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Round Table on Ongoing Trials
Round Table Participants included:
Dr Voahangy RASOLOFO, Institut Pasteur de Madagascar, Madagascar
Dr Jie Siu WANG, Director, Tianjin Centre for Disease Control
and Prevention, China
The Round Table was chaired by Pr Anne FAGOT-LARGEAULT.
Ethical Issues in Clinical Trials in China
- Professor Jie Siu WANG
History of Clinical Trial Ethics World
Wide
The main sources of guidance on the ethical conduct
of clinical trials are contained in the Nuremburg Code (1947),
the Helsinki Declaration (1964/2002), the Belmont Report (1979),
the WHO Guidelines for Good Clinical Practice for Trials on
Pharmaceutical Products (1982/1993), the Council of Europe's
Convention on Human Rights and Biomedicine (1997), and the
Guidelines and Recommendations for European Ethics Committees
of the European Forum for Good Clinical Practice (1997). Many
of these were developed in response to specific events.
The Belmont Report contains seven requirements
providing a systematic and coherent framework for clinical
trials: social or scientific value, scientific validity, fair
subject selection, favourable risk-benefit ratio, independent
review, informed consent, and respect for potential and enrolled
subjects.
The Development of Clinical Trial Ethics
in China
China faced many problems in ethics before 1999.
There were no ethics committee at the national or regional
levels. Proposals were thus not approved by ethics committees,
and individuals were uninformed or inadequately informed about
the clinical trials. There was no requirement for individuals
to sign consent forms, and certain individuals were involved
in trials without their informed consent. With the development
of the world wide standard on clinical trial ethics, China
introduced a drugs inspection law in 1985. In 1995, Good Clinical
Practice (GCP) was finalised for approval, and came into operation
in 1999. In 2001 a new Drug Inspection Law was introduced,
replacing the old law. This legislation provides that:
· Trials can only be conducted in places approved
by the SDA.
· Investigators must be trained, qualified and have certain
experience with GCP in China.
· The clinical trial proposal must be approved by the Ethics
Committee.
· Trial subjects should have adequate access to information
and be aware of the risks, benefits and rights that apply.
· Informed consent forms must be signed by the trial subjects.
· The subjects should have their privacy protected and the
opportunity to unilaterally withdraw from the ongoing research.
The legislation thus significantly improved clinical
trials in China. However, certain Chinese scientists urged
that clinical trials be made more ethical. For example, in
1999, Dr Hu Minyan suggested the composition, duties and functions
of the Ethics Committee. In 2001, Dr Ba Denian recommended
the creation of a National Medical Ethics Committee as quickly
as possible. In 2001, Dr Lu Yuan proposed that trial subjects'
benefits and rights should be protected.
raining courses focused on ethics have now been
held in China. One such course held in Beijing brought together
90 participants from related provinces and HIV prevention
centres. Professor Nancy King from the US and various Chinese
scientists presented their experience and studies in the development
of clinical trial ethics.
China's recognition of the ethics of clinical
trials have been strengthened by these academic activities.
The Ethics of Clinical Trial Study A in
Tianjin
In 1999, the IUATLD began to consult with the
TTI in CDC on Study A, in which sub-centres in Tianjin and
Henan participated. Prior to the implementation of this study,
local ethics committees approved the research protocol in
terms of the IUATLD requirements. All of the enrolled subjects
signed an informed consent form. This was the first time that
Tianjin CDC and TTI worked to make clinical research more
ethical.
Before Study A was carried out, a survey was
held of Tianjin citizens' attitudes to the clinical trials.
They were informed of the trial details and made a decision
as to whether they would participate. Of the 100 patients
identified, 50% agreed to participate, and 41% refused to
participate. 66% agreed to participate in a clinical trial
of new vaccines; and 44% refused.
