copied cards Flashcards
What does 21 CFR Part 11 cover?
Electronic Records; Electronic Signatures
What is a closed system?
An environment in which system access is controlled by persons who are responsible for the content of electronic records that are on the system.
What is an open system?
An environment in which system access is NOT controlled by persons who are responsible for the content of electronic records taht are on the system.
What is a digital signature?
It is an electronic signature based on crypotgraphic methods of originator authentication, computer by using a set of rules and set of parameters such that the identity of the signer and the integrity of the data can be verified.
What is an electronic signature?
it is a computer data compilation of any symbol or series of symbols executed, adopted, or digital form that is created, modified, maintained, archived, retrieved, or distributed by a computer system.
What is a handwritten signature?
a scripted name or legal mark of an individual handwritten by that individual and executed or adopted with the present intention to authenticate a writing in a permanent form.
What does biometrics mean?
it is a method of verifying an individual’s identity based on measurement of the individual’s physical features or repeatable actions wehre those features and/or actions are both unique to that individual and measureable.
Act means…
The Federal Food, Drug, and Cosemetic Act
Agency means…
Food and Drug Administration
General Requirements for electonric signatures are..
1) Each electronic signature should be unique & shall not be reused or reassigned to anyone else. 2) Before the organization certifies the signature they have to verify the identity of the individual. 3) Persons shall certify that electronic signatures used after 20AUG1997 are legally binding.
Electronic signatures NOT based on biometrics shall
1) employ at least two distinct identification components (ID code and password). 2) be used only by genuine owners. 3) use of the signature by anyone other than its genuine owner requires collaboration of two or more individuals.
Electronic signatures that ARE based on biometrics shall
be designed to ensure that they cannot be used by anyone other than their genuine owner.
Controls for ID codes and passwords shall include these 5 components:
1) maintain the uniqueness of each ID code and pw 2) Ensure that the ID code and pw ussuances are periodically checked, recalled, or revised. 3) Following loss management procedures to electronically deauthorize lose, stolen, missing or otherwise potentially compromised tokens, cards, and other devices. 4) use of transaction safeguards to prevent unauthorized use of pws and/or ID codes 5) initial and periodic testing of devices that bear or generate id code or pw info.
What does 21 CFR Part 50 cover?
Protection of Human Subjects
Clinical Investigation means..
any experiment that involves a test article and one or more human subjects and that either is subject to requirements for prior submission to the FDA or is not subject to requirements for prior submission to the FDA but the results of which are intended to be submitted later to or held for inspection by the FDA as part of an application for a research or marketing permit.
Sponsor
person who initiates a clinical investigation, but who does not actually conduct the investigation.
Sponsor-Investigator
individual who both initiates and actually conducts, alone or with others, a clinical investigation.
Exceptions from informed consent for emergency research
1) subject is in a life-threatening situation and collection of valid scientific evidence is necessary to determine safety and effectiveness of particular interventions. 2) Obtaining consent is not feasible. 3) Participation in the research holds out the prospect of direct benefit. 4) The clinical investigation could not practicably be carried out without the waiver. 5) the tx plan makes sense and the investigator is doing what he/she can to contact a legally authorized rep. 6) IRB has approved 7) additional protections of the rights and welfare of the subjects will be provided
Elements of informed consent
1) statement that the study involved research. 2) description of any reasonably foreseeable risks or discomforts to the subject. 3) description of any benefits to the subject or others. 4) disclosure of alternative procedures. 5) statement describing the extent to which confidentiality of records will be maintained 6) statement regarding compensation and medical tx if any injury. 7) who to contact for answers to pertinent questions about research and subjects rights. 8) participation is voluntary.
Additional elements of informed consent
1) statement that the particular tx may involve additional risk to the subject. 2) anticipated circumstances under which participation may be terminated. 3) any additional costs. 4) consequences of a subjects decision to withdraw. 5) statement that significant findings during the research will be provided. 6) approximate number of subjects involved in the study.
Each IRB should have at least how many members?
5
Each IRB shall include:
1 member whose primary concerns are in the scientific area and 1 whose primary concerns are in nonscientific areas, and 1 who is not otherwise affiliated with the institution.
Criteria for IRB approval
- Risks to subjects are minimized. 2. Risks to subjects are reasonable in relation to anticipated benefits. 3. Selection of subjects is equitable. 4. informed consent from each subject. 5. informed consent should be documented. 6. research plan makes adequate provision for monitoring the data collected. 7. adequate provisions to protect the privacy of subjects and to maintain confidentiality of subjects.
test article
any drug for human use, biological product for human use, medical device for human use, human food additive, color additive, electronic product, or any other article subject to regulation under the act or under sections 351 or 354-360F of the public health service act.
