DNDi welcomes the opportunity to respond in these discussions and commends the INB its collaborative approach thus far and hopes that this will continue and be extended to any subgroups. As a not-for-profit research and development (R&D) organization, DNDi focuses these comments on how the instrument can best ensure research which ensures equitable access to health tools.
Equity should be the core guiding principle of any new pandemic instrument, particularly in relation to incentivizing innovation and ensuring equitable access to health tools, given that the lack of equity is at the core of the breakdown of the COVID-19 response. Equity must also guide the governance of the instrument. The power imbalances laid bare throughout the pandemic have made clear that current global health architecture persistently fails to address the needs of low- and middle-income countries (LMICs). Public responsibility on the part of all governments and equal participation from LMICs and high-income countries (HICs), including in priority-setting, decision-making, and resource allocation – will be essential for the very legitimacy of any new instrument.
The instrument should avoid a narrowly defined focus solely on those diseases or pathogens thought to be a ‘security threat’ in HICs and must therefore include existing epidemics, antimicrobial resistance, and other pandemic-prone and climate sensitive diseases and take a One Health approach. An appropriately broad scope will help ensure a disruption in the cycle of panic and neglect, in which there is a surge of attention during a crisis followed by years of inaction. Much of the infrastructure that is needed to ensure timely development and delivery of medical countermeasures for pandemics – including for surveillance, research, clinical trials, manufacturing, regulatory systems, health services, etc. – must be robustly supported and strengthened during intra-crisis times both to deliver necessary services for communities in need and to prepare for and respond to pandemics.
Structure of substantive elements
We are pleased to see the coordination of R&D prioritized as a substantive element in the white paper. However, some substantive elements surrounding the financing, discovery, and development of – and equitable access to – health tools could be grouped to more effectively address the thematic areas of prevention, preparedness, response, and recovery. For example, in order to prepare for equitable access to countermeasures, we recommend the inclusion of globally agreed norms and binding rules that govern the R&D process – including transparency and open sharing of research data, knowledge, and technology as well as equitable allocation of health tools – thereby accelerating the R&D process and ensuring that during the response to pandemics the benefits of scientific progress will be equitably shared and available to all. R&D could be featured and addressed throughout the technical areas and strategic themes which would help to address many of the individual substantive elements currently laid out throughout the matrix.
In addition, sustainable and predictable financing of end-to-end preparatory and crisis R&D is currently not explicitly referenced in the draft, and should include mechanisms for financing increased surveillance, clinical trial, manufacturing, and regulatory capacity which strengthens infrastructure to address both pandemic and existing health priorities.