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Introduction to NIH OBA and the History of Recombinant DNA Oversight

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Title: Introduction to NIH OBA and the History of Recombinant DNA Oversight


1
Introduction to NIH OBA and the
History of Recombinant DNA Oversight
Allan Shipp, M.H.A.
2
NIH Mission
  • Discover new scientific knowledge that will
    improve human health
  • NIH funds, conducts, and oversees biomedical
    research
  • Over 50,000 extramural scientists
  • Over 2,000 research institutions
  • Over 5,000 intramural scientists
  • 27 Institutes and Centers

3
NIH Stewardship Responsibilities
  • Invest wisely taxpayer dollars entrusted to it
    for the support and conduct of biomedical
    research
  • Apply and communicate the knowledge gained from
    research
  • Improve the design and conduct of ongoing and
    future studies
  • Efficiently advance development of new treatments
    and cures
  • Optimize patient safety

4
NIH Office of Biotechnology Activities6705
Rockledge Drive, Suite 750
5
NIH Office of Biotechnology Activities
  • Within the Office of Science Policy, Office of
    the Director, NIH
  • Six programs
  • Recombinant DNA (RAC)
  • Genetics (SACGHS)
  • Xenotransplantation (SACX)
  • Biosecurity (NSABB)
  • Clinical Research Policy (CRpac)
  • Outreach and Education

6
Recombinant DNA Program
  • Oversee recombinant DNA research, including human
    gene transfer
  • Manage the Recombinant DNA Advisory Committee
    (RAC)
  • Administer the NIH Guidelines for Research
    Involving Recombinant DNA Molecules
  • Partner with Institutional Biosafety Committees
    in the oversight of recombinant DNA research

7
Recombinant DNA Program
  • Disseminate information on technical and policy
    matters concerning recombinant DNA research
  • RAC recommendations on clinical protocols
  • Interpretations of the NIH Guidelines
  • Scientific symposia and policy conferences
  • Develop and contribute to public policy on
    recombinant DNA research
  • Interagency oversight of biotechnology

8
A Brief History of Recombinant DNA Oversight
  • Emergence of recombinant DNA technology (Mid
    1970s)
  • Concerns among both scientific community and
    general public
  • Public health and safety
  • Environmental impact
  • Potential ethical and social implications

9
A Brief History of Recombinant DNA Oversight
  • NAS Committee Report (July 1974) called for
  • a moratorium on certain experiments
  • development of NIH guidelines for conduct and
    review of recombinant DNA experiments

10
A Brief History of Recombinant DNA Oversight
  • Asilomar Scientific Summit (1975)
  • Premise Scientists taking responsibility for the
    risks of their own research activities Outcomes
  • Reaffirmation of the need for guidelines
  • Establishment of a new federal oversight
    committee

11
A Brief History of Recombinant DNA Oversight
  • NIH Recombinant DNA Molecule Program Advisory
    Committee
  • First federal advisory committee
  • Launched process of developing NIH guidelines for
    recombinant DNA oversight
  • Made recommendations about local oversight
  • NIH grants using rDNA be awarded only after
    review of risks by an institutional biohazards
    review committee
  • Review of physical containment and facilities
  • Consideration of local circumstances

12
The First NIH Guidelines
  • Published in July 1976
  • Established responsibilities of investigators and
    institutions

13
Local Community Involvement
  • Local communities (e.g., Cambridge) begin
    establishing their own oversight frameworks
  • Local review and citizen involvement key
    characteristics of oversight

14
First Major Revisions (1978)
  • Relaxed certain restrictions deemed no longer
    scientifically necessary, while
  • ...increasing significantly public access to
    information about recombinant DNA research
    activities and increasing public participation in
    the administration of the guidelines in local
    communities.
  • (HEW Secretary Califano)

15
Enhancing Public Access (1978)
  • At least two, and no less than twenty percent, of
    IBC members had to represent the general public
    and have no connection to the institution
  • Important records of IBCs had to be publicly
    available
  • In addition to minutes MUAs, reports of
    violations, and other materials submitted to the
    federal government
  • Major actions only on advice of RAC and after
    public and Federal agency comment
  • Public participation continues to be a hallmark
    of rDNA oversight

16
1982
  • Presidents Commission for the Study of Ethical
    Problems in Medicine and Biomedical and
    Behavioral Research
  • Splicing Life Social and Ethical Issues of
    Genetic Engineering with Human Beings

