ICH E6R1 Good Clinical Practice Flashcards
Good Clinical Practice (GCP)
An international ethical and scientific quality standard for ____, ____, ____ and ____ trials that involve the participation of human subjects.
An international ethical and scientific quality standard for designing, conducting, recording and reporting trials that involve the participation of human subjects.
GCP Compliance Assurance, Aspects (2)
- Rights, safety and well-being of trial subjects are protected (DoH Principles)
- Clinical trial data are credible
ICH GCP Mutual Acceptance Jurisdictions (3+2)
Original Jurisdictions E6(R1):
1. United States
2. European Union
3. Japan
Additional Jurisdictions E6(2):
1. Canada
2. Switzerland
E6(R1) vs E6(R2) ICH GCP Guidelines
E6(R1): Largely paper-based
E6(R2): Electronic data recording and reporting
Applicable Regulatory Requirement(s)
Any laws and regulations addressing the conduct of clinical trials of investigational products.
IRB Approval, Constrained Criteria (4)
The affirmative decision of the IRB that the clinical trial has been reviewed and may be conducted at the institution site within the constrains set forth by:
- the IRB
- the institution,
- GCP, and
- applicable regulatory requirements
Audit, Aspects (2)
A systematic and independent examination of trial related activities and documents to determine whether
- the conduct of the evaluated trial related activities, and
- the recording, analysis and reporting of data
are in compliance according to the protocol, sponsor’s SOPs, GCP, and the applicable regulatory requirements.
Audit Certificate
A declaration of confirmation by the auditor that an audit has taken place.
Audit Report
A written evaluation by the sponsor’s auditor of the results of the audit.
Audit Trail
Documentation that allows reconstruction of the course of events.
Blinding / Masking
A procedure in which one or more parties to the trial are kept unaware of the treatment assignments.
Single-blinding: usually refers to the subjects being unaware.
Double-blinding: usually refers to the subjects, investigator, monitor, and in some cases, data analysts being unaware of the treatment assignments.
Case Report Form (CRF)
A document designed to record all of the protocol required information to be reported to the sponsor on each trial subject.
Clinical Trial/ Clinical Study, Qualifiers (3)
Any investigation in human subjects intended to:
- Discover or verify the clinical, pharmacological, and/or other pharmacodynamic effects,
- Identify any adverse reactions,
- Study absorption, distribution, metabolism and excretion (ADME)
of an object of ascertaining its safety/efficacy.
Note: The terms clinical trial and clinical study are synonymous.
Clinical Trial/Study Report
A written description of a trial of any therapeutic, prophylactic, or diagnostic agent conducted in human subjects, in which the clinical and statistical description, presentations, and analyses are fully integrated into a single report.
Comparator Product
An investigational or marketed product (active control), or placebo, used as a reference in a clinical trial.
Trial Compliance
Adherence to all the trial-related requirement, GCP requirements, and applicable regulatory requirements.
Confidentiality
Prevention of disclosure, to other than authorized individuals, of a sponsor’s proprietary information or of a subject’s identify.
Contract
A written, dated, and signed agreement between two or more involved parties that sets out any arrangement on delegation and distribution of tasks and obligations and, if appropriate, on financial matter.
The protocol may serve as the basis of a contract.
Coordinating Committee
A committee that a sponsor may organize to coordinate the conduct of a multi-center trial.
Coordinating Investigator
An investigator assigned the responsibility for the coordination of investigators at different centers participating in a multi-center trial.
Contract Research Organization (CRO)
A person or an organization (commercial, academic, or other) contracted by the sponsor to perform one or more of a sponsor’s trial-related duties and functions.
Direct Access
Permission to examine, analyze, verify, and reproduce any records and reports that are important to evaluation of a clinical trial (Essential Documents).
Documentation for Clinical Trial, General Content (3)
All record, in any form (written, electronic, x-rays, etc) that describe or record
- the methods, conduct, and results of a trial,
- the factors affecting a trial,
- the actions taken from a trial.
