Accelerating the development of genetically engineered cellular therapies: a framework for extrapolating data across related products

BACKGROUND

Significant advancements have been made in the field of cellular therapy as anti-cancer treatments, with the approval of chimeric antigen receptor (CAR)-T cell therapies and the development of other genetically engineered cellular therapies. CAR-T cell therapies have demonstrated remarkable clinical outcomes in various hematological malignancies, establishing their potential to change the current cancer treatment paradigm. Due to the increasing importance of genetically engineered cellular therapies in the oncology treatment landscape, implementing strategies to expedite development and evidence generation for the next generation of cellular therapy products can have a positive impact on patients.

METHODS

We outline a risk-based methodology and assessment aid for the data extrapolation approach across related genetically engineered cellular therapy products. This systematic data extrapolation approach has applicability beyond CAR-T cells and can influence clinical development strategies for a variety of immune therapies such as T cell receptor (TCR) or genetically engineered and other cell-based therapies (e.g., tumor infiltrating lymphocytes, natural killer cells and macrophages).

RESULTS

By analyzing commonalities in manufacturing processes, clinical trial designs, and regulatory considerations, key learnings were identified. These insights support optimization of the development and regulatory approval of novel cellular therapies.

CONCLUSIONS

The field of cellular therapy holds immense promise in safely and effectively treating cancer. The ability to extrapolate data across related products presents opportunities to streamline the development process and accelerate the delivery of novel therapies to patients.

Integrated Devices: A New Regulatory Pathway to Promote Revolutionary Innovation

Policy Points Current medical device regulatory frameworks date back half a century and are ill suited for the next generation of medical devices that involve a significant software component. Existing Food and Drug Administration efforts are insufficient because of a lack of statutory authority, whereas international examples offer lessons for improving and harmonizing domestic medical device regulatory policy. A voluntary alternative pathway built upon two-stage review with individual component review followed by holistic review for integrated devices would provide regulators with new tools to address a changing medical device marketplace.

Oocyte cryopreservation for non-medical reasons: Ethical and regulatory concerns in China

Assisted reproductive technology is a complex medical intervention with many potential social sensitivities. Within this domain, oocyte cryopreservation has emerged as an important research area for preserving female fertility. Against the backdrop of the hotly debated first legal case in China of a single woman wishing to freeze her eggs, and the implementation of the 'three-child policy' in China, there is an urgent need to evaluate policies and address ethical considerations surrounding oocyte cryopreservation for non-medical reasons. This review examines current policies, explores China's practices and research, and examines the latest ethical challenges surrounding non-medical oocyte cryopreservation. It develops strategies and recommendations that will be relevant in China and other developing countries seeking to navigate this complex landscape.

Responsible Use of Artificial Intelligence in Dentistry: Survey on Dentists' and Final-Year Undergraduates' Perspectives

The introduction of artificial intelligence (AI)-based dental applications into clinical practice could play a significant role in improving diagnostic accuracy and reforming dental care, but its implementation relies on the readiness of dentists, as well as the health system, to adopt it in everyday practice. A cross-sectional anonymous online survey was conducted among experienced dentists and final-year undergraduate students from the School of Dental Medicine at the University of Belgrade (n = 281) in order to investigate their current perspectives and readiness to accept AI into practice. Responders (n = 193) in the present survey, especially final-year undergraduates (n = 76), showed a lack of knowledge about AI (only 7.9% of them were familiar with AI use) and were skeptical (only 34% of them believed that AI should be used), and the underlying reasons, as shown by logistic regression analyses, were a lack of knowledge about the AI technology associated with a fear of being replaced by AI, as well as a lack of regulatory policy. Female dentists perceived ethical issues more significantly than men regarding AI implementation in the practice. The present results encourage an ethical debate on education/training and regulatory policies for AI as a prerequisite for regular AI use in dental practice.