During Study A, the IUATLD held a workshop on
clinical trials ethics in Tianjin in March 2001. Over 100
scientists from over 10 provinces attended the workshop. Dr
Naomi Bock presented the concept of clinical trial ethics
and the details of the Helsinki Declaration. The post-workshop
evaluation showed that 90% of participants heard about the
Helsinki Declaration for the first time at the workshop, and
that it allowed them to acquaint themselves with clinical
trial ethics.
The slide shows details of the informed consent
form used in Study A. Of the 146 individuals who fulfilled
the criteria for Study A, 45 refused to participate in the
trial. 101 agreed to participate but a further 33% refused
to sign the form. We therefore finally enrolled 68 patients
in the trial.
The reasons given for the refusal to sign included
first, that individuals had doubts about signing the form
itself. Second, they had doubts about the new medicine and
the treatment regimen for the trial. Third, some patients
were already being treated and had shown an obvious improvement.
They were unwilling to take the risk of changing to a new
treatment. Fourth, the parents of some patients aged 16 to
18 were unwilling to allow their children to undergo the risks
of the trial. Fifth, in some cases, the patient's company
paid their medical charges and some patients wanted to pay
for the treatment themselves. Finally, a higher level of compensation
was required by some patients.
Future Challenges in China
Even though the situation has improved greatly,
there is still great room for progress. The recognition of
clinical trial ethics among the medical authorities, Chinese
doctors and patients is still not widespread. Some clinical
trials are proposed without consideration of the trial subject's
rights and benefits. Chinese people tend to regard the informed
consent as a bonding contract, and they prefer to have an
oral agreement.
The Chinese Ethics Committee is not properly
constituted. Due to a large variety of advertisements on new
drugs and treatment, people doubt the validity of physician's
explanations of the trial. There is a shortage of research
budgets and economic compensation for the problems and side
effects encountered during trials.
I would make the following suggestions for the
future. Extensive training of experts in the clinical ethics
field should be funded by international organisations. An
organisation is required to establish a Chinese clinical trial
ethics team. The Tianjin Centre for Disease Control and Prevention
would like to be the coordinating centre for clinical trial
ethics research and training. The preferred trainees should
include the principal investigators, the head of institutes
potentially involved in conducting clinical trials, members
of the Ethics Committee, and relevant medical staff and government
officials. Signature of the informed consent form could be
modified to provide for oral consent, verified by a third
party signature.
Conclusion
We are confident about being able to establish
and improve the clinical trials ethics system in China. However,
China needs the support of the European Commission and of
other international organisations in order to carry this issue
forward.
Clinical Trials in Madagascar - Dr Voahangy
RASOLOFO
I will be discussing the evolution of values
and ethics in medicine in Madagascar.
History of Vaccination in Madagascar
Madagascar became a French colony in 1896, governed
by General Gallieni. At the time of his arrival, Madagascar
was affected by a serious small pox problem. At the end of
the 19th century, the Tananarive Institute distributed a small
pox and rabies vaccine throughout the country. In 1921, Madagascar
was affected by a plague epidemic. The EV vaccine against
the plague was developed in 1931. In terms of tuberculosis,
the BCG strain was obtained from Calmette in 1924, and was
produced by the Institut Pasteur of Madagascar in 1926. In
1993, production of the BCG vaccine was brought to an end
due to G&P problems. In 1961, the mission of the Institut
Pasteur of Madagascar was changed to that of public health,
and it became the research centre for the Ministry of Health.
Madagascar Ethics Committee
As late as the 1990s, Madagascar did not have
an ethics committee; only the Minister of Health could issue
authorisation for medical studies. The Minister at that time
considered that the Malagasy people were not guinea pigs,
and she refused all clinical trials in the country. The National
Ethics Committee for Biological Research was created in 1995.
All members are appointed by the Minister of Health. Institutions
submit projects to the Ministry of Health, which transfers
them to the National Ethics Committee. In 2001, five such
projects were under review by the National Ethics Committee.
Conclusion
Ethical issues in clinical trials in developing
countries are problematical where political interests are
more important than ethics.
