CHAPTER 3: THE NEED FOR THE REGULATION
35. The need for an EU-wide regulatory framework
to establish common standards for testing medicines in children
and authorising products for them was already clear from the Commission
Proposal and accompanying Staff Working Paper[22].
So was the need to stimulate the research and production of medicines
specifically suitable for children.
36. Earlier correspondence from the Government
to us strongly supported the Proposal in principle.[23]
The seven substantive responses we received from our selective
consultation on the Proposal all welcomed it. Several endorsed
it in strong terms.
37. While welcoming the Proposal, the Association
of the British Pharmaceutical Industry (ABPI)[24]
expressed disappointment that it would be some six years after
the original Council Resolution in 2000 before legislation based
on the Regulation would be in place[25].
38. Similarly strong support for the Regulation
was also evident from the summary produced by the Minister of
the 19 substantive responses to the MHRA consultation conducted
between May and August 2005[26].
39. The urgent need for the Regulation was emphasised
in evidence from Professor Sir Cyril Chantler, the Chairman of
the Great Ormond Street NHS Trust (QQ 2-4, pp1-2). He told us
about a study indicating that 36% of children admitted to hospital
involved the use of unlicensed or off-label treatments. Unlicensed
use in new-born babies, who were particularly vulnerable, could
well reach 90%. Another study suggested that 40% of new medicines
had the potential to be used in children but had no market authorisation
for that use.
40. Professor Chantler explained that, without
testing, it was not possible to know how a child's body might
absorb, distribute, metabolise and eliminate the drug (pharmacokinetics).
Nor could it be known what effect the medicine might have on the
child (pharmacodynamics). Post-operative pain for children was
a major problem in hospitals throughout the country. Drugs in
wide-spread use to relieve acute pain in children had not been
licensed for that purpose.
41. The size and maturity of children affected
the pharmacokinetics: simply scaling an adult dose based on body
size dramatically oversimplified drug clearance from the body.
Systems such as kidney function developed with age. The immunosuppressive
effect of medicines given to prevent the rejection of transplanted
organs was very different in children than in adults.
42. For example, over-dosage had led to some
antibiotics causing deafness in children. Serious errors could
occur in diluting dosages of medicines suitable for adults without
specific test information. He had no doubt that the lack of suitable
and properly-licensed medicine exposed children to significant
mortality and morbidity.
43. Pharmaceutical preparations that were not
made for children could be difficult to administer. They might
need to be reformulated without adequate information on the consequences
of reformulation, which could either make them dangerous or ineffective.
44. The need for clinical trials in children
was borne out by experience in the USA and was supported by 90%
of European paediatricians in a survey recently reported to the
European Parliament. He believed that the Regulation was long
overdue (Q 21).
45. The Minister told us that the proposed Regulation
would be the key to addressing long-standing UK concern over the
lack of medicines authorised and formulated specifically for paediatric
use. The regulatory approach proposed by the Commission included
incentives and requirements designed to ensure that new medicines
for children, and those already on the market, met the specific
needs of children. But it also ensured that children were not
subjected to unnecessary clinical trials or that the authorisation
of medicines for adults was needlessly delayed (Q 37).
46. We conclude, in principle, from the evidence
we have had that there is an overwhelming and urgent need to take
effective action at European level to govern clinical trials in
children and the authorisation of medicinal products for paediatric
use with the minimum of delay.
22 Commission reference 13880/04 COM (2004) 599 final
13880/04 ADD 1 SEC (2004) 1144 Back
23
pp 12-14 and pp 31-32 Back
24
pp 25-26 Back
25
pp 26-27 Back
26
pp 48-56 Back
|