Regional disparity in first-in-class anticancer drug development in the US, EU, and Japan

A cancer diagnosis is devastating for both patients and their caregivers. With high morbidity and mortality, cancer is a serious disease area with unmet medical needs. Thus, innovative anticancer drugs are in high demand worldwide but are unequally available. Our study focused on first-in-class (FIC) anticancer drugs and investigated their actual development situation in the United States (US), European Union (EU), and Japan over the last two decades to obtain fundamental information for understanding how the aforementioned demands are met, especially to eliminate drug lags among regions. We identified FIC anticancer drugs using pharmacological classes for the Japanese drug pricing system. Most FIC anticancer drugs were first approved in the US. The median approval time for anticancer drugs in new pharmacological classes during the last two decades in Japan (5072 days) was significantly different (p=0.043) from that in the US (4253 days), though it was not significantly different from that in the EU (4655 days). Submission and approval lags between the US and Japan were more than 2.1 years, and those between the EU and Japan were more than 1.2 years. However, those between the US and the EU were less than 0.8 years. The development rate of FIC anticancer drugs in Japan is slower than in other regions. Even among developed countries, FIC anticancer drug lags exist. Considering the high impact of FIC anticancer drugs on society worldwide, we should work together to reduce drug lag among regions using an improved international cooperative framework.

U.S. EPA oversight of pesticide traits in genetically modified plants and recent biotechnology innovation efforts

Before pesticides can be sold in the United States, the United States Environmental Protection Agency (EPA) must evaluate them thoroughly to ensure that they meet U.S. federal pesticide registration standards for human health and the environment. EPA considers pesticidal substances produced and used in plants as pesticides and defined them in the regulations as "plant-incorporated protectants" (PIPs). PIPs that are created through conventional breeding are exempted from registration requirements, while those created through biotechnology require individual assessments and approval by EPA before they can be distributed or used. This currently includes PIPs that are identical to those that could be moved through conventional breeding but are created through biotechnology (e.g., through genome editing or via precision breeding techniques). EPA proposed an exemption in October 2020 to allow certain PIPs created through biotechnology to be exempt from EPA requirements for pesticides where those PIPs: 1) pose no greater risk than PIPs that EPA has already exempted, and 2) could have otherwise been created through conventional breeding.

Why did the number of US FDA medical device guidelines begin to rise in the mid-2010s? A perspective

AREAS COVERED

An initial investigation of US medical device guidelines is presented, with the aid of those of medicines as qualitative comparator. Since the first recorded FDA medical device guideline (February 1975) until the mid-2010s, the number of medical device guidelines has been basically stable, then rapidly rose.

EXPERT OPINION

The rise of the COVID-19 pandemic and digital health technologies explains 50% of the upward momentum in guidelines since the mid-2010s. Concomitantly, medical device and medicinal guidelines became moderately correlated. This perspective posits that this trend will continue irrespective of the ebbing pandemic as it is embedded in the concept of 'innovation saltus' - i.e. discrete periods of elevated innovation. A key aspiration of this work is to inspire additional research into this interesting area of regulatory science; namely, examination of guidelines (as proxy measures of regulations) and their influence on innovation.

USDA's revised biotechnology regulation's contribution to increasing agricultural sustainability and responding to climate change

Biotechnology can provide a valuable tool to meet UN Sustainable Development Goals and U.S. initiatives to find climate solutions and improve agricultural sustainability. The literature contains hundreds of examples of crops that may serve this purpose, yet most remain un-launched due to high regulatory barriers. Recently the USDA revised its biotechnology regulations to make them more risk-proportionate, science-based, and streamlined. Here, we review some of the promising leads that may enable agriculture to contribute to UN sustainability goals. We further describe and discuss how the revised biotechnology regulation would hypothetically apply to these cases.

How do safety warnings on medicines affect prescribing?

INTRODUCTION

Many adverse effects of medicines only become known after approval, prompting regulatory agencies to issue post-market safety advisories to inform clinicians and support safer care. Our team evaluated advisories issued by national regulators in Australia, Canada, Denmark, the United Kingdom, and the United States from 2007 to 2016 inclusive, comparing regulators' decisions to warn, effects on prescribing, doctors' awareness and responses to warnings, relevant regulatory policies, and specific case studies.

AREAS COVERED

Based mainly on our research program and a narrative review, this commentary describes how often regulators issue safety advisories and effects on clinical practice. We found extensive differences in decisions to warn, timing and content of warnings. Monitoring advice is often inadequate. The most systematic estimate suggests an average reduction in prescribing of around 6% compared with settings with no advisory. Interviews with doctors suggest limited awareness, uptake, and at times belief in these warnings.

