of the nuances and challenges of conducting phase
IV trials.
The type of investigator that one seeks during
phase IV development must clearly correspond to
the nature of the study. Usually, larger numbers of
investigators who each contribute fewer patients
than the phase II and III investigators are sought. If
such individuals are local or national thought lea-
ders, who will eventually advocate for the product,
then so much the better. But even at the local level,
it is these investigators who might be found on
hospital formulary committees, develop local
treatment algorithms, see high volumes of patients
and are active in local medical societies.
Comparative superiority trials
Well-designed, head-to-head, active comparator
studies are also always to be preferred over the
Table 10.1 Typical goals and tactics of phase IV clinical trials
Extension of tolerability information Wider range of patients than in
NDA/PLA database
Larger numbers of patients
Competitive efficacy claims Active comparator study designs
New indications Supplemental efficacy studies
Ethnopharmacology Additional approvals in non-ICH countries
Outcomes assessment Pharmacoepidemiology and pharmacoeconomics
in particular healthcare environments
Pharmacovigilance Post-marketing commitments
Market expansion All of the above
The draft ICH Guidance on pharmacovigilance (ICH E2E, 11 November 2003) is likely to cause greater
emphasis on the penultimate item in this list.
Table 10.2 Practical aspects of phase IV clinical trials
Type of study Challenges
Active comparators Obtaining active comparator drug
Blinding, reformulations and bioequivalence
Disclosure of trade secrets to competitors
Placebo-control justifications
Use of appropriate dose ranges
Risks demonstrating superiority of competitor
Equivalence trials Usually large patient populations needed
Cannot demonstrate superiority
Scientific demonstration of a negative
‘Standard of care’ context challenged
Mega-trials Statistical complexity
Few inclusion/exclusion criteria
Representativeness to treated population known
only toward the end of the trial
Open-label Prescriber and patient biases
Scientifically limited
New indication Similarity to phase III designs (q.v.)
Drug interactions Almost unlimited alternatives
Special patient populations See other chapters
New formulations Bioequivalence
120 CH10 PHASE IV DRUG DEVELOPMENT: POST-MARKETING STUDIES