ICH E6 Good Clinical Practice Flashcards
Purpose of GCP
Gives standard for designing, conducting, recording, and reporting clinical trials
What does GCP provide (3 things)
- provides public assurance that rights, safety, and well-being of trial subjects are protected and consistent with principles in Declaration of Helsinki
-provide unified standard for different regulatory authorities
– facilitate mutual acceptance of clinical data
IRB primary responsibility
Safeguard the rights, safety, and well being of trial subjects
IRB provides investigators written what?
Approval,
Modifications required to prior approval,
Disapproval,
Termination/suspension of any prior approval
IRB conducts _________________ review annually
continuing review
-intervals appropriate to degree of risk to human subjects
*but at least one per year
Describe how GCP standards for subject payment (x3)
-amount and method of payment that doesn’t present coercion or undue influence
-Should be prorated and not contingent on completion of trial
-Payment information written in ICF
IRB Composition
At least 5 members
-1 primary area is non scientific
-1 independent of trial site
1) IRB requirements for making decisions (x2)
2) IRB SOPs, decision, and composition must be in what form?
1) Make decisions at ANNOUNCED meetings that has QUORUM (majority)
2) Written
Investigator promptly reports to IRB (x3)
- Deviations from protocol (when necessary to eliminate immediate hazards to subjects)
- Changes increasing risk to subjects or affecting significantly conduct of trial
- ADRs that are serious and unexpected
IRB promptly reports what to investigator?
- Trial related decisions and opinions
- Reasons for decision
- Procedures to appeal
*all in writing
IRB retains records for how long?
at least 3 years after completion of trial
Investigator is
1) Qualified by:
2) Shows qualifications by:
3) Must be familiar with:
1) education, training, and experience and meet all regulatory requirements
2) Up to date CV
3) Proper use of IP, protocol, IB, and be aware and comply with GCP and regulatory requirements
Investigator must allow sponsor and authorities ability to (x3) _____________ clinical trial records
to monitor, audit, and inspect
No deviations of protocol should be initiated without 1)____________.
2) Exception
1) Prior written approval from the IRB
2) when necessary to eliminate immediate hazards to subjects or change involving logistical or administerial aspects
What is the delegation of duty log? And who keeps it?
List of appropriately qualified persons to whom the investigator has delegated significant trial related duties (DoD Log)
Maintained by investigator
Investigator must demonstrate adequate resources for trial, name these resources
a. Demonstrate potential for recruiting required number of subjects within recruiting period
b. Have sufficient time to properly conduct and complete trial
c. Have adequate number of qualified staff and facilities for foreseen duration of trial
d. Ensure all persons assisting in trial are adequately trained on protocol, IP, an trial related duties
At a site, who is Responsible for supervising any individual or party with trial related duties at the site?
Principle Investigator
Who is responsible for all trial related medical decisions?
A qualified physician, who is an investigator or a sub-investigator for the trial, should be responsible for all trial-related medical (or dental) decisions
Should subject’s primary physician be informed of trial participation?
Recommended that investigator informs subjects primary physician about the subjects participation in trial IF SUBJECT AGREES
What happens if subject withdraws from study?
Investigator makes reasonable effort to ascertain the reason why subject withdraws from trial
*not required by subject to give reason
Who is responsible for communicating with the IRB?
Investigator
What is needed from IRB before enrolling a subject?
written and dated approval from IRB regarding:
-protocol, ICFs, subject recruitment procedures, and any other written information provided to subjects
Who provides IRB with updated IB?
Investigator
Who is responsible for updating the IB
The sponsor
When is it ok for Investigator to deviate from the protocol?
-Agreement by sponsor and prior approval from IRB
-EXCEPT when necessary to eliminate an immediate hazard to subjects of when changes involves logistical or administrative aspects of trial (change in monitor, change in phone number
If a protocol deviation occurs, what steps does the investigator take?
ASAP notify
a) the IRB/IEC for review and approval/favorable opinion,
b) to the sponsor for agreement
c) to the regulatory authorities (if required)
When the investigator notifies the IRB, sponsor, and regulatory authorities (if required) of a protocol deviation, what should be in this notification?
-Include the implemented deviation or change, the reasons for it, and, if appropriate, the proposed protocol amendment(s)
Investigator has what IP responsibilities on site:
-Maintain records of product delivery, inventory on site, use by subject, return and destruction records, IP stored properly on site
-reconcile all IP received from sponsor
-train subject on proper use and make sure they are using it correctly
IP storage and use is determined by who?
Sponsor
Investigator has what responsibilities to subject and IP use?
That subject were provided doses specified in protocol, explain correct use of IP to subject, and check if subject is following instructions properly
What happens if there is important new information available that may be relevant to the subject’s willingness to continue participation in the trial?
1) revise ICF
2) the revised ICF should receive IRB/IEC’s approval/favorable opinion in advance of giving to the subject
3) The subject or LAR should be informed in a timely manner
4) revised ICF must be signed before continuing research
*communication of this information should be documented.
Language in the ICF should follow what rules relating to the subject? (two)
1) should not cause subject to waive any legal rights, or releases or appear to release investigator, institution, sponsor, or agents of liability for negligence
2) non-technical as practical and should be understandable
Before informed consent may be obtained the investigator should provide the subject or LAR:
-ample time and opportunity to inquire about details of the trial and to decide whether or not to participate in the trial.
-All questions about the trial should be answered to the satisfaction of the subject or the subject’s
The ICF, before subject does any study procedures, should be:
signed and personally dated by subject/LAR and person who conducted ICF discussion BEFORE ANY STUDY PARTICIPATION OCCURS
*Prior to participation in the trial the subject or LAR should receive a copy of the signed and dated written informed consent form
If subject or LAR is unable to read the ICF:
-an impartial witness should be present during the entire informed consent discussion.