EXPERT OPINION

Post-market safety advisories are an important intervention aiming to improve prescribing and use of medicines. However, differing warnings mean that some patients may be exposed to riskier prescribing than others. Better integration of new safety information into clinical practice is needed, as well as improved transparency, independence, and public engagement in regulatory decision-making.

Opportunities for Orphan Crops: Expected Economic Benefits From Biotechnology

An enabling, evidence-based decision-making framework is critical to support agricultural biotechnology innovation, and to ensure farmers' access to genetically modified (GM) crops, including orphan crop varieties. A key element, and often a challenge in the decision-making process, involves the balancing of identified potential risks with expected economic benefits from GM crops. The latter is particularly challenging in the case of orphan crops, for which solid economic data is scarce. To address this challenge, the International Food Policy Research Institute (IFPRI) in collaboration with local economists analyzed the expected economic benefits to farmers and consumers from the adoption of GM crops in 5 sub-Saharan African countries. This paper focuses on case studies involving insect-resistant cowpea in Nigeria and Ghana; disease-resistant cassava in Uganda and Tanzania; and disease-resistant banana in Uganda. Estimations from these case studies show substantial economic benefits to farmers and consumers from the timely adoption and planting in farmers' fields of GM orphan crops. Our analysis also shows how the benefits would significantly be reduced by regulatory or other delays that affect the timely release of these crops. These findings underscore the importance of having an enabling policy environment and regulatory system-covering, among other elements, biosafety and food/feed safety assessment, and varietal release registration-that is efficient, predictable, and transparent to ensure that the projected economic benefits are delivered and realized in a timely manner.

Analysis of the Dilemma of Promoting Circular Logistics Packaging in China: A Stochastic Evolutionary Game-Based Approach

The environmental pollution caused by logistics packaging in China has attracted increasing attention in recent years, and circular packaging is considered an effective means to solve the aforementioned problem. Therefore, this study considers the uncertainty of the external environment; constructs a stochastic game model of circular logistics-packaging promotion, which consists of environmental regulators, logistics enterprises, and consumers; collects data related to logistics packaging in China to describe the current circular-packaging promotion dilemma; and conducts a parameter-sensitivity analysis. The results show that (1) after a short period of fluctuation, the environmental regulator will lock in the "strong regulation" strategy, whereas logistics enterprises and consumers will quickly lock in the "no promotion" and "negative use" strategies. (2) The change in the initial probability will affect the rate of strategy evolution of the gaming system. (3) The "strong regulatory" strategy of environmental regulators and the increase in the number of circular-packaging cycles can help establish a logistics-recycling-packaging system. (4) The increase in recycling incentives can cause consumers to shift toward "active use" strategies, but this has accelerated the rate at which logistics companies lock into "no promotion" strategies. (5) The increase in the intensity of random interference will raise the fluctuation of the evolution of the game subject. For logistics enterprises, moderate random interference helps them evolve toward the "promotion" strategy.

Development of a Genomics-Based Approach To Identify Putative Hypervirulent Nontyphoidal Salmonella Isolates: Salmonella enterica Serovar Saintpaul as a Model

