Not sure if we are doing clinical trials as opposed to pre clinical trials for the cream. Since it's going to be sold as a cosmetic it may not be necessary. For FDA approval then yes of course they would be.
This is what I think the OWCP plan is. OWCP will bring the cream to the market as a cosmetic product and let word of mouth take care of the business part of it and the revenue.
Then, company will have the money to afford expensive FDA trials. This is a genius plan vs the alternative that is borrowing toxic loans and hurting the stock price before finishing the trials.
Many Biopharma companies have great ideas but they are not business savvy. They keep borrowing and at some point they tank their Price and market lose interest in them and they go bankrupt. This happens a lot in BioPharma business.
OWCP is genius both in handling the business and in the scientific aspect of it.