Recommendations & Conclusions
33 items
1
Conclusion
First Report - The antimicrobial potent…
Acknowledged
The safety of phages has been well established mainly on the basis of observational evidence drawn from specific clinical interventions. However, as with all medicines, robust clinical trial data is important to provide and develop assurances around all aspects of patient safety, including the long-term impact of phages, especially their …
Government response. The government outlined ongoing engagement with phage stakeholders and monitoring of the research and clinical trial pipeline. It stated the upcoming 2024-2029 AMR National Action Plan will set out research priorities, including innovation for AMR.
Department for Science, Innovation and Technology
2
Conclusion
First Report - The antimicrobial potent…
Accepted
Clinical data indicates that in many cases phages have been observed to reduce bacterial infections in patients. We also heard that their use in animals has also been shown to be effective. However, further clinical trials are required to prove the consistent effectiveness of phages. Such studies need to include …
Government response. The government described existing provisions for researchers, including access to bacterial strain panels and expertise, and highlighted funding opportunities through NIHR and UKRI. It specifically noted Innovate UK's recently launched £30 million PACE initiative to accelerate early-stage innovation in AMR, …
Department for Science, Innovation and Technology
3
Recommendation
First Report - The antimicrobial potent…
Accepted
We recommend that the Department for Health and Social Care (DHSC), the Medicines and Healthcare products Regulatory Agency (MHRA), the National Institute for Health and Care Excellence (NICE) and National Institute for Health and Care Research (NIHR) should now consider what specific evidence, and to what standard, is needed to …
Government response. The MHRA committed to providing non-binding advisory guidance on the specific data needed to evaluate licensed phage products for NHS use. The government also confirmed it will continue to engage with phage stakeholders through the Innovate UK KTN Phage Innovation …
Department for Science, Innovation and Technology
4
Conclusion
First Report - The antimicrobial potent…
Acknowledged
Phages have been used as therapy for over a hundred years, and much of the fundamental science relating to phages is understood. However, there is still more that the global and UK research communities can learn. Further research will be able to establish key issues such as long-term interactions between …
Government response. The government recognised the importance of research into non-traditional therapies like phages and committed to continuing to monitor the AMR clinical and research pipeline. It also stated it would not produce annual reports exclusively on phages but would regularly review …
Department for Science, Innovation and Technology
5
Conclusion
First Report - The antimicrobial potent…
Accepted
However, the apparent reticence of funders to commit to phages is despite a general acceptance in the evidence we took that phages show promise and need more research alongside clinical trials. It is important to understand and reflect on the reasons for this. The recently established Innovate UK Phage Knowledge …
Government response. The government welcomed the UK KTN Phage Innovation Network's role and stated it would consider its report recommendations, but clarified it does not plan a public response. It highlighted the existing AMR Funders Forum, chaired by the MRC, as the …
Department for Science, Innovation and Technology
6
Recommendation
First Report - The antimicrobial potent…
Deferred
Because phages have had relatively limited recent research funding from public sources, we recommend that the Government reviews the status of phages within its plans to tackle AMR. We also recommend more specifically that the National Institute for Health and Care Research and the UK Health Security Agency engage with …
Government response. The government supports the principle of phage education but states that medical and veterinary training standards and curricula are the responsibility of independent statutory bodies (GMC, RCVS, and schools), thereby deflecting responsibility. It does not address the recommendation to review …
Department for Science, Innovation and Technology
7
Conclusion
First Report - The antimicrobial potent…
Acknowledged
We were disappointed to hear that there is a translational phage research “gap” in the UK. We agree that funding, and especially public funding, should be awarded with care. However, we are concerned that, despite being included in the Government’s AMR strategy, if not properly supported, the potential of phages …
Government response. The government acknowledges manufacturing challenges and points to existing and newly announced capital grant programmes for life sciences manufacturing. NHS England has also committed to consider whether its antimicrobial subscription model may be relevant to phage products and to review …
Department for Science, Innovation and Technology
8
Recommendation
First Report - The antimicrobial potent…
Acknowledged
We recommend that the Department of Health and Social Care (DHSC) reviews the current funding arrangements for phage translational research and identifies what are the bottlenecks for such research. A review should consider what specific assistance phage translational research requires to increase the prospects of success for funding bids. It …
Government response. The government explains that NIHR does not ringfence funding and awards depend on application quality, noting few past applications for phage research. It states that NIHR and DHSC are exploring approaches with UKRI to improve phage research capacity, but does …
Department for Science, Innovation and Technology
9
Recommendation
First Report - The antimicrobial potent…
Rejected
The Government, the World Health Organisation and a number of the witnesses we heard from have highlighted the importance of a “One Health” approach to tackling AMR across sectors including human and animal health, the food supply chain, and the environment. The Department of Health and Social Care (DHSC) and …
Government response. The government rejects the recommendation to produce annual reports exclusively focused on phages, stating it is reluctant to prioritize any one technology, but will regularly review progress on its 5-year AMR National Action Plan, which will include phages.
