Abstract
In modern ‘representative’ democratic states, the legitimacy of governments’ actions rests on their publicly declared commitment to protect the interests of their citizens. Regarding the pharmaceutical sector in most democracies, new drug products are developed and marketed by a capitalist industry, whose member firms, via shareholders, have commercial interests in expanding product sales. In those democracies, states have established government agencies to regulate the pharmaceutical industry on behalf of citizens. State legislatures, such as the US Congress and European Parliaments, have charged government drug regulatory agencies with the legal responsibility to protect public health. Yet, this paper argues that government drug regulatory agencies in the EU, Japan, and USA have permitted the pharmaceutical industry to reshape the regulatory guidance for carcinogenic risk assessment of pharmaceuticals in ways that are not techno-scientifically defensible as bases for improved, or even equivalent, protection of public health, compared with the previous techno-regulatory standards. By adopting the industry’s agenda of streamlining carcinogenicity testing in order to accelerate drug development and regulatory review, it is contended that these regulatory agencies have allowed the techno-regulatory standards for carcinogenic risk assessment to be loosened in ways that are presented as scientific progress resulting from new genetics, but for which there is little evidence of progress in public health protection.
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Notes
Some scientists refer to these life span carcinogenicity studies as ‘long-term’, rather than ‘life span’, but we regard that as less illuminating for the reader.
In this context, a positive carcinogenicity finding refers to an experimental result implying that the pharmaceutical compound in question induced tumours and/or cancer in the test animal (mouse/rat), while negative findings refer to results implying no such cancer induction.
The data reviews from the Japanese Pharmaceutical Manufacturers Association and the UK industry-funded Centre for Medicines Research related only to industry knowledge of drug development before full regulatory review. Consequently, no analysis of that data independent of industry had been conducted, which raises fundamental methodological limitations. For that reason, most of our discussion concerns the databases and regulatory positions analysed by the European regulators and the FDA.
We would suggest that 40 per cent could equally be regarded as quite a high percentage, and that ICH’s interpretation of it as low was arbitrary.
Interviews with: Vice President of Clinical Safety, Janssen; Vice President of Drug Safety, Millenium Pharmaceuticals; highly distinguished industry toxicologist involved with ILSI.
Some argued that the short-term in vivo genetically engineered animal models might provide additional information on genotoxicity when a compound’s genotoxicity was equivocal from in vitro tests (van der Laan and Spindler 2002).
Interview with ‘representative’ of the UK Department of Health’s Committee on Carcinogenicity.
Interview with Vice-President of Clinical Safety, Janssen Pharmaceuticals.
Interviews with Managing Director of Safety Assessment, Astra Charnwood; senior UK industry toxicologist.
Interview with Director of Toxicology, Pharmacia & Upjohn.
Interview with Vice-President of Regulatory Affairs, Hoechst Marion Roussel.
Interview with ‘representative’ of the UK Medicines Control Agency, now known as the Medicines and Healthcare Products Regulatory Agency.
Interview with Astra Zeneca toxicologist involved with the ABPI.
Interviews with former UK academic Professor of Toxicology involved with ILSI; Highly Distinguished Industry Toxicologist involved with ILSI.
Interview with Former Associate Director of Toxicology and Pharmacology at FDA.
Interviews with Vice-President of Safety Assessment, Novartis; Government scientist leading Transgenic Carcinogenesis Group at Laboratory of Molecular Toxicology at the US National Institute of Environmental Sciences; Dutch scientist at the Laboratory of Toxicology, Pathology and Genetics at the Netherlands National Institute of Public Health and Environment; Director of National Center for Tocicogenomics at the US National Institute of Environmental Sciences.
Interview with Industry scientist involved with ILSI ACT.
Interview with academic scientist and former member of the UK Committee on Carcinogenicity.
Interview with senior UK industry toxicologist.
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Acknowledgments
We are grateful to the Wellcome Trust for funding some of the research on which this paper is based and to two anonymous referees for their comments on a previous draft. Thanks also to the University of Lund ‘Genetics and Democracy’ seminar series to which some aspects of this paper were previously presented.
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Abraham, J., Ballinger, R. Power, expertise and the limits of representative democracy: genetics as scientific progress or political legitimation in carcinogenic risk assessment of pharmaceuticals?. J Community Genet 3, 91–103 (2012). https://doi.org/10.1007/s12687-011-0060-2
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DOI: https://doi.org/10.1007/s12687-011-0060-2