A research permit under section 505(i) of the act is usually known as
investigational New Drug (IND) application
A research permit under section 520(g) of the act is usually known as
investigational device exemption (IDE)
When must an IRB register?
Each IRB must submit an initial registration and must renew every 3 years. IRB registration become effective after review and acceptance by HHS.
Where can an IRB register?
Either electronically or in writing to the Office of Good Clinical Practice, Office of Special medical programs, Food and drug administration, silver spring, MD.
How does an IRB revise its registration information?
must submit changes within 90 days. 30 days if disbanning, otherwise at time of registration renewal.
What does 21 CFR Part 312 cover?
Investigational New Drug Application
clinical investigation of a drug product that is lawfully marketed in the US is exempt from the requirements of this part if all of the following applies:
- The investigation is not intended to be reported to the FDA as a well-controlled study in suppport of a new indicatino for use nor intended to be used to support any other significant change in the labeling of the drug. 2) If the drug that is undergoing investiagtion is lawfully marketed as a prescription drug product, the investigation is not intended to support a significnat change in the advertising for the product. 3) The investigation does not involve a route of administration or dosage level or use in a patient population or other factor that significantly increases the risks associated with the use of the drug product. 4) Investigation is conducted in compliance w/ the IRB and appropriately consents. 5) Investigation is conducted in compliance with the requirements.
What products are exempt from requirements of 312?
1) blood grouping serum 2) reagent red blood cells, and 3) anti-human globulin.
What type of drug is exempt from requirements of 312?
a drug intended solely for tests in vitro or in laboratory research animals.
A clinical investigation involving use of THIS is exempt from the requirements of 312 if the investigation does not otherwise require submission of an IND
Placebo.
Bioavailability studies
YES is subject to provisions of 320.31
Unlabeled indication
No, does not apply to the use in the practice of medicine for an unlabeled indication of a new drug product
Independent ethics committee (IEC)
a review panel that is responsibile for ensuring the protection of the rights, safety, and well-being of human subjects involved in a clinical investigation and is adequately consititued to prvode assurance of that protection.
Investigational new drug
a new drug or biological drug that is used in a clinical investigation.
What does 21 CFR Part 56 cover?
Institutional Review Boards
What is CFR 21 Part 812
Investigational Device Exemptions
What is a significant risk device?
A device that: 1) is intended as an implant and presents a potential for serious risk to the health, safety, or welfare of a subject; 2) Is purpoted or represented to be for a use in supporting or sustaining human life and presents a potential for serious risk to the health, safety, or welfare of a subject. 3) is for a use of substantial importance in diagnosising, curing, mitigating, or treating disease, or otherwise preventing impairment of human health and presents a potential for serious risk to the health, safety, or welfare of a subject. or 4) Otherwise presented a potential for serious risk to the health safety, or welfare of a subject.
What is a transitional device?
a device subject to 520(l) of the act that is a device that FDA considered to be a new drug or antiboitic before MAY 28 1976.
What is a device?
A device, other than a transitional device, in commercial distribution immediately before May 28 1976 when used for investigated in accordance with the indications in labeling in effect at that time.
Investigational Plan should include:
a) purpose b) protocol c) risk ananlysis d) description of device e) monitoring procedures. f) labeling g consent materials h) IRB information i) Other institutions j) additional records and reports.
What types of changes would require a supplemental application?
1) Changes in investigational plan 2) Changes effected for emergency use 3) Changes effected with notice to FDA within 5 days. 4) Changes submitted in annual report.
Can a sponsor make certain changes without prior approval of a supplemental application?
Yes – but the sponsor must notified the FDA within 5 days of the changes going in to effect.
What types of changes can the sponsor make w/o prior approval on a supplemental application?
1) Developmental changes, including manufacturing changes that do not constitute a significant change in design or basic operation and are made based on basic information gathered during the investigation. 2) Changes to clinical protocol that do not affect validity of data, scientific soundness, or the rights safety, and welfare of human subject. 3) Definition of credible information 4) Notice of IDE change
What are the responsibilities of Sponsors as outlined in subpart C?
1) Gaining FDA and IRB approval before beginning the investigation 2) Selecting investigators and monitors 3) Informing investigators 4) monitoring investigations 5) Emergency Research