17
Revised NIH GuidelinesApril 1984
  • IBCs become responsible for review of human gene
    transfer research
  • New responsibility pursuant to recommendations of
    RAC Working Group for Development of Response to
    Presidents Commission Report on Ethical and
    Social Issues
  • Subsequently, RAC Working Group on Human Gene
    Therapy embarks on Points to Consider

18
Revised NIH GuidelinesMay 1986
  • Adoption of Points to Consider guidance
    document for gene therapy protocols
  • IBC approval prior to submission to NIH
  • Points for IBC consideration and review
  • Characteristics of the biological system
  • Pre-clinical risk assessment studies
  • Public health

19
1986
  • RAC adopts Points to Consider in the Design and
    Submission of Protocols for the Transfer of rDNA
    into the Genome of Human Subjects for gene
    therapy protocols

20
1989/90
  • 1989 NIH Director approves 1st human gene
    transfer protocol
  • 1990 Points to Consider added to NIH
    Guidelines as Appendix M
  • Requirements for submitting human gene transfer
    protocols to NIH for review and approval
  • Emphasis on gene transfer not therapy

21
Revised NIH Guidelines July 1994
  • Adoption of Appendices P (plants)
    and Q (animals)
  • Containment guidance for IBCs
  • Augments IBC membership

22
Revised NIH Guidelines October 2000
  • Amended requirements for submission of gene
    transfer protocols
  • Protocols require RAC review prior to IBC
    approval
  • Rationale
  • Research participants are assured that prior to
    their enrollment in a gene transfer clinical
    trial that is either novel or raises significant
    ethical or safety concerns, their local IRB and
    IBC, and PI are apprised of the results of public
    RAC review and discussion.

23
Revised NIH GuidelinesOctober 2000
  • IBC functions specified for review and approval
    of gene transfer protocols
  • Ensure PI addresses all aspects of Appendix M
  • Ensure new enrollment requirements are met
  • Ensure appropriate consideration by PI and IBC of
    results of public RAC review
  • Ensure final IBC approval is granted after RAC
    review process
  • Ensure compliance with surveillance and reporting
    requirements

24
Amendment to Safety Information Reporting
Requirements April 2002
  • Harmonized Federal Requirements for Reporting
    Safety Information
  • Former Reporting Requirements
  • Principle investigator to report all serious
    adverse events (SAE) immediately to the IBC, IRB,
    OHRP and NIH OBA
  • Current Reporting Requirements
  • Scope (unexpected, possibly related) and
    timeframe (15/7 days) for reporting SAE parallel
    those of FDA (21 CFR 312)

25
Amendment to Safety Information Reporting
Requirements April 2002
  • Public access to safety information
  • Affirms importance of public discussion of safety
    information
  • Discourages submission of trade secret or
    commercial confidential information
  • Protection of research participant privacy in SAE
    reporting
  • Safety reports must not contain
    individually-identifiable patient information

26
Why is Biosafety Review of Recombinant DNA Needed
Today?
  • Hasnt history proven the technology to be safe?
  • Why have a technology-based approach to oversight
    instead of one that is based on the risks of
    individual products?
  • Are there really any residual scientific or
    public concerns?

27
Hasnt History Proven the Technology to be Safe?
  • Many of the catastrophic dangers originally
    feared never materialized
  • The oversight system changed to respond to this
    new understanding
  • The RAC no longer reviews and approves most basic
    science protocols
  • Local review is still important to ensure
    biological safety (medical, occupational,
    environmental) and responsible scientific
    practice

28
Why a Technology-Based Approach to Oversight
(Instead of Product Based)?
  • The NIH review system encompasses technology and
    product, as they are intertwined
  • The products of recombinant techniques can have
    unpredictable characteristics that are unlike the
    source or host organisms
  • This unpredictability warrants a local
    case-by-case assessment

29
Are there Really Any Residual Concerns?
  • Public Concerns about the Potential Public Health
    and Environmental Consequences of Research
  • Expanding programs of biodefense research
  • Emerging infectious disease threats (SARS, Avian
    flu)
  • Human gene transfer continues to raise many
    safety, ethical, and scientific issues in need of
    public discussion and analysis
  • Advances in Technology Enable Unprecedented
    Research
  • Reverse engineering of 1918 flu virus
  • Synthesis of the polio virus

30
IBCs Today
  • IBCs are an increasingly critical linchpin to
    public trust in recombinant DNA research
  • We must ensure that they are equipped to fulfill
    their responsibilities so that public safety and
    trust are preserved
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