clock stop for info.

• 60+30+90 days max

• No Time Limit (exception)

FavorableOpinion of

EC

CA no grounds for

non-acceptanceExplicit

authorization required only

in certain cases

One opinion per MS

Separate proceduresbut can run in parallel

Sponsor applies for EUDRACT number

Application to EC Notification to CA

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• Substantial amendments to be notified to ECs and CAs (35 days max)

• Safety measures adopted to protect safety of subjects

• Notification of trial end (90 days or 15 if early termination)

• Notification of SUSARs

– fatal or life threatening: 7 days

– other SUSARs: 15 days

– annual reporting

• Notification of Serious Adverse Events

Guidance on reporting and standard forms

Conduct of a Trial – Reporting Obligations

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• Manufacture/importation authorisation

• Authorisation holder must have QP at disposal: check compliance with EU GMPs or standards that are “at least equivalent”

• IMPs must be supplied free of charge

IMPs – Investigational Medicinal Products

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• CAs can suspend or prohibit trials if:

– conditions for granting authorisation for trial conduct are not met anymore

– doubts about safety/scientific validity

• Must consult with sponsor/investigator except in cases of “imminent risk”

• CA will inform other CAs, EMEA and European Commission

• You may have duty to inform FDA as well

Suspension of Trials - Infringements

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• Before, during or after completion of a trial

• As part of marketing authorisation process or follow-up to it

• At: trial sites, IMP manufacturing site, any laboratory used in the trial, or at sponsor’s premises

• Conducted by CAs

Inspections on GCP/GMP Compliance

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GCP Violations = Unusable Data

• Drugs reviewed by the EMEA can be granted a marketing authorization only if they are based on clinical trials conducted in compliance with the Declaration of Helsinki

• In requesting marketing authorisation, a company submits a file to the EMEA, which includes the description of the trial performed. In examining the file, the EMEA evaluates the respect of GCP, the granting of informed consent and the approval by ECs.

• When problems are identified, namely regarding ethical aspects, the EMEA can advise the Commission to refuse the marketing authorisation or can advise the withdrawal of marketing authorisation already delivered by Member States. This information is also made public.

• However, the EMEA intervention happens after the clinical trial is finalised and presented in the file and not before or during the trial.

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Inconsistent Approach/Interpretation

An example…

• Question: can sponsor be non-EU based?

• EU law answer: yes, if it appoints a EU-based representative

– Answer in BG, Czech Rep., Estonia, Latvia, Lithuania, Malta, Romania, Slovakia, Slovenia: yes, if it appoints an EU representative

– Answer in Cyprus: NO!

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EU Rules on Trials Conducted in Third Countries

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EU Rules on Trials in Third Countries

• Financial penalties apply in case of failure to comply with clinical trials requirements

• Sites in third countries can be inspected by the competent authorities of Member States. The EMEA has a system of GCP inspections in third countries since 2006 which has led to an increasing number of inspections in Latin America, Africa and Asia

• Inspections concentrate primarily on: informed consent and appropriate EC (IRB) approvals

• EU assisting on GCP capacity building/inspections a number of countries - in last EMEA GCP Inspectors’ WG workprogramme: Croatia, Macedonia, Turkey

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Increased Regulatory Scrutiny

• A European Commission paper of 2002 indicated that:

– The regulatory framework for clinical trials is expected to adapt to the globalization.

– the budget and number of international/national GCP inspectors is expected to increase

– more information on all these clinical trials should be available through an international database

– the key role of IRBs and of capacity building in this area

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• Opinion 17 of the European group on ethics in science and new technologies to the European Commission: “Ethical aspects of clinical research in developing countries” (February 2003)

• 2006-2008: Series of Parliamentary Questions on trials in poor countries

• On 5 December, the EMEA issued a strategy paper on: “Acceptance of clinical trials conducted in third countries for evaluation in Marketing Authorisations”

Increased Regulatory Scrutiny …

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EMEA Action Plan: Watch This Space!

Three-year-s action plan includes:

• Clarify application of ethical standards

• Consider issues driving recruitment of subjects in third countries

• Consider tools to respond to non-compliance/step up GCP inspections

• Training of EMEA/sponsors/experts

• Increased transparency: EPAR should include a clear description of the assessment of ethical standards of trials in emerging economies

• Promote capacity building also through EU funding instruments

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Wrap-Up

• Clear opportunities ahead of sponsors in emerging regions

• Require strong central coordination and resource management

• But, also must understand need for flexibility in approach and understanding of local specificities

• Beware of compliance pitfalls no matter where you conduct your trial!

