The ENCePP Code of Conduct: A best practise for scientific independence and transparency in noninterventional postauthorisation studies.

PURPOSE: The ENCePP Code of Conduct provides a framework for scientifically independent and transparent pharmacoepidemiological research. Despite becoming a landmark reference, practical implementation of key provisions was still limited. The fourth revision defines scientific independence and clarifies uncertainties on the applicability to postauthorisation safety studies requested by regulators. To separate the influence of the funder from the investigator's scientific responsibility, the Code now requires that the lead investigator is not employed by the funding institution. METHOD: To assess how the revised Code fits the ecosystem of noninterventional pharmacoepidemiology research in Europe, we first mapped key recommendations of the revised Code against ISPE Good Pharmacoepidemiology Practices and the ADVANCE Code of Conduct. We surveyed stakeholders to understand perceptions on its value and practical applicability. Representatives from the different stakeholders' groups described their experience and expectations. RESULTS: Unmet needs in pharmacoepidemiological research are fulfilled by providing unique guidance on roles and responsibilities to support scientific independence. The principles of scientific independence and transparency are well understood and reinforce trust in study results; however, around 70% of survey respondents still found some provisions difficult to apply. Representatives from stakeholders' groups found the new version promising, although limitations still exist. CONCLUSION: By clarifying definitions and roles, the latest revision of the Code sets a new standard in the relationship between investigators and funders to support scientific independence of pharmacoepidemiological research. Disseminating and training on the provisions of the Code would help stakeholders to better understand its advantages and promote its adoption in noninterventional research.

Bridge the gap: The need for harmonized regulatory and ethical standards for postmarketing observational studies.

Drug safety issues do not respect national borders. Hence, addressing a safety question may necessitate globally coordinated efforts between regulatory authorities and market authorization holders (MAHs) to draw reliable conclusions. Regulatory authorities have shared responsibility with MAHs sponsoring postmarketing nonintervention studies in determining study goals and design. Their shared accountabilities include what will be investigated and how the data will be retrieved to ensure appropriate study quality required for regulatory decision making. The need for a harmonized framework and ethical standards for postmarketing observational studies is well recognized but has been lacking even among the United States, European Union, and Japan, which are so-called International Conference on Harmonisation (ICH) regions. A recent update of the Council for International Organizations of Medical Sciences International Ethical Guidelines for Health-Related Research Involving Humans provides further clarification on provisions for informed consent and the role of research ethics committees. However, without incorporation into legislative structures, the future impact of these guidelines is uncertain. This lack of harmonization leads to a complex and uncertain framework for ethical review and for participant informed consent, resulting in numerous inefficiencies in the regulatory postmarketing observational studies. The regulatory frameworks for postmarketing observational studies conducted under the auspices of regulatory agencies in the 3 regions are reviewed, with a focus on ethical requirements and opportunities for efficiencies.

[Pharmacoepidemiolgy: regulatory basis, methodological approaches and scope]. / La pharmacoépidémiologie: bases réglementaires, approches méthodologiques et champ d'application.

Pharmacoepidemiology is a discipline that studies the use of drugs and evaluation of their beneficial or adverse effects on large populations. It requires compliance with laws and maintaining a regulatory approach in order to ensure confidentiality and protection of personal data. It also requires good knowledge of drugs and diseases and the use of the different available data sources. Pharmacoepidemiology incorporates epidemiological methods (cohort, case-control and cross-sectional studies) where the exposure is drug intake. These methods must be applied at the conception of the pharmacoepidemiological study in order to minimize the effect of bias hich can lead to false conclusions. This paper reviews the regulatory basis, methodological approaches and scope of pharmacoepidemiology.

Public good, personal privacy: a citizens' deliberation about using medical information for pharmacoepidemiological research.

BACKGROUND: Epidemiologists have long argued for access to personal medical information in order to undertake research in the public interest, while legislation and ethical guidelines have increasingly focused on protecting the privacy of individuals. How the public weighs up these public interest and privacy arguments is unclear. METHODS: A citizens' jury was held to explore public views about the use of medical information for the post-marketing surveillance of medicine safety. A steering group of stakeholders oversaw the process, including the framing of the question for the jury and the selection of expert witnesses and jurors. An independent chair and facilitator managed the 3-day hearing. RESULTS: The jury unanimously concluded that researchers contracted by a public body should be permitted to use medical information about identifiable people, without their consent, to study the safety of medicines--providing existing ethical guidelines and relevant laws are followed. Jurors who were initially uncomfortable about the use of information without their express consent all became more comfortable after obtaining further information and deliberating with other jurors. CONCLUSIONS: This outcome suggests that an informed public does not place personal privacy above societal benefits in the particular circumstance of medicines' safety research, given appropriate privacy safeguards. The specificity of the example, the framing of the public interest and privacy considerations--in the context of scientific, legal, ethical, clinical and consumer input--and the opportunity to deliberate, may explain why the conclusions of the jury differ from public opinion surveys about secondary uses of medical information.