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FindingsAnalysis of the 30 interviews led to the identification of a set of themes that were touched on by multiple interviewees. These themes are described below. Quotes taken from the interviews appear in italics. The threat posed by bioterrorism and natural epidemics is significant.
There were a range of views regarding what the most probable bioterrorist scenarios of the future might be, with some believing that attacks with well-known existing bioweapons like anthrax are most likely and others being most worried about attacks with bioengineered pathogens.
Significant shortfalls in bioterrorism preparedness remain. There was no doubt that the U.S. public health system would be key to any response, but many thought that public health remains in need of significant improvement. It was noted that physicians and the primary health care system should play a leading role in detection, but are ill-prepared to do so. Some interviewees felt strongly that great benefit would come from new rapid diagnostic approaches that would enable detection of infectious agents from patient samples. They noted that standard microbiological approaches used by most U.S. hospitals or clinics can take many hours or days to identify the pathogens of greatest concern and, in some cases, may simply fail to diagnose many of these infections. As a result, interviewees said, new diagnostic tests need to be developed. Many interviewees thought that the currently deployed biodetection systems (e.g., BioWatch) will not perform as intended and that high false-positive rates will result in frequent and expensive false alarms and decreased public trust. Planning and coordination of biodefense countermeasure development is currently inadequate.
Most of the experts concluded that there is no integrated plan to develop drugs and vaccines for biodefense. They felt that current efforts lacked coordination, were too limited in scope, or focused too much on specific threat organisms. This group felt that the process of developing countermeasures for biodefense cannot be dealt with by a plan that funds only independent research programs focusing on the basic science of pathogenesis, immune response, and other basic biological processes without making a similar-sized investment to improve the drug development process itself. Interviewees concurred that basic research is critical but added that the pharmaceutical industry has found that a coordinated approach to actively “translate” those laboratory discoveries into the drug discovery and development process is absolutely necessary in order to address the inherent complexities of bringing a new drug to the market.
There was a widely shared sentiment that an “organism-by-organism” approach is not an effective long-term strategy for countermeasure development. The number of potential threat agents (and engineered agents) is much too large to have a “one-bug-one-drug” approach. In the long-term, new paradigms for countering infectious disease will be needed, and the overall drug development process must be shortened.
Many interviewees also felt that the current plethora of government agencies and offices involved in biodefense (e.g., DHHS: NIAID, CDC, FDA; DHS: HSARPA, S&T; DOD: DTRA, USAMRIID, DARPA) makes it difficult for biotech and pharmaceutical firms, which have limited experience with the government as a direct customer, to find the right place to engage. The ability to foster these public-private connections is seen as key to a successful biodefense development effort.
Many experts suggested that the implementation of a robust biodefense countermeasure development plan would be enhanced by a “one-stop shop” that would provide: (a) the environment for the collaborative development of the plan; (b) the rigorous project management necessary to execute the plan; (c) facilitation of government and private-sector partnerships; and (d) the infrastructure for the complex process of creating and stockpiling the critical therapeutics. Some experts felt that this organization needed to be a government office, but others supported the establishment of a quasi-government entity that could effectively mediate between government and private industry and serve as an “honest broker” among all of the participating public and private-sector players. The private sector must be engaged, and BioShield is not sufficient to accomplish this.
Interviewees characterized BioShield as a procurement mechanism by which the government can finance the stockpiling of therapeutic drugs and vaccines against bioterror agents. Interviewees believed that the BioShield legislation represents a significant step for the government and demonstrates the seriousness with which the government is taking the nation’s biodefense. The lack of a welldefined market for bioterrorism countermeasures is often cited to explain the small number of new drugs being developed for this use, and BioShield is an attempt to address this shortfall.3 However, most of the interviewees believed that BioShield is only a necessary first step and is not sufficient to fully engage industry or to produce the countermeasures that will ultimately be needed.
One common concern was that BioShield does not address the liability concerns of the companies from which countermeasures are sought. Since many of these biodefense countermeasures cannot be tested for efficacy in humans (because the disease is fatal and not naturally occurring), efficacy testing will likely be done using animal models. (Safety testing would still be done in humans.) Therefore, it is possible that the first time that a countermeasure is used in humans—possibly on thousands or even millions of people—would be during a crisis. This scenario has the potential to expose the developer to a significant level of liability because of side effects or lack of efficacy in humans, and many firms are unwilling to shoulder that liability exposure on their own. Similar liability issues have been addressed in the past by the National Vaccine Injury Compensation Program (P.L. 99- 660), which provides an alternative to the traditional tort system for resolving claims of adverse reactions, and the complete indemnification granted for the smallpox vaccine (P.L. 107-296).4 Interviewees spoke to the strong need to resolve these liability dilemmas.