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Thanks!!

Cristiana Spontoni, PartnerT: 011.322.627.11.05  E: [email protected]

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Roadmap to Emerging Regions: Sponsor Experiences in Central Europe

and Asia

Carlos F. PezaFebruary 26, 2009

Page 37: Squire, Sanders & Dempsey L.L.P.  Roadmap to Emerging Regions: Clinical Trials in Developing Countries International Clinical Trials Conference

Phase IV trial in Oncology conducted in 5 countries (France, Germany, Greece, Italy, Slovenia) 250 sites 8,448 valid subjects (3,719 valid controls) Field period from November 2005 to October 2008

Cross-Sectional Survey on Tobacco Prevalence in Indonesia Inclusion criteria similar to control inclusion criteria in

European study 11 sites 1,500 valid subjects Field period from January to October 2007

Research was financially supported by Philip Morris International

Recent Experiences in Emerging Regions

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Author
Suggets you say in which citeis/or number of cities
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Slovenia

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Small number of sites provided access to almost every subject in the country who was suffering from the target condition

Regulatory Agency and Central Ethics Committee are among the most efficient in Europe

Highly educated and motivated Investigators Local CROs charged competitive fees for their

services Relatively few challenges for study start up and

conduct

Why Slovenia?

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Small country, well reachable Centralized healthcare system with developed

referral network Approximately 100 clinical trials are performed

annually Laws and regulations for conducting clinical trials

are based on EU Clinical Trials Directive (2001/20/EC)

Agency for Medicinal Products and Medical Devices (JAZMP) is the competent authority for clinical trial authorization

EC approval given at the national level by the National Medical Ethics Committee

National Cancer Registry

Specifics of Slovenian Situation

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Page 41: Squire, Sanders & Dempsey L.L.P.  Roadmap to Emerging Regions: Clinical Trials in Developing Countries International Clinical Trials Conference

Challenge: Identifying and vetting the appropriate CRO Identify the strength and weaknesses of

potential vendors Understand how you will have to supplement

for the potential weaknesses Our approach:

Vetted international and national CROs Decided on National/Local CRO

Identified its strengths Worked with them to shore up their potential

weaknesses

Overcoming the Challenges in Slovenia

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Challenge: Obtaining ethics approval for a controversially funded study

Our approach: Recruited Principal Investigator wisely

Provided him with the information needed to fully understand and promote the study

Became invested in the study Good reputation, leadership skills, and willing to act as a

key advocate of the study Set the stage with Ethics Committee

Identified, recruited and developed good working relationship with Key Opinion Leaders in order to understand local considerations

Understood the potential concerns of the members Addressed these during the submission Gained support of stakeholders and who demonstrated

this support to EC

Overcoming the Challenges in Slovenia

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Challenge: Achieving potential subject recruitment

Our approach: Developed Principal Investigator and sub-investigators

as key promoters and coordinators Coordination and promoting activities of different sites Coordinating and promoting study within site

Developed investigator network where subjects were identified in the periphery and “treated” in the central location

Motivated site team Actively recognize the role of each site member CRA partnership with sites

Kept site team informed and involv

Overcoming the Challenges in Slovenia

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1 Local/National CRO 16 Sites 1 Country Principal Investigator, 24

investigators/subinvestigators, more than 20 study nurses

Comparably high recruitment rate First patient in: April 2007 1,391 valid subjects (721 valid controls) 16% of total study subjects recruited within one

year Recruitment rate stable over the year (no holiday

gaps)

Slovenian Participation in the Study

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Excellent experience in Slovenia High subject recruitment rate Qualified and motivated medical professionals Uniformed regulatory issues as in Western

Europe EU Clinical Trials Directive, ICH and GCP

already implemented Relatively lower CRO costs to conduct the

trial

Our Experience in Slovenia

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Indonesia

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Originally intended to conduct a series of studies to understand the relative risks of smoking for a several disease end point

Planned to conduct several case-control studies for each of the disease endpoints

In planning the studies, it was determined that there did not exist valid epidemiological data to be able to guide the design of the studies

A pilot study of patients in hospitals to be used in the case-control studies was conducted

