REFERENCE PAPER
Currently Discussed
-
ISDB members in Asia & Pacific region are planning a regional
meeting to be held in Sri Lanka in October 2000. For more information
please contact Krisantha Weerasuriya (e-mail: kw_twcp@slt.lk)
and Margaret Ewen (e-mail: margaret_ewen@moh.govt.nz)
-
Drug and Therapeutics Bulletin is planning a training course for
editors in 200. More details will be given in the next newsletter.
-
The French bulletin la revue Prescrire would be glad to organise
a meeting of editors in Paris in summer 2000. The main objective would
be to exchange editorial exchange editorial experiences among ISDB
bulletin editors.
Anyone interested in attending and contributing to such a meeting is
invited to get in touch with Christophe Kopp (e-mail: christophe.kopp@wanadoo.fr)
THE ERICE DECLARATION
On Communitcatingnformation Drug
Safety I
The Erice Declaration on communications in pharmacovigilance was
published in 1997 following the International Conference on Developing
Effective Communication in Pharmacovigilance. The meeting was organised
by: the Uppsala Monitoring Centre, the Clinical Pharmacology Unit, Institute
of Pharmacology of Verona University, with the support of IUPHAR’s Division
of Clinical Pharmacology, the Ettore Majorana Centre for Scientific
Culture, International School of Pharmacology, the World Health Organisation,
and supported by EQUUS Communications, London. This Declaration is still
relevant today and deserves a second round.
The following declaration was drawn up at the International Conference
on Developing Effective Communications in Pharmacovigilance, Erice,
Sicily, 24-27 September 1997. It was attended by health professionals,
researchers, academics, media writers, representatives of the pharmaceutical
industry, drug regulators, patients, lawyers, consumers and international
health organisations.
Monitoring, evaluating and communicating drug safety is a public-health
activity with profound implications that depend on the integrity and
collective responsibility of all parties – consumers, health professionals,
researches, academia, media, pharmaceutical industry, drug regulators,
governments and international organisations – working together. High
scientific, ethical and professional standards and a moral code should
govern this activity. The inherent uncertainty of the risks and benefits
of drugs needs to be acknowledged and explained. Decisions and actions
that based on this uncertainty should be informed by scientific and
clinical considerations and should take into account social realities
and circumstances.
Flaws in drug safety communication at all levels of safety can lead
mistrust, misinformation and misguided actions resulting in harm and
the creation of a climate where drug safety data may be hidden, withheld,
or ignored.
Fact should be distinguished from speculation and hypothesis, and actions
taken should reflect the needs of those affected and the care they require.
These actions call for systems and legislations, nationally and internationally,
that ensure full and open exchange of information, and standards of
evaluation. These standards will ensure that risks and benefits can
be assessed explained and acted upon openly and spirit that promotes
general confidence and trust. The following statements set forth the
basic requirements for this to happen, and were agreed upon by all participants
from 34 countries at Erice:
-
Drug safety information must serve the health of the public. Such
information should be ethically and effectively communicated in terms
of both content and method. Facts, hypotheses and conclusions should
be distinguished, uncertainty acknowledged, and information provided
in ways that meet both general and individual needs.
-
Education in the appropriate use of drugs, including interpretation
of safety information, is essential for the public at large, as well
as for patients health-care providers. Such education requires special
commitment and resources. Drug information directed to the public
in whatever form should be balanced with respect to risks and benefits.
-
All the evidence needed to assess and understand risks and benefits
must be openly available. Constraints, on communication parties, which
hinder their ability to meet this goal must be recognised and overcome.
-
Every country needs a system with independent expertise to ensure
that safety information on all available drugs is adequately collected,
impartially evaluated, and made accessible to all. Adequate non-partisan
financing must be available to support the system. Exchange of data
and evaluations among countries must be encouraged and supported.
-
A strong basis for drug safety monitoring has laid over a long
period, although sometimes in response to disasters. Innovation in
this field now needs to ensure that emergent problems are promptly
recognised and efficiently dealt with, and that information and solutions
are effectively communicated.
These ideals are achievable and the participants at the conference
dedicate/commit themselves accordingly. Details of what might be done
to give effect to this declaration have been considered at the conference
and form the substance of the conference report.