Some interviewees were concerned that BioShield is limited to purchasing countermeasures that are already available or are in late-stage development. They felt these restrictions severely limit the ability to invest BioShield dollars in early discovery and research programs that are needed to develop innovative new countermeasures—for example, broad-spectrum therapeutics. Many interviewees felt that this resulted in a disconnect between BioShield-funded industry and NIH-funded academia that would limit the effectiveness of BioShield and the overall biodefense countermeasure R&D enterprise.
Interviewees noted that a major obstacle to engaging the private sector, especially large pharmaceutical companies, is the “opportunity cost” that big pharmaceutical companies see in developing products for a market that may never materialize. As one recent report noted, “Because antibiotics work so well and so fast, they produce a weak return on investment for manufacturers.”5 Many of the experts believe that the major pharmaceutical houses will invest in biodefense countermeasure development to some extent out of a sense of social responsibility, but there is a point at which their fiduciary responsibility to their investors will prevent them from investing significantly in projects that have no foreseeable profit. Thus, many of the interviewees believed that the government should seriously investigate how to provide additional incentives to pharmaceutical companies to participate in biodefense countermeasure development. The experts identified a number of options that they thought would encourage the large pharmaceutical companies to get more involved. It was suggested that these government incentives might include direct funding of industrial research or providing a better guarantee than BioShield offers of a specific market size at a predetermined price per dose.* Some interviewees suggested that the government could offer developers increased patent life or market exclusivity, either on biodefense countermeasures themselves or on other products in the companies’ portfolios (akin to the Orphan Drug Act P.L. 97-414, which encourages development of new treatments for very rare diseases through tax incentives and market exclusivity agreements6). These incentives have the potential to provide increased revenues for the pharmaceutical companies in exchange for taking the risk of developing a countermeasure for a bioterror agent. The countermeasure development process needs improvement.
In general, respondents felt that there is a significant lack of overall investment in and focus on development of antimicrobial drugs and other countermeasures by all sectors (academia and industry). Most of the large pharmaceutical companies have greatly scaled back their anti-infective programs, and only a few still develop vaccines. Some biotechnology companies have programs in this area, but most venture capital funds (the most common source of early biotech funding) are also less interested in funding research and development in anti-infectives and vaccines because of the lack of a clearly defined and ongoing market.
Most interviewees felt that the bulk of federal biodefense research funding is focusing on basic research (e.g., looking at the fundamental biology of pathogens and the human response to infection) and not on developing the tools to accelerate drug development and clinical testing. Without significant advances in development and testing technologies, drug development will not accelerate, even in the face of dramatic basic science discoveries. Many interviewees felt strongly that a large increase in investment in drug discovery and subsequent development and testing will be required to develop the tools needed to address the threat of bioterrorism and infectious disease and to accelerate the countermeasure development timeline. Of those who commented, most did not believe that there was a single bottleneck in the process that needed to be overcome, but rather they thought that revolutionary changes in the entire process would be required. Further, they believed that changes could be brought about only with an increase in the overall level of funding for antiinfective development in industry, academia, and government. Finally, they believed that the increased activity resulting from the increased funding would have to be executed according to a clearly defined plan. With the current state of the art in genomics, combinatorial chemistry, and high-throughput screening, many interviewees felt that we are in a position to discover potential drugs very quickly—if there is a coherent strategy and sufficient investment is made toward these efforts. Others cautioned that although much progress has been made in basic science and enabling technologies (e.g., microbial genomics, high-throughput screening), these advances have not yet yielded large numbers of new drugs, suggesting that there may be significant work remaining before a new and expedited discovery process is realized. Some interviewees suggested that areas that might represent opportunities for improvement in the drug discovery process are in the field of proteomics (i.e., the study of the complex protein-protein interactions that take place within a cell), which might enable the identification of drugs that disrupt such interactions with increased efficacy. Improvements in proteomics and related experimental tools (e.g., high-throughput protein structure elucidation, computer modeling of protein-drug interactions) could improve more rational drug development processes, such as structure-based drug design. These and other approaches have an enormous potential for faster, more efficient drug development, but they have yielded few drug candidates to date.5 Many of the interviewees believed that it will prove difficult to accelerate preclinical development and that the iterative process of testing (in animals or in test tubes) followed by chemical modification of a potential drug to improve efficacy and reduce toxicity cannot be shortened. However, others suggested that new technologies could increase the rate at which promising compounds are identified by enabling researchers to better predict what will make a “good” drug before the expensive and time-consuming process of testing and modification begins. Some interviewees suggested that the components of preclinical development with the potential to be accelerated are toxicity and pharmacokinetic studies as well as animal safety and efficacy studies. For the toxicity and pharmacokinetic studies, advances in computer modeling may enable the rapid identification of compounds that would fail such tests, thus greatly reducing the time needed to identify viable products. For animal efficacy testing, one stumbling block may be the limited availability of testing facilities. Such testing often requires access to BSL-3 and BSL-4 containment facilities in which the appropriate animal efficacy models (i.e., the ability to cure actual infections in animals or protect against them) can be carried out. A few of the interviewees were concerned that the level of funding at these specialized government research centers (e.g., USAMRIID) is currently insufficient and that these institutions are not being sufficiently leveraged given the severity of the threat from bioterrorism. Making more such facilities available may increase the rate at which viable drug candidates can be identified and characterized.
