All Exam Contents Flashcards
Nuremberg Code (1947)
- Informed Consents
- Sound research based on animal experiments and knowledge of disease
- Beneficence towards subjects
- Freedom to withdraw
- Risk < Human Importance
- Plans and facilities to prevent injury, disability and death
- Termination of participation at any stage
Declaration of Helsinki (1964)
- Informed consent by subject or LAR
- Protocol reviewed by independent committee
- Human research based on lab and animal experiments
- Research conducted by qualified medical personnel
- Risk «_space;Benefits
Belmont Report (1979) Fundamental Principles (3)
Respect for Persons
Beneficence
Justice
Belmont Report: Respect for Persons
- Individual Autonomy
- Protection for individual with reduced autonomy
- Voluntary participation with adequate info
Belmont Report: Beneficence
- Max benefits and min harm
- Respect decisions
- Securing well being
Belmont Report: Justice
- Equitable distribution of research costs and benefits
- Participants should be treated equally
- Selection based on reason related to study
What did the Belmont Report create?
Office of Human Research Protections & Institutional Review Boards
General ICF Requirements
- No study activities until consent is signed
- Time to consider participation
- No coercion
- Language is understandable by subject
- Participation does not waive legal rights for subject and liabilities from sponsor/site
- All subjects receive a signed copy of consent
8 Basic Elements of Consent
- Statement of research, purpose, duration, procedures, experimental aspects
- Description of risk
- Disclosure of benefits
- Disclosure of alternative advantageous treatments/procedures
- State of how confidentiality will be protected for subjects
- For >min risk studies, compensation or treatment if I jury occurs
- Contact information for Qs related to research & research related injury
- Statement that research is voluntary and will not impact care
Additional Elements of Consent (6)
- Statement of risk to pregnant women or fetus if pregnancy occurs. Risk are unforeseeable currently
- Termination of participation by anticipated circumstance without subject consent
- Additional costs related to participation
- Consequences if subject withdraws (ie. cannot used IP) and procedures to complete termination
- Significant findings that affect willingness to participate
- # of study subjects
ICF Documentation
- IRB approved ICF must be signed and a copy must be given to subject
- FDA language that allows FDA inspection
- ICH language that allows regulating authorities (sponsor/sponsor rep/IRB) to inspect
Short Form Consent
- Form states the elements of consents and that it was discussed with subject.
- Subject only signs the short form
- Witness is required
Waiver of Consent : HHS vs FDA
HHS allows for waiver but FDA does not
Requirements for IRB to waive ICF
- Only record linking subject to research is the consent & only harm is breach of confidentiality
- Research is <min risk and involves no procedures which written consent is normally required outside of research context
- Waiver or alteration does not adversely affect welfare of subjects
- Research cannot be carried out without waiver
- Subject/LAR be provided with additional pertinent info after participation.
What might the IRB require study team to present is there is a waiver to ICF?
Study Fact Sheet (Info only, no signatures)
Consent Waiver: Emergency Research
- Subject in life threatening condition and unable to consent but research offers more benefits
- IRB must approve research and waiver
- Research cannot be conducted without waiver
- Community must be assembled and is favorable to research and benefits
- Investigator should still try to consent subject or LAR within certain timeframe and document prior to study participation
CA Only: BOR
Subjects must be given BOR in native language
Obtaining Informed Consent Process + Re-Consent
Informed consent is a multistep process.
1. Investigator must meet with patient.
2. Investigator must verbally explain the 8 elements to the subject + have sample ICF.
3. Allow time for subject to consider and ask questions
4. Prior to signing the consent, investigator must ascertain that patient is eligible, appropriately consented and subject understands study requirements
5. Subject must sign before investigator
6. If new significant findings arise that affect participation, investigator must inform subject and re-consent
Who can conduct consent sessions?
Only Principal and Sub-Is unless other approved by IRB (if less than minimal risk)
Subject Declines Participation
Investigator must make notes in patient’s charts of refusal and do not further contact patient unless they reach out first
Federal Registration Act (1935)
Daily record of proposed rules, final rules and meetings
Code of Federal Regulations (1937)
Established the HHS and FDA
Food Drug and Cosmetic Act (1938)
Food = pure, wholesome, safe to eat and made under sanitary conditions
Drug + Device = safe and effective for intended use
Cosmetic = safe and made form appropriate ingredients
All labeling & packaging is truthful, informative & non-deceptive
Medical Device Amendments to FD&C Act (1976)
First major amendment specifically for devices