University of Toronto St. George Campus - Law
Osgoode Hall Law School
Institute for Advanced Study
KVAB - Royal Flemish Academy of Belgium for Science and the Arts
CENTER FOR TRANSNATIONAL LEGAL STUDIES
Toronto
Canada
Adjunct Professor
Osgoode Hall Law School
French
Dutch
German
English
Spanish
DCL
Doctor of Civil Law
Law
McGill University
Kandidaat Rechten (Bachelors)
Candidate in Law
KULeuven
Campus Kortrijk
Katholieke Universiteit Leuven
LLM (Specialization bioethics)
Master of Laws (LLM)
LL.Lic.
Licentiate of Laws
Faculty of Law
University of Toronto
KU Leuven
Faculty of Law
University of Otago
Pontificia Universidad Javeriana
University of Oxford
Princeton
USA
Member
School of Social Science
Member
Institute for Advanced Study
Brussels Area
Belgium
Fellow
Vlaams Academisch Centrum
Fellow
KVAB - Royal Flemish Academy of Belgium for Science and the Arts
CENTER FOR TRANSNATIONAL LEGAL STUDIES
Faculty of Law
University of Otago
Dunedin
New Zealand
Visiting Professor
Faculty of Law
University of Toronto
Pontificia Universidad Javeriana
Bogotá D.C. Area
Colombia
Visiting Professor
Greater Buenos Aires
Argentina
Visiting Professor
Universidad Torcuato Di Tella
Oxford
United Kingdom
Academic Visitor
HeLEX Centre and Faculty of Law & Plumer Visiting Fellow
St. Anne's College
University of Oxford
Academic Visitor
University of Oxford
Leuven
Belgium
Visiting Professor
Faculty of Law and Faculty of Medicine
Visiting Professor
KU Leuven
Distance Learning
Theory
Public Health
Program Evaluation
Health Services Research
Qualitative Research
Science
Policy
Legal Research
Medical Education
University Teaching
Bioethics
Teaching
Lecturing
Research
Nonprofits
Higher Education
Grant Writing
Curriculum Development
Editing
The Promise and Peril of Adapting the Regulatory System to the Pharmacogenomic Context
Pharmacogenomics—the study of the influence that genetic factors have on drug response—presents significant regulatory challenges. Pharmacogenomics products require the approval of both a pharmaceutical drug and a companion diagnostic
a situation which is further complicated by the fact that authority to regulate these two different types of products is fragmented between different levels of government
different provinces
and even different agencies within the same level of government. Although Health Canada reports that they are ramping up efforts to determine the most appropriate means of incorporating pharmacogenomics information into drug evaluation and regulatory decision-making throughout the stages of drug development
Canada continues to lag behind other jurisdictions in adopting substantial reforms. This is in marked contrast to the significant efforts made by the Food and Drug Administration in the US
which has taken a leadership role in proposing new draft guidance on reforms to improve the evaluation and regulation of pharmacogenomic products—documents that provide useful insight into how Canada may more effectively adapt existing regulatory practices to the pharmacogenomic context. Informed by both the literature and interviews with key Canadian stakeholders
we explore how pharmacogenomic drugs and tests are evaluated and approved within the current Canadian regulatory system and what reforms may be necessary to more effectively evaluate and regulate these emerging health technologies. We begin by looking at
first
the split regulation of companion diagnostics by federal and provincial authorities and
second
how pharmacogenomic products are currently integrated into the drug regulatory system at the federal level. Subsequently
we consider possible reform efforts to better coordinate the review of drug and test components
to offer more flexible approaches to market authorization and to expand regulatory oversight during the post-market phase.
The Promise and Peril of Adapting the Regulatory System to the Pharmacogenomic Context
Why the Shift? Taking a Closer Look at the Growing Interest in Niche Markets and Personalized Medicine
Pharmaceutical research and development is increasingly focused on niche markets
most notably treatments for rare diseases and “personalized” medicine. Drawing on the results of a qualitative study of 34 key Canadian stakeholders (including drug regulators
funders
scientists
policy experts
pharmaceutical industry representatives
and patient advocates)
we explore the major trends that are reportedly contributing to the growing interest of the pharmaceutical industry in niche markets. Informed by both these key informant interviews and a review of the relevant literature
our paper provides a critical analysis of the many different—and sometimes conflicting—views on the reasons for and extent of the shift toward niche markets. We consider some of the potential advantages to industry
as well the important implications and risks that arise from the increasing pursuit of niche markets and pharmacogenomics. While there are many potential benefits associated with targeted therapies and drug development for historically neglected rare diseases
niche market therapies also present evidentiary challenges (e.g.
smaller clinical trials and enrichment strategies) that can make approval decisions difficult
and uncertainties remain around the true benefits of many therapies.
Why the Shift? Taking a Closer Look at the Growing Interest in Niche Markets and Personalized Medicine
Lemmens
Universidad Torcuato Di Tella