ISO14155:2011 Flashcards
What does ISO14155 overall address?
This International Standard addresses good clinical practice for the design, conduct, recording and reporting of clinical investigations carried out in human subjects to assess the safety or performance of medical devices for regulatory purposes.
This International Standard specifies general requirements intended to (Name 4)
- protect the rights, safety and well-being of human subjects,
- ensure the scientific conduct of the clinical investigation and the credibility of the clinical investigation results,
- define the responsibilities of the sponsor and principal investigator, and
- assist sponsors, investigators, ethics committees, regulatory authorities and other bodies involved in the conformity assessment of medical devices.
True or False
ISO does apply to in vitro diagnostic medical devices.
FALSE
Define adverse device effect (ADE)
adverse event related to the use of an investigational medical device
Note 1 to entry: This definition includes adverse events resulting from insufficient or inadequate instructions for use, deployment, implantation, installation, or operation, or any malfunction of the investigational medical device.
Note 2 to entry: This definition includes any event resulting from use error or from intentional misuse of the investigational medical device.
Definition of Medical Device according to ISO
any instrument, apparatus, Implement, machine, appliance, Implant, software, material, or other similar or
related article
a) intended by the manufacturer to be used, alone or in combination, for human beings for one or more of
the specific purpose(s) of
1) diagnosis, prevention, monitoring, treatment or alleviation of disease,
2) diagnosis, monitoring, treatment, alleviation of, or compensation for, an injury,
3) investigation, replacement, modification, or support of the anatomy or of a physiological process,
4) supporting or sustaining life,
5) control of conception,
6) disinfection of medical devices, and
B) which does not achieve its primary intended action in or on the human body by pharmacological,
immunological or metabolic means, but which may be assisted in its intended function by such means
Yes/No
When talking about the term medical devices, does it include in vitro diaognistic medical devices?
No - it doesn’t include in vitro diagnostic medical devices
Define USADE
unanticipated serious adverse device effect
serious adverse device effect which by its nature, Incidence, severity or outcome has not been Identified in the
current version of the risk analysts report
**NOTE **Anticipated serious adverse device effect (ASADE) Is an effect which by Its nature, incidence, severity or
outcome has been Identified in the risk analysis report.
Define IB
Investigator’s brochure
compilation of the current clinical and non-clinical Information on the investlgational medical device(s),
relevant to the clinical investigation
Define Malfunction
failure of an lnvestlgational medical device to perform in accordance with Its intended purpose when used in
accordance with the Instructions for use or CIP
What is a Use Error?
act or omission of an act that results in a different medical device response than Intended by the manufacturer
or expected by the user
NOTE 1 Use error Includes slips, lapses, and mistakes.
NOTE 2 An unexpected physiological response of the subject does not in Itself constitute a use error.
What is the most important consideration in any trial?
Clinical Investigations shall be conducted In accordance with the ethical principles that have their origin In the
Declaration of Helsinki (see Reference [8]). These principles protect the rights, safety and well-being of human
subjects, which are the most important considerations and shall prevail over interests of science and society.
These principles shall be understood, observed, and applied at every step in the clinical investigation
Can you compensate subjects in a clinical investigation?
Compensating subjects for costs resulting from participation in the clinical Investigation (e.g. transportation)
**may be appropriate if allowed by national regulations, but the
compensation shall not be so large as to unduly
encourage the subjects to participate.
True or Fale
Arrangements for additional health care for subjects who suffer from an adverse event as a result of
participating In the clinical investigation shall be made and documented.
True
True/False
With regards to the EC, if regional EC requirements are less strict than the requirements of this International Standard, the
sponsor shall apply the requirements of this International Standard to the greatest extent possible, Irrespective
of any lesser requirements, and shall record such efforts.
True
What information should be submitted to the EC at a minimum in the inital submission? (10 items)
a) CIP;
b) IB or equivalent documentation;
c) informed consent form and any other written information to be provided to subjects;
d) procedures for recruiting subjects and advertising materials, if any;
e) a copy of the curriculum vitae (CV) of the principal lnvestigator(s) for which the EC has oversight.
The following documents might also need to be provided to the EC depending on the clinical investigation
design and national or regional requirements:
f) sample or draft CRFs, Including other data collection tools, as required by the CIP;
g) documents related to payments and compensation available to subjects;
h) proposed compensation to the institution or principal Investigator;
i) documentation related to any conflict of interest, including financial, on the part of an Investigator;
j) evidence of the clinical investigation insurance.
Name what you need from the EC before commencing a clinical trial?
the sponsor shall obtain documentation of the EC’s
approval/favourable opinion identifying the documents and amendments on which the opinion was based.
NOTE The sponsor can request the EC opinion voting list for the clinical Investigation to document that members of
the Investigation site team were not part of the voting.
During trial what info should be provided to EC, if required by national regulations, the CIP or the EC?
a) serious adverse events;
b) requests for deviations, and reports of deviations, if the deviation affects subject’s rights, safety and wellbeing,
or the scientific integrity of the clinical investigation; ·
Under emergency circumstances, deviations from the CIP to protect the rights, safety and well-being of
human subjects may proceed without prior approval of the sponsor and the EC. Such deviations shall be
documented and reported to the sponsor and the EC as soon as possible.
c) progress reports, Including safety summary and deviations;
d) amendments to any documents already approved by the EC;
NOTE For non-substantial changes [e.g. minor logistical or administrative changes, change of monitor{s),
telephone numbers, renewal of Insurance] not affecting the rights, safety and well-being of human subjects or not
related to the clinical investigation objectives or endpoints, a simple notification to the EC and, where appropriate,
regulatory authorities can be sufficient.
e) if applicable, notifications of suspensions or premature termination;
f) if applicable, justification and request for resuming the clinical Investigation after a suspension;
g) clinical investigation report or its summary.
