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Increasing access to medicines 167<br />

side of caution. However, if the regulator only considers potentially<br />

harmful side effects, this will have the unintended consequence of<br />

raising the cost, and delaying or preventing the approval of new<br />

drugs.<br />

One consequence of an excessively precautionary approach is<br />

that regulatory authorities allow new medicines or vaccines to be<br />

sold to the public only after extensive pre-clinical and clinical trials<br />

have been performed. These trials examine the safety, quality and<br />

efficacy of the new drug in treating or curing diseases. Estimates of<br />

the average time it takes to for a new drug to go through these trials<br />

range from 8.5 to 13.5 years, a process which adds considerable<br />

costs to the drug development process (DiMasi, 1995; Adams &<br />

Brantner, 2003; Dranover & Meltzer, 1994).<br />

Estimates of the cost of bringing a new drug to market vary;<br />

some researchers suggest that the total cost is over US $800 million<br />

(DiMasi et al., 2003). As such, manufacturers have strong incentives<br />

to concentrate their resources on developing ‘blockbuster’ drugs<br />

that will provide a return on that significant investment. Meanwhile,<br />

there is less incentive to invest in drugs for rarer conditions<br />

in the richer world (such as psychiatric disorders) and even for relatively<br />

common diseases in lower-income countries.<br />

Professor Sir Michael Rawlins, Chairman of the UK’s National<br />

Institute for Health and Clinical Excellence, has argued that many of<br />

the preclinical and clinical studies required by various regulatory<br />

agencies add little to the safety of the final product, but instead contribute<br />

unnecessarily to the estimated US $300–450 million cost of<br />

clinical development (Rawlins, 2004). Clearly removing excessively<br />

precautionary regulatory barriers would speed up drug development<br />

and reduce costs, creating stronger incentives to invest in the<br />

development of new drugs for diseases that may otherwise be relatively<br />

unprofitable.<br />

To some extent, the length of time it takes for new drugs to enter<br />

the market, and the consequent cost to society of delays, is an issue<br />

recognised by regulatory agencies. The FDA has adopted ‘fast-track<br />

approval’ and ‘accelerated approval’ for certain classes of drugs,

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