Department for Science, Innovation and Technology
10
Conclusion
First Report - The antimicrobial potent…
Acknowledged
For the potential benefits of phages to be fully explored and, if possible, exploited in the UK, with competitive advantage, it is important that existing phage- related assets are properly aligned and integrated, connecting the various sectors, institutions, and actors so they can draw on shared resources, information, data, and …
Government response. The government welcomes the insights and acknowledges the importance of a robust network for phage-related knowledge sharing, expressing support for the existing UK KTN Phage Innovation Network and describing other relevant coordination efforts.
Department for Science, Innovation and Technology
11
Recommendation
First Report - The antimicrobial potent…
Deferred
We recommend that the Department for Health and Social Care responds to the UK’s Phage Knowledge Transfer Network’s proposals within six months of their publication. The Department should set out how it will help develop a network for phage-related knowledge sharing and assets such as biobanks. The Department should also …
Government response. The government states it has committed to establishing general clinical trial acceleration networks with funding, but does not specifically address responding to the Phage Knowledge Transfer Network's proposals or developing a phage-specific knowledge sharing network or biobanks.
Department for Science, Innovation and Technology
12
Recommendation
First Report - The antimicrobial potent…
Deferred
If phages are to be used more widely within the UK’s healthcare system it is important that healthcare professionals are aware that they are an antimicrobial alternative, especially when antibiotics have failed or are failing. We recommend that information about the clinical use of phages is included within medical training …
Government response. The government supports the principle of education and training on phages but redirects responsibility for medical and veterinary training standards and curricula to the independent General Medical Council, Royal College of Veterinary Surgeons, and medical schools.
Department for Science, Innovation and Technology
13
Recommendation
First Report - The antimicrobial potent…
Deferred
The public will need to be convinced that phages are safe and effective. This will be key if phages are to play a role in addressing AMR in healthcare and as part of a One Health approach to addressing AMR across various sectors, such as the food industry and the …
Government response. The government supports training on phage therapy but redirects responsibility for medical and veterinary training standards to the General Medical Council (GMC) and the Royal College of Veterinary Surgeons (RCVS), stating they determine curriculum content.
Department for Science, Innovation and Technology
14
Recommendation
First Report - The antimicrobial potent…
Rejected
The set of consensus high standards for pharmaceutical production, known as Good Manufacturing Practice (GMP), should continue to be required in the UK for high quality phages manufactured for generic products targeting the most common bacterial pathogens. It should also underpin the production of phage biobanks to be accessed at …
Government response. The government states that GMP requirements remain appropriate for named-patient use, thereby rejecting the committee's suggestion for non-GMP phages for compassionate use. It notes MHRA guidance for licensed products is in development.
Department for Science, Innovation and Technology
15
Conclusion
First Report - The antimicrobial potent…
Accepted
One of the main obstacles to establishing Good Manufacturing Practice (GMP) facilities in the UK is the cost and the reluctance of pharmaceutical firms to invest in phages and antimicrobials more generally because of an uncertain return on investment compared to other medicines and drugs. However, investing in a small, …
Government response. The government acknowledges manufacturing challenges and highlights existing capital grant programmes that incentivize life sciences manufacturing investment. NHS England has also committed to consider whether its antimicrobial subscription model may be relevant to phage products in the future.
Department for Science, Innovation and Technology
16
Recommendation
First Report - The antimicrobial potent…
Deferred
We recommend that the Department for Health and Social Care considers bringing together funders with relevant catapults and innovation centres, such as the Centre The antimicrobial potential of bacteriophages 59 for Process Innovation, to build a GMP facility that can be accessed and used by phage innovators, the NHS and …
Government response. The government indicates DHSC should review current guidance for non-GMP phages, and MHRA is developing new non-binding advisory guidance for them. However, it does not address the recommendation to build a GMP facility or invest in existing spaces for phage …
Department for Science, Innovation and Technology
17
Recommendation
First Report - The antimicrobial potent…
Accepted
We recommend that the MHRA provides guidance on how phage cocktails will be regulated. It should consider the case of influenza vaccines, and allow phage permutations to be assessed on the basis of their individual constituent ingredients meeting agreed purity and safety standards and not for each new combination of …
Government response. The government states that the MHRA is developing non-binding advisory guidance for the licensing requirements of phage products, which will address regulatory frameworks and genetic modifications, with public input.
