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#AllTrials <https://twitter.com/search?q=%23AllTrials> Retroceso de la 
Agencia Europea del Medicamento respecto al acceso a los datos de 
ensayos clínicos.
#AllTrials <https://twitter.com/search?q=%23AllTrials> *Backpedalling on 
European Medicine Agency’s "proactive publication of clinical-data" 
draft policy.* *Was it all just a window-dressing exercise? Who or what 
is the EMA afraid of?
*

It is online athttp://english.prescrire.org/en/  (1st item of the page!)
Direct link:http://english.prescrire.org/en/79/207/46302/3553/3303/SubReportDetails.aspx

El 20/05/2014 17:06, Juan Gérvas escribió:
> -attached, the press release just on air (ISDB, Prescrire and more)
> -about EMA and its  “proactive publication of clinical-data” policy
> -un saludo
> -juan gérvas
>
> El 17/05/2014 20:10, Tom Jefferson escribió:
>> Please blog away
>>
>>
>> On 17 May 2014 11:23, Klim McPherson <[log in to unmask] 
>> <mailto:[log in to unmask]>> wrote:
>>
>>     Also as the argument goes:  'If more transparency then many fewer
>>     RCT's and since regulatory approval 'demands' double blind RT 's
>>     evidence that presents problems in a world where side effects are
>>     purely a nuisance to manufacturers  and often best swept under
>>     the carpet.
>>
>>     klim
>>
>>     From: healingjia Price <[log in to unmask]
>>     <mailto:[log in to unmask]>>
>>     Reply-To: healingjia Price <[log in to unmask]
>>     <mailto:[log in to unmask]>>
>>     Date: Saturday, 17 May 2014 10:00
>>     To: "[log in to unmask]
>>     <mailto:[log in to unmask]>"
>>     <[log in to unmask]
>>     <mailto:[log in to unmask]>>
>>     Subject: Re: EMA's U Turn
>>
>>     Financial interests  and to reduce pre release opposition by such
>>     things as an evidence based critical appraisal of the data to
>>     prevent harm
>>
>>     Sent from my iPhone
>>
>>     On May 17, 2014, at 6:27 AM, "Zbys Fedorowicz"
>>     <[log in to unmask] <mailto:[log in to unmask]>> wrote:
>>
>>>     Isn’t this actually a Y-TURN i.e. WHY?
>>>
>>>     Prof Zbys Fedorowicz
>>>
>>>     Director
>>>
>>>     The Bahrain Branch of the UK Cochrane Centre
>>>
>>>     The Cochrane Collaboration
>>>
>>>     For information on the Bahrain branch see:
>>>     http://bahrain.cochrane.org/en/index.html
>>>
>>>     *From:*Evidence based health (EBH)
>>>     [mailto:[log in to unmask]] *On Behalf Of *Tom
>>>     Jefferson
>>>     *Sent:* Saturday, May 17, 2014 12:29 AM
>>>     *To:* [log in to unmask]
>>>     <mailto:[log in to unmask]>
>>>     *Subject:* EMA's U Turn
>>>
>>>     Is the Lady U-Turning?
>>>
>>>     Peter Doshi, Tom Jefferson
>>>
>>>     May 16, 2014
>>>
>>>     The EMA appears poised to make a major U-turn on its
>>>     transparency initiatives, reversing its principle of public
>>>     access to clinical trial data as its sets up a system of
>>>     controlled access similar to those independently established by
>>>     industry. This is a stunning and surprising reversal,
>>>     particularly as it comes after AbbView dropped its lawsuit
>>>     against EMA and after the passing of the European clinical
>>>     trials legislation which will require public access to clinical
>>>     study reports. If
>>>     finalized, the EMA’s new policy will prohibit a data requestor
>>>     from even printing out a redacted clinical study report: they
>>>     must instead read it in a so-called “view on-screen-only” mode.
>>>     In the first half of 2013, the EMA held a series of
>>>     teleconferences with its five advisory committees to obtain
>>>     guidance on developing a policy for the draft policy
>>>     on proactive publication of and access to clinical-trial data.
