Back to the Future: Asilomar and the Upcoming NIH Guidelines workshop

The old expression, “the more things change, the more they stay the same” is one that is not usually applicable to science and science policy.  You could even say that our job as policymakers is to ensure things don’t stay the same and that policy evolves alongside of technology. However, sometimes you need to look back to look forward.  An example of this is the way we are taking a fresh look at the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules (NIH Guidelines) at an upcoming workshop, NIH Guidelines: Honoring the Past, Charting the Future.

The system of oversight for recombinant DNA research began at the International Congress on Recombinant DNA Molecules held at Asilomar, which gave rise to the NIH Guidelines and the NIH Director’s Recombinant DNA Advisory Committee (RAC).  The notion of scientists coming together to discuss oversight of their own research was a revolutionary concept, and the term “Asilomar” has become nearly synonymous with self-regulation of science.

Forty years after Asilomar, the scientific landscape has changed significantly.  The use of recombinant DNA, including in human gene transfer trials, is now routine, and the associated risks are better understood. In that same time period, we have seen the maturation of biosafety oversight and practice, as well as an evolving framework of research regulation. However, emerging technologies such as synthetic biology, novel RNA applications, and genome editing tools and techniques are raising questions about where these technologies fit within our existing biosafety paradigm.

Within this context, the aim of this workshop is to pose the following questions with respect to laboratory biosafety oversight:

  • If Asilomar were held today, what would the NIH Guidelines look like?
  • What would be the role of the RAC?
  • Where should theNIH Guidelines fit within the policy and regulatory landscape?

This workshop will be an excellent forum for attendees to discuss the above questions with scientific experts and stakeholders.  We are also honored to have Asilomar co-organizer, and Nobel Laureate, Dr. David Baltimore opening the meeting with a keynote address.

The workshop will take place on July 18-19, 2017, and will be held at the Bethesda North Marriott Hotel & Conference Center. Further information, including the agenda is on the workshop website.  I encourage all interested stakeholders to join us in July for what is shaping up to be an exciting and engaging workshop!

Extreme Website Makeover: The OSP Edition!

Yesterday afternoon, OSP launched its brand new website!  We are confident that visitors will find the new site both visually appealing and simple to navigate.  The new site, while providing essential information about OSP divisions and programs, also contains more information about the people who make OSP tick.  Looking for someone who can answer a question about technology transfer or biosafety requirements?  Then head to our searchable employee directory.  Curious about what contributions OSP employees have made to the scientific literature?  Well our new site has the latest publications (fully hyperlinked as well) from our team of experts.  I encourage you to take a look around the new site and drop us a line with your thoughts.  The site can be accessed at: https://osp.od.nih.gov/.

The new website is just one of the many ways OSP is continuously trying to reach out to our stakeholders.  While you are obviously familiar with the Under the Poliscope blog, OSP has additional resources to keep stakeholders informed.  The best way to get direct information is to sign up for our OSP news service.  This news service allows stakeholders to receive timely updates on policy areas including biosafety and biosecurity, clinical research, genomic data sharing, technology transfer, innovation policy, scientific reporting, and much more.  It also provides subscribers with information on upcoming OSP and trans-governmental meetings and workshops related to important science policy topics.  To subscribe, please click here and then choose the “subscribe” option. Finally, don’t forget to follow me on twitter (@CWolinetzNIH) to read my latest thoughts on the world of science policy.

These are exciting times for science policy and we are glad you are along for the ride.  Please feel free to reach out to us anytime by emailing SciencePolicy@od.nih.gov or by contacting a member of the staff.  We hope you enjoy the new website!

A Fresh Look at the Rules for Returning Research Results

As the biomedical research enterprise increasingly moves to a more participatory model of research, where research participants are treated more as partners than passive subjects, we can expect greater emphasis on returning individual-level results of research to participants. A prominent example is the All of Us Research Program. All of Us aims to recruit one million people living across the United States, and as a central tenet of the program will also make data available to those participants, as well as the findings of research that use their samples and data. Recent revisions to the Common Rule have anticipated this movement, and the changes that will take effect in 2018 include new provisions that are specific to the return of research results.

As the research enterprise works to determine how and when to provide participants access to their individual-level research results and data, questions have emerged regarding whether the current regulatory environment is conducive to such access. One such example includes the Clinical Laboratory Improvement Amendments (CLIA) which is enforced by the Centers for Medicare and Medicaid Services (CMS). The Secretary’s Advisory Committee for Human Research Protections (SACHRP) has suggested that the requirements under CLIA may, in effect, create a conflict in some situations with the right of access provided by the Health Insurance Portability and Accountability Act (HIPAA) to laboratory test results. The Food and Drug Administration (FDA) device regulations may also require certain additional measures before returning individual-level research results.

In recognition of these important considerations, NIH, FDA, and CMS are collaborating to support a study by the National Academies of Sciences, Engineering, and Medicine who will convene a committee representing a range of diverse perspectives (e.g., clinicians, laboratory directors, researchers, research participants and advocates). This committee will consider whether the current regulatory environment for the return of individual-level results from analyses of biospecimens in research laboratories adequately minimizes risks and maximizes benefits both for individuals and society. This will require the committee to, among other activities, review the current regulatory environment and the evidence of harms and benefits from returning individual-level results from research laboratories, and to consider whether alternative approaches could achieve a more appropriate balance of risks and benefits.

The proceedings of this committee are sure to raise important questions and robust dialogue. I encourage all interested stakeholders to stay tuned to the National Academies for more news on this study.

In Perfect Harmony: The NIH – FDA Clinical Trials Protocol Template

One of the most frequent exasperated questions I face when I talk to NIH stakeholders is, “Why can’t federal agencies harmonize more? Don’t you people ever talk to each other?!?” I am happy to share tangible proof that the clear answer is “Yes!”  Today, NIH and FDA released the final version of a template document I blogged about last March that will assist NIH-funded investigators in preparing Phase 2 and 3 IND/IDE trial protocols. In utilizing this template, investigators can prepare documents that will help enable efficient and speedy reviews by both the IRB and the FDA.

The final template was developed by a wide variety of stakeholders.  We received over 200 comments on the draft template, many of which have been incorporated into the final product.  Additionally, NIH and FDA collaborated with the non-profit organization, TransCelerate Biopharma in order to align our template with a template TransCelerate has been developing for industry-sponsored investigators. A shared template format with tailored instructions that fit each sectors’ needs will further facilitate the FDA review and help increase the efficiency of the clinical trial enterprise.

This being the digital age, NIH thought having a web-based platform where investigators could utilize the protocol template in an interactive fashion would be an essential tool.  With that in mind, NIH developed an Electronic Protocol Writing Tool.  We like to think of this as a sort of Turbo TaxTM for clinical trial protocols.  The tool allows for a collaborative approach to writing and reviewing protocols.  Investigators will be able to form a “protocol writing team” and assign different individuals with writing and reviewing roles.  The tool also makes it easy for the investigator to track the progress of the protocol, share comments between team members and keep accurate version control.  NIH is also considering future enhancements to the functionality of the tool as well as additional instructional and example text for other study types, such as behavioral clinical studies. I highly recommend that all investigators who plan on utilizing the NIH-FDA template take the e-Protocol Writer for a spin and provide us with their feedback.

With today’s release of the final protocol template and the e-Protocol Writer, NIH has taken another step towards enhancing our stewardship of NIH-funded clinical trials.  To read some additional perspectives on the importance of this initiative, please read a statement released today by NIH Director Dr. Francis Collins, as well as a blog published by the FDA.