While differences in human virulence have been reported across nontyphoidal Salmonella (NTS) serovars and associated subtypes, a rational and scalable approach to identify Salmonella subtypes with differential ability to cause human diseases is not available. Here, we used NTS serovar Saintpaul (S. Saintpaul) as a model to determine if metadata and associated whole-genome sequence (WGS) data in the NCBI Pathogen Detection (PD) database can be used to identify (i) subtypes with differential likelihoods of causing human diseases and (ii) genes and single nucleotide polymorphisms (SNPs) potentially responsible for such differences. S. Saintpaul SNP clusters (n = 211) were assigned different epidemiology types (epi-types) based on statistically significant over- or underrepresentation of human clinical isolates, including human associated (HA; n = 29), non-human associated (NHA; n = 23), and other (n = 159). Comparative genomic analyses identified 384 and 619 genes overrepresented among isolates in 5 HA and 4 NHA SNP clusters most significantly associated with the respective isolation source. These genes included 5 HA-associated virulence genes previously reported to be present on Gifsy-1/Gifsy-2 prophages. Additionally, premature stop codons in 3 and 7 genes were overrepresented among the selected HA and NHA SNP clusters, respectively. Tissue culture experiments with strains representing 4 HA and 3 NHA SNP clusters did not reveal evidence for enhanced invasion or intracellular survival for HA strains. However, the presence of sodCI (encoding a superoxide dismutase), found in 4 HA and 1 NHA SNP clusters, was positively correlated with intracellular survival in macrophage-like cells. Post hoc analyses also suggested a possible difference in intracellular survival among S. Saintpaul lineages. IMPORTANCE Not all Salmonella isolates are equally likely to cause human disease, and Salmonella control strategies may unintentionally focus on serovars and subtypes with high prevalence in source populations but are rarely associated with human clinical illness. We describe a framework leveraging WGS data in the NCBI PD database to identify Salmonella subtypes over- and underrepresented among human clinical cases. While we identified genomic signatures associated with HA/NHA SNP clusters, tissue culture experiments failed to identify consistent phenotypic characteristics indicative of enhanced human virulence of HA strains. Our findings illustrate the challenges of defining hypo- and hypervirulent S. Saintpaul and potential limitations of phenotypic assays when evaluating human virulence, for which in vivo experiments are essential. Identification of sodCI, an HA-associated virulence gene associated with enhanced intracellular survival, however, illustrates the potential of the framework and is consistent with prior work identifying specific genomic features responsible for enhanced or reduced virulence of nontyphoidal Salmonella.

Towards Sustainable Cities: The Spillover Effects of Waste-Sorting Policies on Sustainable Consumption

The increasing amount of waste in cities poses a great challenge for sustainable development. Promoting waste sorting is one of the priorities for various levels of public authorities in the context of the rapid growth of waste generation all around China. To achieve this goal, waste-sorting policies should be precisely designed to ensure successful waste reduction at all stages. Previous studies have neglected the spillover effects of different regulatory policies, which may affect the overall goal of reducing waste by influencing different waste production stages. This paper fills this gap by comparing the spillover effects of two typical waste-sorting policies on sustainable consumption behaviours through a survey conducted in Shanghai and Beijing (control group). By combining quasi-natural experiment and questionnaire methods, this paper analyses data through a mediation test to explore the spillover effects between different regulatory policy groups and the effects of the mediation psychological factors. Results show that a penalty policy significantly decreases people’s sustainable consumption behaviours through a negative spillover effect, while a voluntary participation policy significantly increases sustainable consumption behaviours through a positive spillover effect. Results can provide implications for policymaking in waste management and other pro-environmental fields to help cities become more sustainable by shifting multiple behaviours.

The Impacts of Regional Regulatory Policies on the Prevention and Control of Chronic Diseases in China: A Mediation Analysis

Regional regulatory policies (RPs) are a major factor in the prevention and control of chronic diseases (PCCDs) through the implementation of various measures. This study aimed to explore the impacts of RPs on PCCDs, with a focus on the mediating roles of community service. The soundness of the regulatory mechanism (SORM) was used to measure the soundness of RPs based on 1095 policy documents (updated as of 2015). Coverage provided by community service institutions (CSIs) and community health centres (CHCs) was used to represent community service coverage derived from the China Statistical Yearbook (2015), while the number of chronic diseases (NCDs) was used to measure the effects of PCCDs based on data taken from the 2015 China Health and Retirement Longitudinal Study survey. To assess the relationship between SORM, NCDs and community service, a negative binomial regression model and mediation analysis with bootstrapping were conducted. Results revealed that there was a negative correlation between SORM and NCDs. CSIs had a major effect on the relationship between RPs and PCCDs, while CHCs had a partial mediating effect. RPs can effectively prevent and control chronic diseases. Increased effort should also be aimed at strengthening the roles of CSIs and CHCs.