Erice, September 27, 1997
Motion agreed on by a General Assembly of the ISDB,
Amsterdam September 1999
EUSURING THAT DRUG REGULATORY AUTHORIETIES SERVE
PUBLIC HEALTH FIRST AND FOREMOST
The ISDB adopt the aim engaging in actions that ensure that drug regulatory
authorities place public health considerations above the commercial
interests of the drug industry.
To this end ISDB will undertake actions aimed at ensuring that drug
bulletins obtain full data on the indications, efficacy and risks of
drugs from the drug regulatory authorities.
FUNDING OF MEDICINES AGENCIES
This paper was published in the December issue
of la revue Prescrire.
More and more countries are creating medicines agencies responsible
for licensing new drugs and for postmarketing surveillance, tasks previously
confided to health ministry departments. European Union member states
have the European Medicines Evaluation Agency (EMEA), which, for some
categories of drugs, supplants national bodies.
These new agencies are public bodies under state control, but have a
certain degree of autonomy. While the budget of health ministry departments
responsible for drug evaluation was included in that of the ministries
concerned (i.e. drawn from the public coffer), the new agencies manage
their own expenditures and funding. The latter consists largely of fees
paid by drug manufacturers on submission of marketing authorisation
requests (a).
The yearly reports released by some agencies give an approximate idea
of their funding sources. They can therefore be used to compare the
parts represented by public and private funding (the latter consisting
mainly of fees paid by drug companies).
We examined the latest reports released by the French medicines agency
(which, in 1999, was renamed the French Acency for Health Product Safety1
and by the European Medicines Evaluation Agency (EMEA)2, i.e. the two
agencies via which drugs on the French market. We also examined the
latest financial report from the United States Food and Drug Administration
(FDA), one of the oldest such bodies (b)3.
The contributions made by the public and private sectors vary according
to the agency but, in all three cases, the part represented by drug
manufacturers’ fees is large and growing. Thus, it represented 36% of
the FDA budget (for human drug assessment) in 1997, and 40% in 1998
3; for the French agency, manufactures’ dues represented 68% of receipts
in 1997 and 1998, while public funding fell from 27% to 24% (c)1; finally,
for the European agency (EMEA), drug companies fees represented 39%
of receipts in 1996, 48% in 1997 and 53% in 19982.
This trend towards increasing funding by the industry (in the form of
fees), and the corresponding reduction in public funding is confirmed
by the EMEA Management Board, which anticipates that industry will account
for 69% of funding and the European Union only 28% in the year 20004.
Fees paid by manufacturers are increasingly high, and are thus gradually
becoming the main funding source for medicines evaluation agencies.
Is this logical, when these agencies work not on behalf of drug manufacturers
but also have a public health mission? And is it reasonable in a context
where pharmaceutical companies are becoming increasingly concentrated
(by merging) and powerful, and, pressed by international competition,
more and more in a hurry to obtain market authorisation for their new
products?
Likewise, the race between the larger medicines agencies (American,
European and Japanese) to offer manufactures the shortest interval between
file submission and marketing authorisation carries a risk of premature
drug marketing. This is one of the inevitable consequences of “independent”
medicines evaluation agencies getting much or most of their running
costs directly from industry.
La revue Prescrire
a- Manufactures also pay fees for other services,
but those paid for
marketing applications are highest. In 1999, marketing application fees
for new drugs were 7.500 to 22.500 Euros in France, 140.000 to 200.000
Euros for the EMEA, and equivalent of 189.500 Euros for the FDA.
b- More precisely, it is the financial report
involving the section of the FDA responsible for drug assessment.
c- Note that the part of income corresponding
to services and goods rose from 3% to 6% during the same period.
d- The data given in the French medicines agency
reports for 1997 and 1998 correspond to estimated budgets.
1- French medicines Agency
“Rapport 1997”: 270 pages.
2- The European Agency for the Evaluation of
Medicinal Products “Fourth General Report” 1998: 83 pages.
3- Food and Drug Administration “FY 1998 PDUFA
Financial Report” 1998: 26 pages.
4- The European Agency for the Evaluation of
Medicinal Products – Press release “Twenty-first meeting of the management
board” 10 February 1999: 1 page.
|