Round Table Discussion
Dr Anne FAGOT-LARGEAULT
I believe you all have many questions on HIV testing.
Brigitte GICQUEL
We are beginning several trials on new drugs and vaccines.
We will also be considering variations in populations with
a view to determining whether certain genes are linked to
sensibility. To this end, we have to determine whether tuberculosis
in patients is associated with HIV or not. Therefore, when
we begin a study, we need to include HIV testing as well as
PPD testing. In many cases, this is problematical.
Dr Anne FAGOT-LARGEAULT
Why do you not test for genetic predisposition as well?
Brigitte GICQUEL
We currently have more information on innate immunity. We
know that certain receptors on phagocytes are responsible
for entry of the bacilli. A study dealing with this has already
been published on leprosy, and several studies will be carried
out on tuberculosis.
Dr Anne FAGOT-LARGEAULT
Why do you not then test for HIV, tuberculosis and genetic
factors?
Brigitte GICQUEL
The variations in some genes are relevant to innate immunity
for tuberculosis. However, this is not the aim of the study.
Dr Anne FAGOT-LARGEAULT
What are the arguments in favour of testing and the arguments
against testing?
Solomon BENATAR, Department
of UCT Bioethics, University of Cape Town
Let us imagine that a researcher is interested in obtain new
knowledge. He or she has many scientific questions to be answered.
If these questions are answered, not only will knowledge be
improved, but the treatment provided to patients will also
be improved.
Brigitte GICQUEL
If we discover an important variation related to the disease,
this could be part of the diagnosis process in the future.
Solomon BENATAR
The role of the scientist is thus to pursue new knowledge
with a view to better diagnosis and treatment in the future.
In order to do that, research has to be carried out in humans.
There is a risk that the researcher will use people who are
ill as a means to the end of answering those questions. The
whole history of medical research is based on the concept
that the needs of society should not override the needs of
individuals. The use of individuals as a means to an end is
considered to be unethical, for example, under the Helsinki
Declaration. Therefore, if you want to do research on people
suffering from HIV or from tuberculosis, the research must
have some benefit for them. Furthermore, the individuals involved
must understand that they are the subjects of research and
not of treatment. Dr
Marc DOHERTY
We should not underestimate the people participating in trials.
I have often been surprised by the willingness of people in
some of the poorest rural zones of Africa to participate in
the trials with a view to helping their community.
Solomon BENATAR
Many people in developing countries are more trusting than
the average sceptical Western subject. We cannot simply arrive
in countries with a view to carrying out research without
taking into account the existing, and often inadequate, health
care systems in those countries. We have to do something that
will improve the situation of the people in the country. Unfortunately,
researchers do not often see this as their role. There is
thus a tension between using people to obtain the information
you want, and abusing people to obtain that information. About
40% of the world's population do not have access to any of
the scientific progress that has been made in the past 100
years. There is no guarantee that the new knowledge obtained
will result in a benefit for a very significant proportion
of the world's population. However, these are the very people
that we want to do research on.
Dr Hazell DOCKRELL
The project we have been running in northern Malawi for the
past 25 years is completely free standing and not attached
to any local institution. Over that time, the unit has made
a great contribution to the community. Our staff on site are
often concerned that we are not putting more back into the
community. However, we are partly funded by the Wellcome Trust,
which argues that it is not an aid body but a research body.
Solomon BENATAR
This is one of the most contentious issues in the debate on
international research ethics. We need greater coordination
between the different bodies working in each country, which
often do not know what the others are doing. I believe that
research workers have a responsibility to use their influence
to drive more resources for aid in the country. Researchers
are often reluctant to do this, arguing that they are not
aid or care givers.
Richard ASHCROFT
The original question refers to a vaccine trial that requires
HIV negative subjects. This requires the carrying out of HIV
screening at enrolment. Part of the consent process would
include counselling people that you are going to test for
HIV. One could argue that the researcher's role ends there;
they are not responsible for then providing HIV treatment.