Indonesian Smoking Prevalence Study

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Large Country Very few trials being conducted, but numbers are

growing. Government and investigators receptive to industry

knowledge GCP implemented into national laws and guidelines

governing clinical trials ECs to be established at institutional,

regional/provincial, and national levels according to need National Agency for Drug and Food Control is competent

authority for clinical trial authorization Lack of population-based registries

Hospital based-cancer registries in 13 cities

Specifics of the Indonesian Situation

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Cross-sectional study on the smoking prevalence of Indonesian male hospital patients

Study performed to regulated standards of a clinical trial

11 hospital sites in Jakarta, Solo, Surabaya, Padang 1 Principal Investigator, 22

investigators/subinvestigators, 60 CRA/interviewers More than 18,000 medical records evaluated 1,533 valid subjects recruited 38 week field period

Indonesian Smoking Prevalence Study

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Challenge: Designing a clinical trial to account for the specifics of the region Cultural issues Inclusion/Exclusion Criteria Trial Length and approval timings Infrastructure issues Investigator and Staff Training

Our approach: Trial designed to account:

Differences in medical practice (disease diagnosis, investigator-patient relationship)

Translation of study/regulatory documents Validation of measurement scales (patient questionnaire)

Understood need to apply “partnership approach” to build supportive relationships

Overcoming the Challenges in Indonesia

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Challenge: Identifying and vetting the appropriate CRO partner No local CROs Only a handful of Regional CROs working in

Indonesia Our approach:

Decided on one regional CRO Worked on setting clear expectations on how the

study should be conducted Task distribution (assigning of responsibility) Which SOPs were going to be used

Increased communication Thorough training of CRO staff and co-monitoring

visits

Overcoming the Challenges in Indonesia

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Challenge: Investigators and Staff experience Lack of clinical trial experience Gaps between concept and reality in the field

Our Approach: Incorporation of GCP, ethical practices, clinical

management training into Investigator Meetings, CRA/interviewer training, monitor training Special emphasis on informed consent process The training methods paralleled the expected

performance of the study team Site based CRAs conducting SDVs during patient

recruitment process Increased site monitoring

Overcoming the Challenges in Indonesia

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Challenge: Local infrastructure and sites constraints Lack computerized central patient database

systems Lack of secure storage space Difficult internet and phone access Understaffing

Our approach: Site auditing prior to contract signature Financial investments made into resources and

personnel Regular monitoring

Overcoming the Challenges in Indonesia

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Challenge: Cultural Complexities Hierarchical social structure impacts recruitment

Investigator Site Patient

Our approach: Build trust and cultivate relationships

Principal Investigator Key Opinion leaders

Involve hospital administration in site selection and start up activities

Train and inform on “foreign” practices and international expectations

Overcoming the Challenges in Indonesia

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Untapped potential Large patient pool Many potential sites

Government and Investigators very eager to bring more clinical research into the country

Need for capacity building Limited infrastructure Continued need to help local authorities

adjust their regulatory environment to allow high quality clinical research

Our Experience in Indonesia

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Advance preparation and strategy development Thorough knowledge of local processes and operations Design trial with an implementable protocol Upfront dialogue and partnership-oriented approaches Identify a CRO that is suitable for you Know your limitations and how much you are willing to

concede to your vendors Audit CRO, site and monitors GCP training before start of the study Close monitoring during the study What is your plan B?

Approaches to Consider

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Questions?

Carlos F. PezaConsultant

The Weinberg Group Inc.One Embarcadero, Suite 500

San Francisco, CA 94111P +1 415.293.1031

[email protected]

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About Your SpeakerCarlos Peza is a Consultant at The Weinberg Group. He recently served as Project Manager for a large international Phase IV oncology trial. The study was carried out in more than 250 sites in five European countries and enrolled more than 8,500 valid subjects.

Mr. Peza also managed a cross-sectional study on smoking prevalence in Indonesia. The study field period took place over a period of 38 weeks in 2007 in 11 sites in Indonesia. More than 18,600 medical records were reviewed and valid data was collected from more than 1,500 subjects.

His main tasks in these studies were interacting with international, national, and regional CROs to assure comprehensive management of the studies. In addition, he managed the development and implementation of the data collection instruments and all interview-related project components, including the development of a computerized questionnaire instrument for the European study, translation of the data collection instruments into the appropriate country languages, as well as the training and monitoring of interviewers.

Through his experience at The Weinberg Group, Mr. Peza has developed a significant knowledge of protocol design, questionnaire design, data collection methods, survey quality, coverage error, and interviewer effects.