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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

Investigator's brochure (IB)

The investigator's brochure (IB) means a compilation of the clinical and non-clinical data on the investigational medicinal product or products which are relevant to the study of the product or products in humans (Art. 2(2)(23) EU Clinical Trials Regulation 536/2014). Its purpose is to give investigators and other trial personnel the information they need to understand the rationale for, and comply with, key features of the protocol such as dose, dosing frequency, methods of administration and safety monitoring procedures.

ICH E6 GCP section 7 sets out the expected content: summary, introduction, physical and chemical properties, non-clinical studies (pharmacology, pharmacokinetics, toxicology), effects in humans, and a summary of data and guidance for the investigator. The IB is submitted with the clinical trial application, reviewed at least annually, and contains the reference safety information used to determine whether a serious adverse reaction is expected or unexpected for expedited reporting purposes. Where the product is authorised, the summary of product characteristics may replace the IB.

The IB summarises results of earlier trials and must be written from aggregated or anonymised data; individual case narratives should not allow identification of subjects. It is confidential and commercially sensitive, distributed to sites under the confidentiality provisions of the clinical trial agreement, and archived in the trial master file.

Does the investigator’s brochure replace the clinical trial protocol?

No. The brochure provides relevant product evidence and safety information, while the protocol specifies how the particular study will be conducted. Sites need both documents where required. When product information changes, assess whether the protocol, safety monitoring or participant information also needs updating rather than treating the brochure as an isolated reference.