Essential Documents
Documents which individually and collectively permit evaluation of the conduct of a study and the quality of the data produced.
Independent Data-Monitoring Committee/
Data and Safety Monitoring Board/
Monitoring Committee/
Data Monitoring Committee,
Duties (3)
An independent data-monitoring committee that may be established by the sponsor to assess at intervals:
- the progress of a clinical trial,
- the safety data,
- the critical efficacy endpoints,
to recommend to the sponsor whether to continue, modify, or stop a trial.
Impartial Witness
A person, who is independent of the trial, who cannot be unfairly influenced by people involved with the trial (“impartial”),
who attends the informed consent process if the subject or the subject’s legally acceptable representative cannot read, and who read the informed consent form and any other written information supplied to the subject (“witness”).
Independent Ethics Committee, Reviewing Aspects (4)
An independent body, whose responsibility it is to ensure the protection of the rights, safety and well-being of human subjects involved in a trial, and provide public assurance of that protection, by reviewing and approving:
- the trial protocol,
- the suitability of the investigator(s),
- facilities, and
- informed consent process
Direct Access, Aspects with Precautions (2)
Any party (i.e., regulatory authorities, sponsor’s monitors, and auditors) with direct access should take all reasonable precautions within the constrains of the applicable regulatory requirement to maintain:
- the confidentiality of subject’s identities, and
- the sponsor proprietary information.
Informed Consent
A process by which a subject voluntarily conforms his or her willingness to participate in a particular trial, after having been informed of all aspects of the trial that are relevant to the subject’s decision to participate.
Informed consent is documented by means of a written, signed, and dated informed consent form.
Inspection
The act by a regulatory authority of conducing an official review of
documents, facilities, records, and any other resources that are deemed by the authority to be related to the clinical trial, and
that may be located at the site of the trial, at the sponsors’s and CRO facilities, or at other establishments deemed appropriate by the regulatory authority.
Medical Institution
Any public or private
entity/agency/facility
where clinical trials are conducted.
Institutional Review Board (IRB), Responsibilities (2)
An independent body constituted of medical, scientific and others, whose responsibility is to ensure the protection of the rights, safety and well-being of human subjects involved in a trial by, reviewing and approving
- the trial protocol and amendments
- informed consent process.
Interim Clinical Trial/Study Report
A report of intermediate results and their evaluation based on analyses performed during the course of a trial.
Investigational Product, Qualifying Scenarios (4)
A pharmaceutical form of an active ingredient or placebo being tested or used as a reference in a clinical trial, including
- Pre-market approval product
- Product with a marketing authorization but its assembly (formulation/packaging) is different than the approved form
- Product with a marketing authorization but its use (indication) is different than the approved form
- Product with a marketing authorization is used to gain further information about the approved use.
Investigator
A person responsible for the conduct of the clinical trial at a trial site.
If a trial is conducted by a team of individuals at a trial site, the investigator is the responsible leader of the team (Principal Investigator, PI).
Investigator’s Brochure, Definition
A compilation of the clinical and nonclinical data on the investigational product, relevant to the study in human subjects.
Legally Acceptable Representative
An individual, juridical or other body authorized under applicable law to consent, on behalf of a prospective subject, to the subject’s participation in the clinical trial.
Clinical Trial Monitoring
The act of overseeing the progress of a clinical trial, and of ensuring that it is conducted, recorded in accordance with the protocol, SOPs, GCP, and the applicable regulatory requirements.
Monitoring Report
A written report from the monitor to the sponsor after each site visit, or other trial-related communication according to the sponsor’s SOPs.
Multicenter-trial
A clinical trial conducted according to a single protocol but at more than one site, and therefore, carried out by more than one investigator.
Nonclinical Study
Biomedical studies not performed on human subjects.