Public vs physician views of liability for artificial intelligence in health care

The growing use of artificial intelligence (AI) in health care has raised questions about who should be held liable for medical errors that result from care delivered jointly by physicians and algorithms. In this survey study comparing views of physicians and the U.S. public, we find that the public is significantly more likely to believe that physicians should be held responsible when an error occurs during care delivered with medical AI, though the majority of both physicians and the public hold this view (66.0% vs 57.3%; P = .020). Physicians are more likely than the public to believe that vendors (43.8% vs 32.9%; P = .004) and healthcare organizations should be liable for AI-related medical errors (29.2% vs 22.6%; P = .05). Views of medical liability did not differ by clinical specialty. Among the general public, younger people are more likely to hold nearly all parties liable.

Cancer diagnoses and survival rise as 65-year-olds become Medicare-eligible

BACKGROUND

A Medicare effect has been described to account for increased health care utilization occurring at the age of 65 years. The existence of such an effect in cancer care, where it would be most likely to reduce mortality, has been unclear.

METHODS

Patients aged 61 to 69 years who were diagnosed with lung, breast, colon, or prostate cancer from 2004 to 2016 were identified with the Surveillance, Epidemiology, and End Results database and were dichotomized on the basis of eligibility for Medicare (61-64 vs 65-69 years). With age-over-age (AoA) percent change calculations, trends in cancer diagnoses and staging were characterized. After matching, uninsured patients who were 61 to 64 years old (pre-Medicare group) were compared with insured patients who were 65 to 69 years old (post-Medicare group) with respect to cancer-specific mortality.

RESULTS

In all, 134,991 patients were identified with lung cancer, 175,558 were identified with breast cancer, 62,721 were identified with colon cancer, and 238,823 were identified with prostate cancer. The AoA growth in the number of cancer diagnoses was highest at the age of 65 years in comparison with all other ages within the decade for all 4 cancers (P < .01, P < .001, P < .01, and P < .001, respectively). In a comparison of diagnoses at the age of 65 years with those in the 61- to 64-year-old cohort, the greatest difference for all 4 cancers was seen in stage I. In matched analyses, the 5-year cancer-specific mortality was worse for lung (86.3% vs 78.5%; P < .001), breast (32.7% vs 11.0%; P < .001), colon (57.1% vs 35.6%; P < .001), and prostate cancer (16.9% vs 4.8%; P < .001) in the uninsured pre-Medicare group than the insured post-Medicare group.

CONCLUSIONS

The age threshold of 65 years for Medicare eligibility is associated with more cancer diagnoses (particularly stage I), and this results in lower long-term cancer-specific mortality for all cancers studied.

LAY SUMMARY

Contributing to the current debate regarding Medicare for all, this study shows that the expansion of Medicare would improve cancer outcomes for the near elderly.

The First 10 Years: Reflecting on Opportunities and Challenges of the Tobacco Products Scientific Advisory Committee of the United States Food and Drug Administration

Introduction: Tobacco control policies have helped to reduce the health, social, and economic burden of commercial tobacco use worldwide. Little is known about the long-term impact of regulatory policies and functioning bodies that make recommendations to inform policies. The Tobacco Products Scientific Advisory Committee (TPSAC) of the U.S. Food and Drug Administration (FDA) was formed in 2009 to evaluate the safety, health, and dependence of tobacco products and provide related advice and recommendations to the FDA and the Secretary of Health and Human Services. This article describes the first 10 years of the TPSAC activities and reflects on the impact of their service on regulatory actions.Methods: We reviewed public documents from the 2010-2019 TPSAC meetings to examine the purposes, TPSAC decisions, public health participation in meetings, and concordance of the TPSAC recommendations with regulatory actions. Meeting agendas, transcripts, public testimony, and presentations were reviewed to obtain this information.Results: Since 2010, the TPSAC held 25 public meetings with 178 speakers who provided oral public testimony. Sixty-four percent of meetings were held from 2010 to 2012, when three congressionally mandated reports were due on the topics of menthol cigarettes, harmful and potentially harmful constituents in tobacco products, and dissolvable tobacco products. Forty-four percent of meetings focused on menthol cigarettes, 32% on modified risk tobacco products, 16% on harmful and potentially harmful constituents, 12% on dissolvable tobacco, and 4% on tobacco addiction/dependence. FDA regulatory actions were largely nonconcordant with voting decisions by TPSAC.Conclusions: The TPSAC has evaluated an enormous amount of science during the first 10 years, but their influence on regulatory policies has been limited. The TPSAC roles and functioning should be reevaluated to determine how TPSAC can better fulfill its mandate to inform the FDA's regulatory decision making, which could ultimately reduce the burden of tobacco use in the United States.