Department for Science, Innovation and Technology
18
Recommendation
First Report - The antimicrobial potent…
Deferred
For phages to be effective they will need to keep pace with bacterial resistance and be amenable to adaptation for individual patients. Genetically engineered (GE) phages may be one way of ensuring this. GE phages have already been used in the UK and elsewhere. However, if they are to be …
Government response. The government's response consists solely of a list of references and links, providing no specific textual reply or commitment regarding guidance for GE phages or extracted phage enzymes.
Department for Science, Innovation and Technology
19
Conclusion
First Report - The antimicrobial potent…
Acknowledged
If the UK government supports the commercial production of genetically engineered (GE) phages, it will inevitably lead to regulatory divergence from the EU. However, we believe this divergence offers the UK an opportunity that should be pursued. This should be part of a clear regulatory and safety licensing regime for …
Government response. The government acknowledges that genetic modifications influence regulatory frameworks and states that MHRA's upcoming non-binding advisory guidance will clarify this. The Veterinary Medicines Directorate is also reviewing existing requirements for genetically modified organisms in phage-based veterinary medicines.
Department for Science, Innovation and Technology
20
Recommendation
First Report - The antimicrobial potent…
Rejected
We welcome the willingness of the MHRA to adopt a flexible approach to accelerating the authorisation of the use of phage therapies and its offer to work with phage innovators to support their development. However, the MHRA should provide clarity on how different pathways for developing phages, such as the …
Government response. The government rejects the premise of regulating non-GMP phages, stating all medicines must be manufactured to GMP standards. It clarifies that specific developmental pathways are not needed for compassionate use phages and that MHRA guidance under development will provide information …
Department for Science, Innovation and Technology
21
Conclusion
First Report - The antimicrobial potent…
Acknowledged
Our evidence suggests that current regulations for clinical trials and the manufacturing of medicines are unlikely to be effective for phages as they are for other drugs or antibiotics. This is because the current regulatory approach to testing and manufacturing medicines is based on a single consistent formulation being shown …
Government response. The government acknowledges the issues with current regulations for phages, stating that new MHRA guidance under development will address safety testing, extrapolation between strains, and clarify that named-patient use requires GMP but not clinical trials.
Department for Science, Innovation and Technology
22
Recommendation
First Report - The antimicrobial potent…
Accepted
The MHRA should set out how they propose to regulate and ensure clinical safety for each of the scenarios set out above. This would allow for the narrowing of R&D and production work to prevent wasted effort and allow an agile approach, allowing non-generic phage production for specific patients but …
Government response. The government states that MHRA non-binding advisory guidance for licensed phage products is in development, scheduled for public consultation in 2024, and will define safety tests and extrapolation for bacteriophages. It also confirms GMP requirements for named-patient use.
Department for Science, Innovation and Technology
23
Recommendation
First Report - The antimicrobial potent…
Accepted
The MHRA should also set out more broadly how current clinical trial structures can support the development and regulation of new personalised medicines. This should include an outline of what changes may be required to underpin this emerging and promising area. This should include early and regular engagement by regulators …
Government response. The government commits to reviewing clinical trial legislation, with accompanying guidance to be published in 2024, and is establishing clinical trial acceleration networks to support innovation and new ways of delivering trials.
Department for Science, Innovation and Technology
24
Conclusion
First Report - The antimicrobial potent…
Accepted in Part
One of the major obstacles to phage clinical trials in the UK has been the requirement for GMP phages. However, regulators require that for phages to achieve GMP standards they must themselves have first been subject to clinical trials. This impasse is stalling the development of phages in the UK. …
Government response. The government states that MHRA's draft non-binding advisory guidance will define standards for licensed phages and clarifies that phages for named-patient use require GMP standards but not clinical trials or marketing authorization, thus providing clarity on the described conundrum.