Protocol, Sections (5+2)
A document that describes:
- objective,
- design,
- methodology,
- statistical considerations, and
- organization of a trial,
also usually gives:
- background
- rationale
Protocol Amendment
A written description of changes to or formal clarification of a protocol
Quality Assurance (QA),
All those planned and systematic actions that are established to ensure that:
- the performance of the trial, and
- the generation, documentation, and reporting of data
are in compliance with GCP and applicable regulatory requirements.
Quality Control (QC)
The operational techniques and activities undertaken within the quality assurance system,
to verify that the requirements for quality of the trial-related activities have been fulfilled.
Randomization
The process of assigning trial subjects to treatment or control groups using an element of chance to determine the assignments in order to reduce bias.
Regulatory Authority, Duties (2)
The authorities that
- review submitted clinical data
- conduct inspections
Source Data
All information in original records (or certified copies) of clinical findings, observations, or other activities in a clinical trial necessary for the reconstruction and evaluation of the trial.
Source data are contained in source documents.
Source documents, Examples (7)
- Hospital records
- Clinical charts
- Laboratory notes
- Subject’s diaries
- Evaluation checklist
- Pharmacy records
- Digital records
Sponsor
An individual, company, institution, or organization which takes responsibility for the initiation, management, and financing of a clinical trial
Sponsor-Investigator
An individual (not a company, institution, or organization) who both initiates and conducts a clinical trial.
Standard Operating Procedure (SOPs)
Detailed, written instructions to achieve uniformity of the performance of a specific function.
Sub-Investigator
An individual member of the clinical trial team designated and supervised by the investigator at trial site to perform critical trial-related procedures and to make important trial-related decisions.
Typically include associates, residents, research fellows.
Trial Subject
An individual who participates in a clinical trial, either as a recipient of the investigational products or as a control
Subject Identification Code
A unique identifier assigned by the investigator to each trial subject to protect the subject’s identify and used in lieu of the subject’s name when the investigator report adverse events and other trial related data.
Trial Site
The location where trial-related activity are actually conducted.
Vulnerable Subjects Unduly Influences (2)
Individuals whose willingness to volunteer in a clinical trial may be unduly influenced by:
- the expectation, whether justified or not, of benefits associated with participation.
- a retaliatory response from senior members of a hierarchy in case of refusal to participate.
Vulnerable Subject Examples (3)
- Unduly influence by expectation of benefits: members of a disadvantageous status (health, age, financial, emergency, ethnic, political)
- Unduly influence by retaliatory response: members of a group with a hierarchical structure (students, employees, soldiers, prisoners)
- Person incapable of giving consent.
Well-being of the Trial Subject, Aspects (2)
The physical and mental integrity of the subjects participating in a clinical trial.
Certified Copy, Verification Methods (2)
A copy of the original record that has been verified to have the same information, including data that describe the context, content, and structure, as the original, by
- a dated signature
- generation through a validated process
Monitoring Plan
A document that describes the strategy, methods, responsibility, and requirements for monitoring the trial.
Validation of Computerized Systems, Principles (2)
A process of establishing and documenting that the specified requirements of a computerized system can be consistently fulfilled from design until decommissioning of the system or transition to a new system. The approach to validation should be based on a risk assessment that takes into consideration of the system’s:
- intended use
- potential to affect human subject protection and the reliability of trial results.