Alternatively, once could argue that by testing for HIV, the
researcher becomes responsible for providing HIV treatment
to those who test positive. In this context, I would suggest
the analogy of someone who comes upon an individual drowning
in the Seine. Most people would argue that the right thing
to do would be to jump in and save the person. However, are
you then responsible for that person, for example, if you
know that he or she has suicidal tendencies? Are you more
responsible if you happen to be a psychiatrist or if you are
a researcher in the epidemiology of suicide? As a researcher,
do you have a duty to people who enter into your purview?
Simply by being in that place at that time, have you created
a relationship with those people that gives you greater responsibility?
Brigitte GICQUEL
We are not going to undertake a trial just anywhere. It will
be undertaken in conditions where people can be treated. We
should provide a benefit, for example, by increasing the capacity
for diagnosis. This would be of mutual benefit for both the
country and for the researcher. By choosing the site for the
trial in collaboration with people involved in controlled
programmes, many of these problems can be avoided.
Dr Marc DOHERTY
If the person saved from the Seine advises you that he or
she was driven to suicide by significant debts, are you then
responsible for paying that person's debt? In many cases in
Africa, it is not possible to make any significant impact
on HIV with the resources that are available for clinical
work.
Solomon BENATAR
A basic ethical principle provides that, if you cannot do
any good, you should at least not do any harm. By testing
someone for HIV and advising them that they are HIV positive,
you could do some harm given that you cannot offer them any
treatment. In the 1960s and 1970s it was possible to eradicate
tuberculosis from the world. We had the resources to do this,
but not the political will. We could find a cure or a vaccine
for HIV, but it is likely that this will not reach the very
people who need it. This raises the issue of whether we can
really translate our scientific knowledge into useful action.
If researchers themselves do not see this as part of that
role, no one else will.
Dr Marc DOHERTY
We would not consider doing a trial if we did not consider
that it would have a benefit for the individuals involved.
The polio figures over the last few decades show that we can
make a difference.
Dr Anne FAGOT-LARGEAULT
You seem to imply that a TB diagnosis is neutral, but that
a HIV diagnosis will lead to strong social discrimination.
However, in the past in France for example, a TB diagnosis
was considered as a source of shame.
Solomon BENATAR
We can cure tuberculosis, but we cannot cure HIV. The stigma
attached to HIV is still very high both for individuals and
communities. Are we doing enough to reduce that stigma? For
example, Doctors without Borders have been offering anti-retroviral
treatment on a selective basis in a certain area of Africa.
Many more people are now coming to the centre for HIV testing,
because they know that they have the possibility of being
treated. No one wants to be tested when there is no possibility
of treatment.
Dr Marc DOHERTY
In many African countries, TB or leprosy is still highly stigmatised,
even though they are treatable diseases. In Ethiopia for example,
someone who is diagnosed with leprosy will be excluded from
the family or village, even when they are cured.
Dr Voahangy RASOLOFO
The problem is not the stigma attached to HIV but how can
we take care of HIV positive patients. For example, anti-retroviral
therapy is not available in our country. This is why we have
suggested carrying out an anonymous test, but is this ethical?
Boubacar BAH, CHU Ignace
Deen, Guinea
The problem of HIV testing is a real problem in our countries.
Some individuals will accept an HIV test, because they do
not know exactly what it means in terms of consequences. Those
who have more information, may either refuse the test or agree
to it. In relation to tuberculosis, the greatest reluctance
to testing arises in more educated people, who fear that they
will lose their jobs if they test positive. Given that we
are unable to offer any treatment, I believe that if a patient
refuses to undergo an HIV test, the test should not be carried
out.
Dr Anne FAGOT-LARGEAULT
I agree completely. It is not possible to carry out an HIV
test without the knowledge of the person.