>>>     Individuals serving on the advisory committees came from
>>>     academia, industry, and other sectors. The process was open,
>>>     transparent, and inclusive. We served on some of these
>>>     advisory committees. The process culminated in the publication,
>>>     on June 24, 2013, of a draft policy document titled “Publication
>>>     and access to clinical-trial data” (EMA/240810/2013
>>>     <tel:240810%2F2013>). The EMA invited public comments on this
>>>     document, and received more than 1,000 submissions from
>>>     stakeholders (http://tinyurl.com/k9a2plb). This week, the EMA is
>>>     discussing the finalization of its policy. Documents distributed
>>>     prior to the meeting indicate that a major U-turn is about to
>>>     occur.  Under the draft Terms of Use policy document: “ the User
>>>     [data requestor] acknowledges that the Information [meaning
>>>     Clinical Study Reports as well as other types of documents] will
>>>     be made available to the User in a “view-on-screen-only” mode,
>>>     after completing the registration process. The User agrees that
>>>     the User is not permitted to
>>>     download, save, edit, photograph print, distribute or transfer
>>>     the Information. The User agrees not to access the Information
>>>     using a method other than the interface provided by the EMA, or
>>>     remove, bypass, circumvent, neutralise or modify any
>>>     technological protection measures which apply to the Information.”
>>>
>>>     The EMA’s June 2013 draft policy document suggested that
>>>     clinical study reports were largely “open access” documents,
>>>     with only those sections containing individual participant data
>>>     necessitating a “controlled access” scheme (See Annex II of the
>>>     June 2013 draft policy). However, the new Terms of Use document
>>>     indicates that EMA now plans to treat clinical study reports as
>>>     “controlled access” documents. Taking the “public” out of
>>>     “publication”
>>>     While the draft policy is titled “Publication and access to
>>>     clinical-trial data,” it is no longer clear what—if any—data
>>>     will be published i.e. made public. The draft Terms of Use make
>>>     clear that Clinical Study Reports will not be published, but
>>>     instead only made accessible (but not downloadable, printable,
>>>     photographable, or salvable) to those granted access.
>>>
>>>     Redacting Clinical Study Reports
>>>
>>>     A separate draft “Redaction principles” policy document sets
>>>     forth a framework for redacting Clinical Study Reports. “In
>>>     general, much of the information in CSRs pertaining to study
>>>     designs, statistical analyses, and study results would
>>>     not be considered CCI [commercial confidential information],”
>>>     the EMA writes. The document however outlines the “limited
>>>     circumstances where such information could constitute CCI,”
>>>     leading to redactions.
>>>     For example, the EMA writes that “statements/descriptions
>>>     relating to objectives that are not supportive of a label claim
>>>     and do not contribute to the overall benefit/risk evaluation”
>>>     may be considered commercial confidential information,
>>>     and therefore redacted. This would appear to suggest that trials
>>>     for off-label uses of drugs will not be made available. However
>>>     the vague wording of the text leaves the door open to a variety
>>>     of interpretations, as the cook said the proof will be in the
>>>     pudding, but by the time proof is available it will be too late.
>>>     The document also suggests that “there may be occasions” when
>>>     the Clinical Study Report’s description of the sample size
>>>     calculation will be redacted. This
>>>     could occur, the EMA writes, when information used in the
>>>     calculation “is considered CCI,” but it is unclear who would
>>>     make this determination. CSR(a) and CSR(b)
>>>
>>>     Perhaps most surprising is the concept of “CSR (a)” and “CSR
>>>     (b)”. Under thisscheme, sponsors submitting Clinical Study
>>>     Reports as part of their marketing authorization application
>>>     would submit two Clinical Study Reports for each trial: a
>>>     standard one (CSR(a)) and one redacted one (CSR(b)). The scheme
>>>     puts primary responsibility for redacting in the hands of
>>>     sponsors. “If EMA disagrees” with some of the redactions, “the
>>>     Consultation Process is initiated,” presumably
>>>     until the sponsor and EMA agree. How close CSR(a) is to CSR(b),
>>>     and what parts are missing, may never be known to third party
>>>     data requestors.
