21 Code of Federal Regulations Flashcards
What is CFR 21 Part 11?
This code of federal regulations pertains to Electronic Records and electronic Signatures.
(Applies to Records in electronic form not paper records sent electronically)
What is a closed system?
A system that is controlled by the people responsible for the EMR content.
1.Must have procedure to protect data integrity and confidentiality.
2. Must be able to create copies of records
3. Validation of systems to ensure accuracy of content
4. Protect and limit system access (Time stamps, Audit trails, and use of QA procedures)
5. Provide proper training for specific roles
6. Authority controls (Username and password)
What is an open system?
A system that is not controlled by the people responsible for the EMR content.
1.Must have procedure to protect data integrity and confidentiality.
2. Must be able to create copies of records
3. Validation of systems to ensure accuracy of content
4. Protect and limit system access (Time stamps, Audit trails, and use of QA procedures)
5. Provide proper training for specific roles
6. Authority controls (Username and password)
What are the requirements for an Electronic Signature?
- Printed name
- Date and time of signature
- Reason for signature (Review, Approval, Authorization)
What is an Electronic signature?
After confirming the identity of an individual it is linked to them and it is only used by the individual.
Should not be re-used or re assigned to anyone else.
What is CFR 21 Part 50?
Protection of Human Subjects
What must you obtain in order to involve a Human in research?
Informed Consent
What is CFR 21 Part 50 Subpart B?
Informed Consent of Humans
An Informed Consent Form should not have?
- No coercion
- No exculpatory language
- No excusing an institution from liability for negligence
What are the exceptions to obtaining an ICF?
- Emergencies ( There is no ample time to obtain, no better option for the pt.)
- President of USA can waive consent of IND for members of the armed forces
- Must have reasonable risks and prior animal/preclinical studies that display a benefit in use of IND/Device
- Must be able to provide the subject or LAR with ICF ASAP
What is a LAR?
Legally Appointed Representative
What are the Elements of an Informed Consent Form?
- Purpose
- Procedures involved
- Experimental parts
- Risks & Benefits
- Alternative options
- Statement that this is voluntary
- How confidentiality will be maintained
- Compensation/TX for injury if > minimal risk
- Who to contact for clinical concerns and subject rights
Documentation of Informed consent
Sign and Date
Date of IRB approval
Subject given a copy of the written consent document
ICF Short Form
Requires witness at the oral presentation of the ICF to the subject
Consenter: Signs a copy of the summary
Subject :Signs Short form
Witness: Signs both the Short form and a copy of the summary
What is CFR 21 Part 50 Subpart D?
Additional Safeguards for Children and Includes wards of state, but they must have an advocate assigned and have no relation to the trial
Safeguards for Clinical Trials Involving Children
Studies are ok if they have minimal risk or if > than minimal risk , present prospect of direct benefit to subject.
Benefit must be favorable vs. alternative options
Adequate provisions are made for solicitation of assent from kids /parent
Or greater than minimal risk and no direct benefit but generalizable knowledge at subjects condition will be gained.
IRB accounts for AGE, MATURITY and PSYCHOLOGIAL state of kids involved i.e.. assent of the child is not necessarily needed to proceed
What is CFR 21 Part 56?
Institutional Review Boards
What investigations/scenarios are exempt from IRB review?
- Investigations commenced prior to July 27, 1981
- Emergency use of test articles and must be reported within 5 days
- Consumer acceptance studies. (Taste, food quality and etc.) Food ingredients must be at or below safe levels approved by FDA
What is CFR 21 Part 56 Subpart B?
IRB Registration and membership
Who should the IRB register to initially? How often do they need to renew their registration?
IRB’S must be registered at a site maintained by the Department of Health and Human Services and must renew registration with DHHS every 3 years
What information should the IRB have in order to be registered?
- Site’s name and Address
- Name, address, phone, fax and email of senior officer at the institution. (Must be revised within 90 days if any change and revised information should be sent to FDA)
- # of active protocols under initial and /or continuing review or expedited review (I.e active protocols)
- Description of product types in active protocols. If new products/protocols are picked up it must be reported within 30 days
How often should an IRB Re-Register?
Bonus Question!!! 😁
Every 3 years.
Bonus: IRB is registered after review and acceptance by Department of Health and Human Services
How can IRB registration occur?
Electronically or by mail to the office of GCP in MD
How many days does an IRB have to notify if disbanding? Who do they notify?
30 days to notify the FDA
IRB Membership
- Must have greater than or equal to 5 members with varying backgrounds, which is an effort to be nondiscriminatory and protect vulnerable subjects.
- No IRB shall have all women or all men or a single profession in its membership
- At least 1 member with concerns in a scientific area
- At least 1 member in a non scientific area
- At least 1 member who is in no way affiliated with the institution
- No members with a protocol related conflict of interest.
IRB Functions and Operations
IRB must have written SOPS for reporting and monitoring requirements
IRB must have convened meetings with majority of members present for protocol review EXCEPTION: Expedited review
Who give approvals or disapprovals for protocols?
The IRB has authority.
IRB can also request modification requirements for protocols