The Principles of ICH GCP, Clinical Trial Requirement (13)
Subject Protection Principal (5)
Sponsor Principal (3)
Investigator Principal (5)
Clinical trial requires:
Subject protection Principal:
1. DoH, GCP ARR compliance
2. prior IRB/IEC approval
3. Risk vs Benefit justification
4. Prevailing right, safety, and well-being of trial subjects over other interests
5. Quality assurance system for human subject protection and trial reliability
Sponsor
6. Adequate supporting information on the investigational product
7. Scientifically sound and well-written protocol
8. Good manufacture practice (GMP) for investigational products
Investigator
9. Qualified physician for medical care
10. Qualified individual for conducting trial
11. Freely given informed consent
12. Proper data management
13. Subject privacy confidentiality
IRB/IEC Responsibilities (9)
Procedures (5)
Consent Ethics (2)
Payment (2)
Procedure
1. Safeguard the right, safety and well-being of trial subjects
2. Obtaining trial related documents
3. Consider qualifications of the investigator
4. Review human subject risk at least once per year
5. Request additional information meaningful to subject protection
Consent Ethics
6. Determine the ethical compliance for trials with consent from legally acceptable representative
7. Determine the ethical compliance for trials without possible consent
Payment
8. Assure payment is free of coercion or undue influence to subject
9. Ensure payment is communicated clearly to the subjects
Clinical Trial Related Documents for IRB (9)
- Protocol (and amendment)
- Informed consent form (and consent updates)
- Subject recruitment (procedures and advertisement)
- written information for subjects
- Investigators Brochure
- Safety Information
- Payment and Compensation
- Investigator’s CV
- Others
Compensation Payment
Payment to a subject should be prorated and not wholly contingent on completion of the trial by the subjects.
IRB/IEC Decision, Types (4)
- Approval
- Modifications required prior to approval
- Disapproval
- Termination
approval = favorable opinion
disapproval = negative opinion
Composition of IRB, Minimum Criteria (3)
- at least 5 members
- at least one member whose primary area of interest is in a nonscientific area
- at least one member who is independent of the institution or trial site
May invite nonmembers with expertise in special areas for assistance.
IRB Voting Member, Criteria (2)
Voting IRB members on a trial-related matter should:
- be independent of the investigator and the sponsor of the trial
- have participated in the IRB review and discussion
Investigators may provide information on any aspect of the trial, but should not participate in the deliberations or voting.
IRB Function, Expectations (3)
IRB should:
- perform its functions according to written operating procedures
- maintain records of its activities and minutes of meetings.
- comply with GCP and ARR
IRB Decision Quorum
An IRB should make its decisions at announced meetings at which at least a puorum (minimum number), as stipulated in its written operating procedures.
IRB Procedures (9)
Review Procedures (5)
Review Specification (4)
Review Procedures:
1. Determining composition (name and qualification)
2. Scheduling and conduct meetings (time and location)
3. Conducting review of trials
4. Determining the frequency of continuing review
5. Providing expedited review and approval of minor changes
Review Specification:
6. Specifying that no subject should be admitted to a trial before approval
7. specifying that no deviation of protocol should be made without approval
8. specifying that investigator should promptly report to IRB when deemed necessary
9. ensuring that IRB promptly notify in writing when deemed necessary
Protocol Deviation, Amendment Exemptions (2)
No protocol deviation should be made expect for when,
- necessary to eliminate immediate hazards to the subjects
- the changes involves only logistical or administrative aspects of the trial (changes of monitors or phone numbers)
Investigator Prompt Notification to IRB (4)
- Serious and unexpected ADRs
- Protocol deviation to eliminate immediate hazards to subjects
- Any adverse effect to protection of the subject
- Any adverse effect to conduct of the trial
IRB Prompt Notification to Investigator (3)
- Trial-related opinions
- Reasons for its decision
- Procedures for appeal
IRB Records, Examples (6)
- written procedures
- membership lists
- occupation/affiliation of member
- submitted documents
- minutes of meetings,
- correspondence
All record maintained for at least 3-years after completion of the trial
Investigators Qualification, Criteria (3)
- Qualified by education, training, and experience to assume responsibility for the proper conduct of the trial
- Meet all the qualifications specified by the applicable regulatory requirements
- Provide evidence of such qualification through up-to-date CV and other requested documents
Investigators Agreement, Aspects (4)
Investigator should
- be thoroughly familiar with the appropriate use of investigational product provided by the sponsor
- comply with GCP and ARR
- permit monitoring and auditing by the sponsor, and inspection by the regulatory authorities.