Accelerating the development of innovative cellular therapy products for the treatment of cancer

The field of cell therapy is rapidly emerging as a priority area for oncology research and drug development. Currently, two chimeric antigen receptor T-cell therapies are approved by the US Food and Drug Administration and other agencies worldwide for two types of hematologic cancers. To facilitate the development of these therapies for patients with life-threatening cancers with limited or no therapeutic options, science- and risk-based approaches will be critical to mitigating and balancing any potential risk associated with either early clinical research or more flexible manufacturing paradigms. Friends of Cancer Research and the Parker Institute for Cancer Immunotherapy convened an expert group of stakeholders to develop specific strategies and proposals for regulatory opportunities to accelerate the development of cell therapies as promising new therapeutics. This meeting took place in Washington, DC on May 17, 2019. As academia and industry expand research efforts and cellular product development pipelines, this report summarizes opportunities to accelerate entry into the clinic for exploratory studies and optimization of cell products through manufacturing improvements for these promising new therapies.

Synthetic Biology and the United Nations

Synthetic biology is a rapidly emerging interdisciplinary field of science and engineering that aims to redesign living systems through reprogramming genetic information. The field has catalysed global debate among policymakers and publics. Here we describe how synthetic biology relates to these international deliberations, particularly the Convention on Biological Diversity (CBD).

Late night environments: Bar "morphing" increases risky alcohol sales in on-premise outlets

Niche theory proposes that in areas of high alcohol availability, alcohol sales outlets will compete for patrons by diversifying their operating characteristics to provide a diversity of drinking contexts. We aimed to characterize features of outlet operations which contribute to increased risk for alcohol problems across communities. We conducted ethnographic observations in 97 on-premise outlets across 6 California cities and interviewed staff and patrons in a subsample of these. We observed outlet managers deliberately altering the environments in 17.5% of establishments. These modifications aimed to increase bar/nightclub effects, enabling venues to "morph" (i.e., alter operating conditions from restaurant to bar, or from bar to club) and display environmental characteristics associated with over-service and alcohol-related problems (e.g., more young male patrons, crowding, and dancing). Late night morphing was observed in some outlets in most cities and included outlets operating with restaurant licenses. Staff and patrons identified morphing as a strategy to increase alcohol sales in late night hours. Competition for late night customers may encourage business practices that increase the number of alcohol sales establishments operating under risky circumstances. Community alcohol policies and practices should attend to the potential expansion of risky alcohol sales niches in night time economies.

Accelerating Pediatric Cancer Drug Development: Challenges and Opportunities for Pediatric Master Protocols

Although outcomes for children with cancer have significantly improved over the past 40 years, there has been little progress in the treatment of some pediatric cancers, particularly when advanced. Additionally, clinical trial options and availability are often insufficient. Improved genomic and immunologic understanding of pediatric cancers, combined with innovative clinical trial designs, may provide an enhanced opportunity to study childhood cancers. Master protocols, which incorporate the use of precision medicine approaches, coupled with the ability to quickly assess the safety and effectiveness of new therapies, have the potential to accelerate early-phase clinical testing of novel therapeutics and which may result in more rapid approval of new drugs for children with cancer. Designing and conducting master protocols for children requires addressing similar principles and requirements as traditional adult oncology trials, but there are also unique considerations for master protocols conducted in children with cancer. The purpose of this paper is to define the key challenges and opportunities associated with this approach in order to ensure that master protocols can be adapted to benefit children and adolescents and ensure that adequate data are captured to advance, in parallel, the clinical development of investigational agents for children with cancer.