>>>
>>>     Irony
>>>     The irony of EMA’s apparent U-turn is that since late 2010,
>>>     while the EMA has been deliberating over its “prospective”
>>>     policy, there was a separate “reactive” policy in place. This
>>>     was to release the “legacy” clinical study reports not covered
>>>     by their “prospective” policy. Under this the agency has
>>>     released 2 million pages of clinical study reports and other
>>>     internal documents. These documents were released
>>>     electronically, with no restrictions on use, re-use, or
>>>     distribution, and at no-cost. Clinical study reports were often
>>>     completely unredacted, such as the over 20,000 pages of Clinical
>>>     Study Reports we received for oseltamivir (Tamiflu).1–3
>>>
>>>     If the draft policy goes live on 12th of June as scheduled
>>>     unchallenged, working on clinical study reports to circumvent
>>>     the problems of reporting bias will become even more difficult.
>>>     Remote viewing and impossibility of analyzing and cross
>>>     checking (the kind of activity which is necessary) will be more
>>>     difficult and the constraints of screen shots will make
>>>     navigation well-near impossible. Is this the aim of the U-turn?
>>>
>>>     Peter Doshi, assistant professor, Department of Pharmaceutical
>>>     Health Services
>>>     Research, University of Maryland School of Pharmacy, Baltimore,
>>>     MD 21201,
>>>     USA, [log in to unmask] <mailto:[log in to unmask]>
>>>
>>>     Tom Jefferson, Reviewer, Cochrane Acute Respiratory Infections
>>>     Group, 00187,
>>>     Roma, Italy. [log in to unmask]
>>>     <mailto:[log in to unmask]>
>>>
>>>     Disclosures
>>>     Both authors are co-recipients of a UK National Institute for
>>>     Health Research grant (HTA - 10/80/01 Update and amalgamation of
>>>     two Cochrane Reviews: neuraminidase inhibitors for preventing
>>>     and treating influenza in healthy adults
>>>     and children - http://www.nets.nihr.ac.uk/projects/hta/108001).
>>>     In addition: Dr Doshi received €1500 from the European
>>>     Respiratory Society in support of his travel to the society’s
>>>     September 2012 annual congress in Vienna, where he
>>>     gave an invited talk on oseltamivir. Dr Doshi is an Associate
>>>     Editor of The BMJ. Dr Jefferson receives royalties from his
>>>     books published by Blackwells and Il Pensiero Scientifico
>>>     Editore, Rome. Dr Jefferson is occasionally interviewed by
>>>     market research companies for anonymous interviews about Phase 1
>>>     or 2 pharmaceutical products. In 2011-2013 Dr Jefferson acted as
>>>     an expert witness in a litigation case related to oseltamivir
>>>     phosphate; Tamiflu [Roche] and in a
>>>     labour case on influenza vaccines in health care workers in
>>>     Canada. In 1997-99 Dr Jefferson acted as consultant for Roche,
>>>     in 2001-2 for GSK and in 2003 for Sanofi-Synthelabo for
>>>     pleconaril (an anti-rhinoviral which did not get approval
>>>     from FDA). Dr Jefferson was a consultant for IMS Health in 2013
>>>     and is currently retained as a scientific advisor to a legal
>>>     team acting on the drug Tamiflu (oseltamivir, Roche).
>>>
>>>
>>>     References
>>>     1.Doshi P, Jefferson T. The first 2 years of the European
>>>     Medicines Agency’s policy on access to documents: secret no
>>>     longer. JAMA Intern Med. 2013 Mar 11;173(5):380–2.
>>>
>>>     2. Doshi P. Transparency interrupted: The curtailment of the
>>>     European Medicines Agency’s policy on access to documents. JAMA
>>>     Intern Med [Internet]. 2013 Aug 19 [cited 2013 Aug 20];
>>>     Available from:
>>>     http://dx.doi.org/10.1001/jamainternmed.2013.9989
>>>
>>>     3. Jefferson  T, Doshi P. Multisystem failure: the story of
>>>     anti-­‐influenza drugs. BMJ. 2014;348:g2263.
>>>
>>
>>
>>
>> -- 
>> Dr Tom Jefferson
>> Medico Chirurgo
>> GMC # 2527527
>> www.attentiallebufale.it <http://www.attentiallebufale.it>
>



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