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Conducting Research during Public Health
Emergencies
RADM Ali S. Khan, MD, MPH
October 30, 2007
SACHRP Panel on Disaster Research
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CDC’s Mission
… "to promote health and quality of life by preventing and controlling disease, injury, and disability."
Strategic imperative:Public Health Research: Create and
disseminate the knowledge and innovations people need to protect their health now and in the future.
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Public Health Emergencies
Outbreaks Natural disasters Biological, chemical or nuclear terrorism Other public health threats
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Defining non-research activities in the context of emergency response CDC’s 1999 guidance document Most activities during emergency
responses tend to be non-research Purpose is not to contribute to generalizable
knowledge Purpose is to gain the information needed
to solve an immediate threat
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Non-research
Hurricane Katrina Environmental
assessments Surveillance
SARS Case finding Virus characterization Assay development
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Research determination
To prevent mis-labeling of research as non-research…
Determination is the responsibility of each National Center Not investigator driven Associate Director for Science and the Human Subjects
Contact Research protocols are submitted for IRB review Emergency IRB review option
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Why conduct research during emergencies? Sometimes research is an appropriate
response tool Other times, emergencies present a unique
opportunity to gain knowledge Public health imperative
Be mindful that research is a privilege!There is a fine line between opportunity and
exploitation.
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Response activities that could be considered research Additional analyses beyond those needed
to solve the immediate health problem Investigation of a non-standard intervention
or comparison of standard interventions Storage of specimens for future use in
research Long-term epidemiologic follow-up
Defining research in the context of emergency response
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Research as a response tool: Rift Valley Fever
Suspect Ribavirin may be effective treatment based on animal models
Efficacy had not been demonstrated
Placebo-controlled trial proved Ribavirin was not effective treatment and uncovered side effects
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Public Health Imperative
World Trade center 1993 – Case control study to
determine risk factors for smoke-related morbidity
Identified factors related to evacuation and safety systems
Recommendations from this study led to significant improvements, saving lives in the 2001 attack
2001 – Biomonitoring study of firefighters to determine contaminant exposures
Included comparison group of unexposed firefighters
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Unique opportunities: Ebola & SARS
Ebola Phage display libraries Human monocolonal
antibodies SARS
Follow up of pregnant mothers and their infants
Continued development of laboratory assays
Follow up studies of persistence of anti-SARS antibodies
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Challenges to getting emergency research approved Delays of convening an IRB during an
emergency and timeliness of review Timeliness of multiple IRB review Requirement for Federal-wide assurances
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Missed opportunities: Monkeypox and SARS
Natural History Study – Monkey Pox
Transmission dynamics and risk among specific populations
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Potential solutions: Obtaining IRB review
Standing or “just in case” protocols Lacks flexibility Cannot anticipate all possible emergencies IRBs are hesitant to approve Can be burdensome to maintain
Emergency IRB review Can be difficult to attain quorum on short notice
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“Just-in-Case”
SARS: following the SARS outbreak, investigators developed a protocol to cover all of the things they would like to study the next time SARS came around… Prepared all data collection instruments in
advance Prepared consent forms Obtained IRB approval Shared with State health departments
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Possible solutions:multiple sites Simultaneous IRB review
Differing interpretation of regulatory requirements
Centralized IRB review Requires IRB Authorization Agreement and
amending FWA Does not adequately consider local context
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Possible Solutions: FWAs
Unaffiliated investigator agreement Applicability is limited Can be burdensome if needed for a large
number of investigators
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Possible regulatory solutions
Designate exemption category for research during emergencies under 46.101(b)
Waive applicability of regs for emergency research as a class under the provision for Secretarial waiver, 45 CFR 46.101(i)
No IRB review ≠ No ethical consideration!
Currently at CDC: Exemptions under 101(b) are made at the Agency level, and are reviewed by both the Center
ADS and the Human Research Protection Manager
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Possible regulatory solutions
Allow expedited review of greater than minimal risk research during emergencies (to be followed by convened review as soon as is feasible)
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Possible regulatory solutions: multiple sites Pre-designation of CDC IRB as central IRB for public
health emergencies Allow for informal IRB reliance relationships during
emergencies Without IRB Authorization Agreement Without amending FWA
Suspend FWA requirement Allow local sites to engage in HHS-conducted research
without FWA during emergencies
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Additional considerations
Coordination with local health departments Local context Integration of local investigators Prevent duplication of activities
Anticipation and planning Prepare protocols in advance
Community pre-consent Standing pre-event committees
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Acknowledgements
Laura Youngblood Lauren Stockman Drue Barrett Tom Sinks Susan Stokes Rita Helfand Inger Damon
Robin Ikeda Mike McGeehin Dan Sosin Mike Gerber Lisa Lee Dixie Snider