-AFTER subject/LAR orally consents and, if able, signs/dates ICF impartial witness should sign and personally date ICF
When impartial witness signs the ICF, they are attesting that:
the information in the consent form accurately explained to, and
apparently understood by, the subject or LAR, and that
informed consent was freely given by the subject or LAR
ICH should contain
i. Trial is research
ii. Purpose
iii. Treatment and probability for random assignment
iv. Trial procedures
v. Subjects responsibilities
vi. Aspects of trial that are experimental
vii. Reasonably foreseeable risks
viii. Reasonably expected benefits
ix. Alternative treatments
x. Compensations/treatment available in event of trial related injury
xi. Anticipated payment
xii. Anticipated expenses
xiii. Subject participant is voluntary
xiv. Monitor, auditor, IRB, and regulatory authored who will be granted direct access to subjects medical records to verify trial procedures and data – and the subject is authorizing this access
xv. Records identifying subject are confidential
xvi. Subject will be informed in a timely manner if info becomes available that may be relevant to subjects willingness to continue trial
xvii. Person to contact for further info regarding trial and rights of subjects, and whom to contact for trial related injury
xviii. Foreseeable circumstances and reasons which trial may be terminated
xix. Expected duration of subjects participation in trial
xx. Approximated number of subjects in trial
Prior to trial participation, subject should receive (what form):
copy of signed and dated ICF
*signed and dated by subject or LAR and person performing consent
If prior consent by subject is not available (emergency situation), what do you do?
1) LAR consent
2) If LAR not available - require measures described in IRB approved protocol
3) The subject or LAR should be informed about the trial as soon as possible and CONSENT TO CONTINUE in study
source documents should be (6 things)
Attributable, legible, contemporaneous, original, accurate, and complete
who is responsible for maintaining source documents?
Investigator
Any change or corrections in CRF should be (4 things)
dated, initialed, and explained, and not obscure original entry
Essential documents are retained for how long at site?
- who is responsible for informing when documents are no longer needed?
2 years after last approval of marketing application
Or at least 2 years since formal d/c of clinical development of IP
*Can be retained for longer if required by regulatory authorities or by agreement with sponsor
Whos informs who when essential documents are no longer needed to be stored?
Sponsor inform investigator
Who provides written summaries of trial status to IRB annually?
Investigator
Investigator promptly provides written reports to 1)________ and 2)_________on any changes significantly affecting conduct of trial or increasing risks to subjects
1) sponsor
2) IRB
All unexpected serious adverse events (SAEs) should be reported immediately to the 1) ____________
These reports should identify subjects by 2) __________ assigned to the trial subjects rather than by the subjects’ names, personal identification numbers, and/or addresses.
The investigator should also comply with the 3)___________related to the reporting of unexpected serious adverse drug reactions to the regulatory authority(ies) and the IRB/IEC.
1) Sponsor
2) unique code numbers
3) applicable regulatory requirement(s)
Investigator reports all unexpected SAES to:
sponsor
*depending on regulatory requirements also to regulatory authorities and IRB
ADR reporting
1) Investigators report to the sponsor
2) Sponsors report to regulatory authorties:
3) Sponsors should also inform investigators:
4) Investigators and sponsors report to the IRB:
1) All ADRs
2) Any ADRs that are both serious and unexpected
3) Any new observations regarding the drug, especially AEs and safe use concerns
4) All unanticipated SAEs
When a study subject dies, the investigator supplies the 1)_________ and 2)__________ with what?
1)sponsor
2)IRB
additional requested info (autopsy, terminal medical reports)
If trial is prematurely terminated or suspended for any reason, the investigator should (x3)
1) promptly inform the trial subjects
2) assure appropriate therapy and follow-up for the subjects,
3) inform the regulatory authorities (if required)
If investigator terminates or suspends a trial without prior agreement of the sponsor, the investigator should (x3)
1) should promptly inform the sponsor
2) should promptly inform the IRB/IEC,
3) provide the sponsor and the IRB/IEC a detailed written explanation of the termination or suspension
*also per GCP 4.12.1 promptly inform the trial subjects, assure appropriate therapy and follow-up for the subjects, and inform the regulatory authorities (if required)
If the sponsor terminates or suspends a trial the investigator should (x2)
1) promptly inform the IRB/IEC
2)provide the IRB/IEC a detailed written explanation of the termination or suspension.
*also per GCP 4.12.1 promptly inform the trial subjects, assure appropriate therapy and follow-up for the subjects, and inform the regulatory authorities (if required)
If the IRB/IEC terminates or suspends its approval/favorable opinion of a trial the investigator should: (x2)
1) should promptly notify the sponsor
2) provide the sponsor with a detailed written explanation of the
termination or suspension
*also per GCP 4.12.1 promptly inform the trial subjects, assure appropriate therapy and follow-up for the subjects, and inform the regulatory authorities (if required)
Upon completion of the trial, the investigator should provide final report to: (x2)
1) provide the IRB/IEC summary of the trial’s outcome,
2) regulatory authorities with any report required
Who is responsible for study quality management and assurance?
Sponsor
Study Quality Management includes:
DELETE
The design of efficient clinical trial protocols and tools and procedures for data collection and processing and collection of info essential to decision making
Ensure all aspects of trial are operationally and unnecessarily complex
Who identifies risks to critical trial processes and data?
Sponsor
Quality Assurance and Control. What is it, how is it achieved, and who is responsible?
-systematic process used to determine if research is accurate and complete and the results are consistent with established protocol and procedures
- achieved by implementing and maintaining quality assurance control systems with written SOPs
-sponsor