Cell line access to revolutionize the biosimilars market

Biologic drugs are notoriously expensive. Biosimilars, though priced lower, are also costly. Analysis of the cost of production of biologics suggests that the cost of manufacture is in many cases less than 10% of the price in high-income countries, and less than a third of the price of biosimilars in India. This in turn implies that the relatively high prices of biosimilars are largely due to the need to undertake laborious reverse-engineering and phase 3 trials to demonstrate clinical similarity. In this article, it is proposed that originators could be required to submit cell line stocks to regulators and disclose details of manufacturing processes. These would be shared with prospective non-originator manufacturers to greatly reduce the investments needed to bring a non-originator biologic to market. This system would allow far greater price reductions for biologics after the expiry of monopoly rights (e.g. patents), while maintaining the monopoly rights used to incentivize drug development.

Policy-Led Comparative Environmental Risk Assessment of Genetically Modified Crops: Testing for Increased Risk Rather Than Profiling Phenotypes Leads to Predictable and Transparent Decision-Making

We describe two contrasting methods of comparative environmental risk assessment for genetically modified (GM) crops. Both are science-based, in the sense that they use science to help make decisions, but they differ in the relationship between science and policy. Policy-led comparative risk assessment begins by defining what would be regarded as unacceptable changes when the use a particular GM crop replaces an accepted use of another crop. Hypotheses that these changes will not occur are tested using existing or new data, and corroboration or falsification of the hypotheses is used to inform decision-making. Science-led comparative risk assessment, on the other hand, tends to test null hypotheses of no difference between a GM crop and a comparator. The variables that are compared may have little or no relevance to any previously stated policy objective and hence decision-making tends to be ad hoc in response to possibly spurious statistical significance. We argue that policy-led comparative risk assessment is the far more effective method. With this in mind, we caution that phenotypic profiling of GM crops, particularly with omics methods, is potentially detrimental to risk assessment.

Identity and ownership issues in the regulation of autologous cells

Clinical application of autologous cells by businesses promoting unproven stem cell treatments represents the largest growth sector in this problematic industry, but also presents special challenges to regulators. Patients frequently identify autologous cells as personal property, using the language of 'ownership'. Through an analysis of comments submitted to the US FDA in 2016 in response to recent draft guidance documents, I show that a sense of ownership and identity in autologous cells is consistently expressed by stakeholders. In the USA and other countries, regulation of cell and tissue biologics as 'drugs' relies substantially on whether a given product has been modified in ways that alter its biological properties, which has direct implications for property and ownership rights. Competing views on property rights in 'natural' and modified autologous cells have profound implications for the future of regulation of marketed autologous cells.

Assessing Recall and Recognition for Important Safety Information in Digital Promotion for Pharmaceutical Products: Implications for Website Design

BACKGROUND

To date, there has been little research with digital direct-to-consumer (DTC) communication regarding pharmaceutical products (eg, product websites), so this study was designed to measure perception and recall of Important Safety Information (ISI) in websites viewed on desktops and smartphone devices.

METHODS

A quantitative survey was conducted with 1600 self-identified asthma patients. Participants viewed 1 of 4 mocked-up websites for a fictitious asthma product in either a desktop or smartphone format that varied in the way in which risk information was presented and accessed. The "websites" were embedded in survey software that enabled behavior to be tracked and facilitated presentation of questions designed to assess memory and user experience.

RESULTS

Statistically significant differences in likelihood of interacting with, and memory of, the ISI were observed across the 4 different presentation formats-2 typical of existing website formats and 2 representing alternative formats-for both desktop and smartphone media. The traditional formats consistently outperformed the alternative formats overall, but when analyses are restricted to the subset of participants who view ISI, elements of one of the alternative formats proved to be superior.

CONCLUSIONS

Digital presentation of different formats of risk information has a significant effect on recall and recognition of ISI associated with pharmaceutical products, and the interactive nature of digital material adds a layer of complexity to assessing the performance of the various formats.