Department for Science, Innovation and Technology
25
Recommendation
First Report - The antimicrobial potent…
Accepted
We recommend that the MHRA sets out what standard of phages will be required for UK clinical trials and how GMP will be acquired by UK produced phages if they cannot be assessed by a clinical trial. This guidance should be published within six months of the publication of this …
Government response. The government states that the MHRA's draft non-binding advisory guidance on phage regulation, intended for public consultation later this year, will define quality, safety, and efficacy standards for licensed phages. It also clarifies that phages for named-patient use require GMP …
Department for Science, Innovation and Technology
26
Recommendation
First Report - The antimicrobial potent…
Accepted
The funding of clinical trials, especially later trials, has proved an obstacle for phages. We were pleased to hear that the National Institute for Health and Care Research would welcome applications from phage researchers and companies to access public funding to conduct clinical trials. We recommend that DHSC and the …
Government response. The government states that the NIHR offers an existing Research Support Service for researchers, including those working on phages, and that MHRA's upcoming guidance will recommend sponsors engage with them for scientific advice, which MHRA already provides.
Department for Science, Innovation and Technology
27
Recommendation
First Report - The antimicrobial potent…
Accepted
We are pleased that the MHRA is open to using phage data from a variety of sources as long as it is of sufficient quality. We recommend that the MHRA outlines how it will use clinical data from other countries and non-health evidence to inform its decision-making on regulating phages. …
Government response. The government states that the MHRA has mutual recognition agreements and has introduced the International Recognition Procedure (IRP) from January 2024, which allows it to recognise the decision-making of trusted reference regulators to expedite market approval for products in the …
Department for Science, Innovation and Technology
28
Recommendation
First Report - The antimicrobial potent…
Deferred
The current situation whereby in the absence of UK GMP facilities only phages imported from abroad can be used, which may themselves be non-GMP, is irrational and discriminatory. This is a costly approach based on a fragile supply chain, which is denying very ill patients rapid access to a therapy …
Government response. The government states new non-binding advisory guidance on phage regulation is under development by MHRA, but the production of a monograph will be deferred until MHRA gains experience from this guidance.
Department for Science, Innovation and Technology
29
Recommendation
First Report - The antimicrobial potent…
Rejected
We believe that the UK should allow the compassionate use of non-GMP phages produced in the UK for last resort medical cases where other medical approaches have failed or are failing. This would bring the UK in line with several EU countries, and the USA and Australia. The UK can …
Government response. The government rejects allowing non-GMP phages for compassionate use, stating all medicines must meet GMP standards, and defers the production of a monograph until MHRA gains experience from developing new advisory guidance.
Department for Science, Innovation and Technology
30
Recommendation
First Report - The antimicrobial potent…
Deferred
We recommend that the Medicines and Healthcare products Regulatory Agency (MHRA) revisits the regulation of the clinical use of non-GMP phages produced in the UK for last resort compassionate cases where antibiotics or other antibacterial interventions have failed. The MHRA should review the use of non-GMP phages in such cases …
Government response. The government reiterates that all medicines must be manufactured to GMP and states that new non-binding advisory guidance is under development by MHRA. However, the production of a monograph specifically for non-GMP phages, as recommended, will be deferred.
Department for Science, Innovation and Technology
31
Recommendation
First Report - The antimicrobial potent…
Deferred
We recommend that the MHRA reviews how current regulations would govern liability for clinicians and hospitals who used UK non-GMP phages, produced to a magistral monograph. It should consider what changes, if any, could be made to provide greater reassurance regarding liability, where appropriate safety and purity standards were met.
Government response. The government rejects the recommendation, stating that regulation for pharmacy practice is beyond the remit of the MHRA and that liability for unlicensed medicines currently rests with the prescriber.
Department for Science, Innovation and Technology
32
Recommendation
First Report - The antimicrobial potent…
Rejected
If the antimicrobial use of phages is to move beyond ad hoc compassionate cases, the Government and its agencies should reflect on what role they are to play in the fight against AMR. At the moment, phages are referred to in the AMR strategy, as one approach amongst others. However, …
Government response. The government rejects producing a further definitive statement on phages or a roadmap at this time, stating it will continue to monitor developments and include phages as one of many research areas in the upcoming AMR national action plan.
Department for Science, Innovation and Technology
33
Recommendation
First Report - The antimicrobial potent…
Rejected
We recommend that the Government produces a clear statement on its assessment of phages. If it concludes that phages are to play a significant role in fighting AMR, it should produce a comprehensive plan as to how they will be supported and how the necessary infrastructure and regulatory landscape will …
Government response. The government rejects producing a new clear statement on phages or a comprehensive plan for their support and regulatory landscape at this time. It states that existing evidence is promising but requires more robust data, and that phages will be …
Department for Science, Innovation and Technology