Dr Voahangy RASOLOFO
However, if a patient agrees to be HIV tested, and in fact
tests positive, what do we then do? Certain countries such
as Uganda have a national AIDS programme. However, when the
national AIDS programmes are either non-existent or very poor,
what do we do? If we do anonymous, non-correlated testing,
we will know we have HIVs in our cohort. What is our resulting
responsibility?
Eduardo TICONA, Hospital
Nacional Dos de Mayo, Peru
The development of ethics committees in many countries involves
various social and political issues. The right balance must
be found in each country.
Brigitte GICQUEL
If a research institution obtains the authorisation the national
ethics committee in the country where the trial will be carried
out, does it also need the authorisation of the ethics committee
in its own country?
Dr Anne FAGOT-LARGEAULT
Vaccine trials are usually very large and carried out over
many different countries. Do all the ethics committees in
each country have to be consulted?
Richard ASHCROFT
Usually, there is no one single ethics committee that can
provide approval. I was struck by the Madagascar example where
the national ethics committee was not consulted at all. This
would seem to argue for the need for approval from the home
country and from the country where the research will be carried
out.
Solomon BENATAR
Any researcher from the North who wants to undertake research
in a developing country should have approval from both the
home country's ethics committee and the ethics committee of
the developing country. This ensures that researchers do not
undertake unethical actions outside of their own countries.
Of course, it could be possible that both ethics committees
agree to something that is unethical.
Dr Anne FAGOT-LARGEAULT
In most countries where the protocols are made, there is no
national rule that requires people to have their protocol
reviewed at home before applying it in another country. This
issue has been discussed in France but has not yet been made
a legal obligation.
Solomon BENATAR
We should go beyond legal requirements, which often lag behind
practice or only set minimum standards. We should encourage
people to meet a higher standard than they are currently meeting.
Hopefully, this would become part of the law in due course.
Dr Anne FAGOT-LARGEAULT
For example, if a protocol of the Institut Pasteur was to
be applied in Thailand, to which ethics committee should the
request by submitted?
Solomon BENATAR
To the ethics committee of the Institut Pasteur.
Brigitte GICQUEL
Should we not also submit the protocol to a national ethics
committee, if it exists?
Dr Hazell DOCKRELL
We would not let anyone carry out work without prior approval
from our own ethics committee. If the study is being carried
out in the UK, we would also require approval from the local
NHS trust. However, if the work is to be performed in another
country, there is no relevant body in the UK who could approve
it.
Brigitte GICQUEL
Obtaining approval from our own ethics committees does not
prevent us from going to the national authority.
Dr Marc DOHERTY
We have found that local authorities will not review studies
that are not being carried out in their areas. We therefore
submitted our proposal to the WHO. However, the WHO does not
have the resources to carry out such reviews at the global
level. There is thus no authority that can cover these issues.
Eduardo TICONA
The situation of each country must be considered in determining
what can be done in each country.
Brigitte GICQUEL
Each country should have its own ethics committee, which will
make a decision according to the situation in that country.
For example, anti-retroviral therapy is available in some
countries and not in others. In some countries, such therapy
is associated with a stigma, and in others not.
Richard ASHCROFT
In some countries, the national ethics committee may be willing
to provide its opinion on research to be carried out outside
of the country. In others, they will not. Researchers can
ask committees for an opinion and commit to following the
opinion, even if it is not legally binding.
Dr Anne FAGOT-LARGEAULT
The local committees I am familiar with have declared themselves
as being not competent to provide an opinion in such cases.
Solomon BENATAR
Local ethics committees will usually only be reluctant to
provide advice in very complex cases. In South Africa, for
example, none of the ethics committees of any of our universities
felt that they were sufficiently competent to provide an opinion
on the early HIV vaccines trials. We therefore produced a
set of guidelines for HIV vaccine trials, which will become
the national guidelines. It will now be possible for local
ethics committees to provide an opinion on the basis of those
guidelines. We are trying to grapple with these complex issues
and provide guidance. UNAIDS is also working on developing
some guidelines in this area.
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