Several of the interviewees also identified two additional levers that could be used to accelerate the development of new biodefense countermeasures. It was suggested that the nation take advantage of the drugs already on the market and develop libraries of these drugs that could very quickly be screened against a novel pathogen in the midst of an epidemic. Because they are FDA-approved and the production parameters for these drugs have already been determined, if one of them, or a cocktail, is found to be effective, the ability to manufacture and distribute it would be achieved much faster than starting from scratch. The nation could work to aggregate (or otherwise gain access to) the many libraries of potential drugs, in addition to already-licensed drugs, that are constantly being developed in academia and industry. This would enable the biodefense countermeasure development process to benefit from the work being done by all developers, not just individual companies or academic centers working in isolation. The other major realm of potential opportunity to accelerate drug development identified by a number of the interviewees was clinical trials and the FDA approval process. Some interviewees felt that the FDA should reevaluate its risk-benefit standards for biodefense countermeasures. By increasing the acceptable level of risk for biodefense-specific countermeasures (i.e., those that would be used only in an emergency), the ability to move these drugs and vaccines through the development pipeline during “peacetime” could be considerably increased. (Under BioShield, the Secretary of DHHS now has the authority to issue emergency exemptions to FDA approval for biodefense countermeasures, but only during a crisis.) However, other interviewees felt that this alteration of acceptable risk was not necessary and could be detrimental to public acceptance of biodefense countermeasures. DiscussionWe think that a number of important conclusions can be drawn from these interviews. A group of leaders from government, academia, and the private sector believe that there is a strong threat of a large-scale bioterrorist attack or a serious outbreak of a natural epidemic disease such as pandemic influenza in the near future. They generally think that the current U.S. biodefense countermeasure development strategy and process are not sufficient to meet the challenges posed by these threats and that the active participation of the biotech and pharmaceutical industries will be necessary to this effort, but no such broad participation has yet occurred. Most interviewees believe that BioShield is a good first step toward engaging the private sector, but there are many other complicated challenges to overcome before such engagement will occur. Many interviewees called for the development of an explicit overall biodefense countermeasure strategy, and many argued for the creation of a single organization that would have the responsibly for monitoring the execution of this strategy and for facilitating the collaboration of academia, biotech and pharmaceutical firms, and multiple government offices and agencies. Interviewees were divided as to whether this new organization should be housed within the federal government or if it could be more effective by sitting between the public and private sectors, perhaps as a government-chartered corporation (like Fannie Mae) or some other quasi-governmental research and development organization. Interviewees argued that the lack of liability protection for biodefense countermeasure developers must be remedied. Some interviewees suggested that improvement in computer modeling for prediction of the toxicity and pharmacokinetics of a potential new drug was a key step in drug development that could be accelerated. Most felt that increased funding was required to speed up the process by which countermeasures are developed and that this funding would have to be administered according to an explicit plan that distributed these funds to both basic science research and to more applied projects that would address the technologies of drug development and testing. These interviewees strongly suggested that there are many potential opportunities for substantial acceleration in the biodefense countermeasure development process that should be explored and that the price, cost, and complexity of developing countermeasures are not immutably defined or intractable. Given the threat of bioterrorism, the complexity of creating the necessary medical countermeasures, and the number of as yet unpursued opportunities to rapidly accelerate their creation, the Administration and Congress would be wise to make the countermeasure development process, in and of itself, a topic of intense analysis and action in the months and years ahead. AcknowledgmentsThe work of the Center for Biosecurity of UPMC on this project is supported by the Alfred P. Sloan Foundation. The work of the Sarnoff Corporation on this project is supported by the U.S. Army Medical Research and Materiel Command under Contract No. DAMD17-03-C- 0082. The views and opinions and/or findings contained in this report are those of the authors and should not be construed as an official Department of the Army position, policy, or decision unless so designated by other documentation. In the conduct of research where humans are subjects, the investigators adhered to the policies regarding the protection of human subjects as prescribed by 45 C.F.R. 46 and 32 C.F.R. 219 (Protection of Human Subjects). References
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