- maintain a list of qualified persons for delegation
Investigators Adequate Resources (3)
The investigator should:
- be able to demonstrate a potential for recruiting the required number of suitable subjects (based on retrospective data)
- have sufficient time to properly conduct and complete the trial
- have adequate number of qualified staff and facilities
Investigator Delegation Responsibilities (3)
- Ensure all persons assisting the trial have adequate information on the protocol, investigational product, and trial-related duties and functions
- Supervise any individual or party to whom the investigator delegates
- Implement procedures to ensure the integrity of the trial-related duties and functions performed and any data generated by the retained services
Investigator Responsibilities for Medical Care of Trial Subject (4)
- Ensured all trial-related medical decision made by a qualified physician who is a PI/Sub-I.
- ensure adequate medical care is provided for any AE related to the trial.
- inform the subject’s primary physician about the subject’s participation in the trial upon agreement by the subject.
- Make reasonable effort to ascertain the reasons for subjects to withdraw prematurely from a trial, while respecting their rights
Investigator Communication with IRB (3)
- Before trial initiation, during application, provide IRB with Investigator’s Brochure and its updates.
- Before trial initiation, obtain IRB approval of reviewed trial documents.
- During the trial, continue to provide IRB all update documents subject to review.
Investigator Protocol Compliance Assurance (4)
The investigator should conduct the trial in compliance with the protocol, which need to be:
- Approved by sponsor, ARR, and IRB
- free of deviation without IRB approval (with 2 exceptions)
- documented and explained for any deviation
- amended and submitted to sponsor, ARR, and IRB for approval.
Investigator Investigational Products, Responsibilities (6)
Investigator is responsible for:
- overall accountability of the investigational product at the trial site.
- assign some or all of the accountability to an appropriate pharmacist, if allowed/required
- Maintains record of the investigational products
- Proper storage as specified by the sponsor or ARR
- Ensure the investigational products are only used in accordance with the approved protocol
- Explain and follow up on the correct use of the investigational products to subject
Investigational Products, Logistic Records, Examples (4)
Investigator should maintains the following record of the investigational products:
- Delivery record to trial site
- inventory at the site
- use by each subject
- return to the sponsor or alternative disposition of unused products
All investigational products received from the sponsor should reconcile.
Investigators Randomization Responsibilities (2)
The investigator should:
- follow the trial’s randomization procedures, and 2. ensure that the code is broken only in accordance with the protocol.
Investigators Unblinding Responsibilities, Scenarios (2)
The investigator should promptly document and explain to the sponsor any premature unblinding of the investigational products for:
- accidental unblinding
- unblinding due to a serious adverse events
Investigator Responsibilities for Informed Consent of Trial Subjects (15)
General Compliance (2)
Informed Consent Form Language (4)
Informed Consent Discussion (5)
Consent by Representative (4)
General Compliance
1. Obtain informed consent in compliance to ARR, GCP, DoH, and the approval by IRB.
2. Revise informed consent form with relevant and important information, and inform IRB and subject for new approval and consent
Informed Consent Language:
3. Ensure no coercion or unduly influence in trial participation or continuation.
4. Ensure language causes no waiving of any legal rights of subject or releases trial from liability for negligence.
5. Ensure language is as non-technical as practical to be understood by the subjects/representative/ witness.
6. Fully inform all pertinent aspects of the trial.
Informed Consent Discussion:
7. Ensure the information was accurately and effectively explained by impartial witness if needed.
8. Ensure the all components (20) of ICF is explained during the discussion.
9. Provide opportunities to inquire more details and answers to the satisfaction of subject.
10. Ensure that ICF is signed and dated.
11. Ensure copy of the signed and dated written ICF and its updates received by the subjects
Consent by representative:
12. Ensure that subject personally agree and sign if capable the ICF, despite consent from the legally acceptable representative.
