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Term of the Day

Natural history study

A natural history study is a preplanned observational study intended to track the course of a disease over time, identifying demographic, genetic, environmental and other variables that correlate with its development and outcomes in the absence of intervention, or under standard of care. Designs may be retrospective (chart review of existing records) or prospective (longitudinal follow-up of a cohort or registry).

Natural history data is particularly important in rare and paediatric diseases, where randomised placebo-controlled trials may be infeasible or unethical. The FDA (guidance on rare disease natural history studies, 2019) and the EMA accept well-designed natural history studies to define endpoints and biomarkers, identify patient subgroups, estimate sample sizes and, in some cases, serve as external or historical control arms for single-arm trials supporting orphan products.

Because they are non-interventional, natural history studies fall outside the CTR and are governed by national law (for example France's MR-003 or MR-004 reference methodologies) and by the GDPR. They typically involve secondary use of medical records, long-term follow-up, genetic data and small populations in which anonymisation is rarely achievable, so pseudonymisation, a DPIA and a robust research legal basis under Art. 9(2)(j) are essential. Registries maintained by patient organisations or academic consortia raise additional questions of joint controllership and data access governance.

I

Investigational medicinal product (IMP)

An investigational medicinal product (IMP) means a medicinal product which is being tested or used as a reference, including as a placebo, in a clinical trial (Art. 2(2)(5) EU Clinical Trials Regulation 536/2014). The definition therefore covers the candidate drug itself, active comparators and placebos, whether or not the product already holds a marketing authorisation; an authorised product used outside its approved indication or formulation in a trial is also an IMP. Products used to support the trial without being tested are auxiliary medicinal products.

IMPs must be manufactured under good manufacturing practice (Chapter IX CTR and Commission Delegated Regulation (EU) 2017/1569), labelled according to Annex VI, released by a qualified person and traced from manufacturer through depots and sites to the subject, using systems such as IRT. Quality, non-clinical and clinical data on the IMP are compiled in the IMPD and summarised for investigators in the investigator's brochure. In the United States the equivalent concept is the investigational new drug governed by the IND regulations.

IMP accountability records link kit numbers to subject numbers and dispensing dates, which makes them pseudonymised personal data that must be retained in the trial master file for 25 years, protected against unauthorised unblinding, and covered by the trial's DPIA together with the supply-chain vendors involved.