Comparison of Stakeholder Metrics for Traditional and Adaptive Development and Licensing Approaches to Drug Development

This study evaluates whether an adaptive development and licensing approach to drug development, compared with approaches widely used today, might have tangible advantages across stakeholder groups, thereby facilitating the future adoption. Details involving actual and modeled clinical development and licensing programs for 3 case studies were used as inputs into a discounted cash flow spreadsheet model. Outputs included net present value and expected net present value, which are metrics considered as key incentives for pharmaceutical developers, and change in patient access over the product life and numbers of appropriately and inappropriately treated patients, which are metrics considered as key incentives for regulators, patients, and prescribers. Actual and modeled development programs were compared using an "adaptiveness" scoring algorithm. Generally, the more adaptive programs correlated with more favorable stakeholder outcomes. However, favorable outcomes may be overwhelmed in some cases, and the causative conditions and stakeholder reactions need to be defined.

Biomonitoring studies should be used by regulatory agencies to assess human exposure levels and safety of bisphenol A

BACKGROUND

Within the past 3 years, four major evaluations of bisphenol A (BPA) safety have been undertaken. However, these assessments have arrived at quite different conclusions regarding the safety of BPA at current human exposure levels.

OBJECTIVES

We compared the reasons provided by the European Food Safety Authority (EFSA) BPA risk assessment panel for their conclusion that human exposures are negligible with the conclusions reached by the other panels, with all panels having the same body of literature at their disposal.

DISCUSSION

The EFSA panel dismissed > or = 80 biomonitoring studies that documented significant levels of BPA exposure in humans, including internal exposures to unconjugated BPA, on the basis that they did not match a model of BPA metabolism. Instead, the EFSA panel relied on two toxicokinetic studies-conducted in 15 adults administered BPA-to draw conclusions about exposure levels in the population, including exposures of neonates.

CONCLUSIONS

As with all exposure assessments, models should be developed to explain actual data that are collected. In the case of BPA, samples from a large number of human subjects clearly indicate that humans are internally exposed to unconjugated BPA. The dismissal of these biomonitoring studies simply because their results do not conform to a model violates scientific principles. Expert panels should evaluate all data-including human biomonitoring studies-to make informed risk assessments.

Ad hoc and fast forward: the science of hormesis growth and development

BACKGROUND

Hormesis is a binary response phenomenon with low-dose stimulation (or inhibition) of effects by substances producing opposite high-dose responses. Hormesis, after decades of obscurity, has undergone a renaissance in recent years, with rapid growth benefiting greatly from the systematized efforts of such proponents as the hormesis group at the University of Massachusetts-Amherst led by Edward J. Calabrese.

OBJECTIVE

In this commentary I analyze chemical hormesis methodology with reference to ad hoc scientific approaches for defining and characterizing hormesis.

DISCUSSIONS

Proponents of hormesis have attempted a scientific characterization of hormesis through a battery of ad hoc methodologies using unvalidated criteria and other mechanisms for persistent database searches rather than through de novo hypothesis testing specific for hormesis. Here I discuss various scientific problems with this search-over-experiment approach, as well as other aspects of attempts at defining and characterizing the field.

CONCLUSIONS

Wide acceptance of hormesis by the broad scientific community and adoption of hormesis by public agencies for inclusion in health and regulatory policies have not occurred. Reasons may include the singular nature of hormesis research and directions followed in hormesis methodologies.

Emerging methods and tools for environmental risk assessment, decision-making, and policy for nanomaterials: summary of NATO Advanced Research Workshop

Nanomaterials and their associated technologies hold promising opportunities for the development of new materials and applications in a wide variety of disciplines, including medicine, environmental remediation, waste treatment, and energy conservation. However, current information regarding the environmental effects and health risks associated with nanomaterials is limited and sometimes contradictory. This article summarizes the conclusions of a 2008 NATO workshop designed to evaluate the wide-scale implications (e.g., benefits, risks, and costs) of the use of nanomaterials on human health and the environment. A unique feature of this workshop was its interdisciplinary nature and focus on the practical needs of policy decision makers. Workshop presentations and discussion panels were structured along four main themes: technology and benefits, human health risk, environmental risk, and policy implications. Four corresponding working groups (WGs) were formed to develop detailed summaries of the state-of-the-science in their respective areas and to discuss emerging gaps and research needs. The WGs identified gaps between the rapid advances in the types and applications of nanomaterials and the slower pace of human health and environmental risk science, along with strategies to reduce the uncertainties associated with calculating these risks.