13. Non-therapeutic trial with no direct clinical benefit should generally be consented only by subject themselves, not by representatives
14. Non-therapeutic trials may only be consented by legally acceptable representatives under certain conditions.
15. When consent from neither subject or representative is possible, enrollment of the subject will require IRB approval.
Components in the Informed Consent Form (20)
Nature of the trial (3)
Study Design (5)
Risk and Benefit (4)
Compensation and expense (3)
Subject Protection (3)
Subject Communication (2)
The ICF should state:
The nature of the trial:
1. the trial involves research
2. the purpose of the trial
3. invasive and non-invasive trial procedures
The Study Design:
4. the experimental aspects of the trial
5. expected duration of the subject participation
6. approximate number of subjects involved
7. the trial treatments and probability for random assignment for each treatment
8. foreseeable circumstances for participation termination
Risk and benefit for subject:
9. responsibilities of the subject
10. reasonably foreseeable risks or inconveniences
11. reasonably expected benefits, or whether benefits exists
12. the risk and benefits of alternative procedures/treatment available
Subject Compensation and expense:
13. compensation and treatment in event of trial-related injury
14. anticipated prorated payments to the subject if any
15. anticipated expense to the subject if any
Subject Protection:
16. the subjects participation and continuation is voluntary without penalty
17. direct access to the subject’s original medical records without violating the confidentiality of the subject
18. records identifying the subjects will be kept confidential
Subject Communication:
19. subject will be informed timely if new information affect subject’s willingness to continue
20. person(s) to contact for trial related activities, subject rights, and injuries.
Direct Access, Parties (4)
- monitor
- auditor
- IRB
- regulatory authority
Legally Acceptable Representative Senarios, Example (2)
- minors
- patients with severe dementia
Legally Applicable Representative Consent Exception for Non-therapeutic Trials, Requirement (1+3+1)
Non-therapeutic trials must be conducted in subjects with consent from subject themselves, not from a legally acceptable representative unless:
the are required by design (1), poses minimum risk or burden (3), mandated by IRB (1)
- the objectives of the trial cannot be met by means of a trial in subjects who can give informed consent personally
- the foreseeable risks to the subjects are low
- the negative impact on the subject’s well-being is minimized and low
- the trial is not prohibited by law
- the approval of IRB is expressly sought on inclusion of the subject.
Investigator Records, Requirements (2)
- sources documents and trial records are adequate and accurate
- source data is attributable, legible, contemporaneous, original, accurate, traceable, and complete.
Investigator Case Report Form (CRF), Responsibilities (7)
Data (3)
Documents (4)
Data, derived data, changed data:
1. Ensure accuracy, completeness, legibility, and timeliness of all data
2. Ensure consistency or explain discrepancies for data derived data from source documents
3. Date, initial and explain any changes according to sponsor guidance.
Essential Documents:
4. Maintain and safeguard the Essential Documents
5. Retain Essential Documents until at least 2-years after the last approval of a marketing application, or clinical development discontinuation.
6. Document financial aspects in an agreement between sponsor and investigator
7. Make records available for monitor, auditor, IRB, and regulatory authority upon request.
Investigator Progress Reports, Requirements (2)
- submit summary of trial status to IRB at least annually
- promptly provide written reports to sponsor, IRB, and institution on any changes significantly affecting the conduct of the trial or increasing the risk to subjects.
Investigator Safety Reporting (3)
- Immediately report serious and unexpected AE to sponsor, followed by detailed report.
- Other AE identified in the protocol as critical to safety evaluations should be reported to sponsor accordingly.
- Report death event to the sponsor and IRB with any autopsy report, terminal medical report, and other requested information.
Investigator Responsibility During Premature Termination or Suspension of a Trial (3)
- promptly inform the trial subjects
- assure appropriate therapy and follow-up for the subject
- inform the regulatory authorities when applicable
Investigator Trial Completion Report (3)
Upon completion of the trial, the investigator should
- inform the institution
- provide a summary of trial outcome to IRB
- provide requested report regulatory authorities