Name some non-substsantial changes where a simple notification to the EC is sufficient?
NOTE For non-substantial changes [e.g. minor logistical or administrative changes, change of monitor{s),
telephone numbers, renewal of Insurance] not affecting the rights, safety and well-being of human subjects or not
related to the clinical investigation objectives or endpoints,
section 4.5.4
During the clinical investigation, what info from the EC must be obtained prior to implementation?
a) approval/favourable opinion of amendments, as stated In 4.5.4 d);
b) approval of the request for deviations that can affect the subject’s rights, safety and well-being or the
scientific integrity of the clinical investigation, as stated in 4.5.4 b);
c) approval for resumption of a suspended clinical Investigation, as stated in 4.5.4 f) , if applicable.
When should Clinical Investigations be conducted in vulnerable populations?
only when they cannot be carried out In
non-vulnerable populations and shall follow the additional EC procedures where applicable. These clinical
investigations shall be designed specifically to address health problems that occur in the vulnerable
population, and offer the possibility of direct health-related benefit to the vulnerable population.
What two forms (or one combined) does the Informed Consent consist of?
The Informed consent form consists of an information form (see 4.7.4) and an informed consent signature
form (see 4.7.5). These two forms** can either be combined in one document or separated into two documents.**
What should the process of obtaining IC contain and be documented? 10 Items.
a) ensure that the principal investigator or his/her authorized designee conducts the informed consent
process,
b) include all aspects of the clinical investigation that are relevant to the subject’s decision to participate
throughout the clinical investigation,
c) avoid any coercion or undue improper influence on, or inducement of, the subject to participate,
d) not waive or appear to waive the subject’s legal rights,
e) use native non-technical language that is understandable to the subject,
f) provide ample time for the subject to read and understand the informed consent form and to consider
participation in the clinical investigation,
**g) **include personally dated signatures of the subject and the principal investigator or an authorized designee
responsible for conducting the informed consent process,
h) provide the subject with a copy of the signed and dated Informed consent form and any other written
information,
i) show how informed consent will be obtained and recorded in special circumstances (see 4.7.3) where the
subject is unable to provide it him- or herself, and
**j) **ensure important new information is provided to new and existing subjects throughout the clinical
Investigation.
The above requirements shall also apply with respect to informed consent obtained from a subject’s legally
authorized representative.
Name 3 special circumstances for Informed Consent
- Subject needing legally authorized representatives
- Subject unable to read or write
- Emergency treatments
Why would a subject need a LAR?
Informed consent may be given by the legally authorized representative only if a subject is unable to make the
decision to participate in a clinical investigation (e.g. infant, child and juvenile, seriously ill or unconscious
subject, mentally ill person, mentally handicapped person). In such cases, the subject shall also be informed
about the cllnical investigation within his/her ability to understand.
T/F a Mentally ill person is an example of a population who may need a LAR?
True
T/F a Mentall handicapped person is an example of a population who may need a LAR?
True
T/F a inmate person is an example of a population who may need a LAR?
False
T/F a infant/child and Juvenile is an example of a population who may need a LAR?
True
T/F a seriously ill or unconscious subject is an example of a population who may need a LAR?
True
How do you obtain IC if someone can’t read or write?
Informed consent shall be obtained through a supervised oral process If a subject or legally authorized
representative is unable to read or write. An Independent witness shall be present throughout the process.
The written informed consent form and any other information shall be read aloud and explained to the
prospective subject or his/her legally authorized representative and, whenever possible, either shall sign and
personally date the informed consent form. The witness also signs and personally dates the informed consent
form attesting that the information was accurately explained and that informed consent was freely given.
Who signs the IC if someone is unable to read or write?
The witness and subject (or LAR)
Can you enroll a subject under an emergenct treatment if they can’t sign the ICF?
Yes -
the informed consent of the subject’s legally authorized
representative, If present, shall be requested.
When it Is not possible to obtain prior informed consent from the subject, and the subject’s legally authorized
representative is not available, the subject may still be enrolled if a specific process has been described in the
CIP as given In A.13 b).
Can you enroll a subject if the subject or LAR can’t sign the consent form?
When it Is not possible to obtain prior informed consent from the subject, and the subject’s legally authorized
representative is not available, the subject may still be enrolled if a specific process has been described in the
CIP as given In A.13 b).
If you enroll under emergency treatment, what do you need to try to inform the subject or LAR of?
Arrangements shall be made to inform the subject or legally authorized representative, as soon as possible,
a) about the subject’s inclusion in the clinical investigation, and
b) about all aspects of the clinical investigation.
if you enroll under an emergceny situation do you try to obtain IC from the subject or LAR when the medical condition allows?
YESSSSSS!
If you enroll under an emergency situation, does the subject have to agree to remain in the trial by providing IC?
Yes - duh
When can the PI enroll a subject without obtaining IC of the subject or LAR? 5 conditions that must be met.
c) the prospective subject fulfils the emergency conditions and is obviously In a life-threatening situation;
d) no sufficient clinical benefits are anticipated from the currently available treatment;
e) there is a fair possibility that the life-threatening risk to the prospective subject can be avoided If the
investlgational device Is used;
f) anticipated risks are outweighed by the potential benefits of applying the investlgatlonal device;
g) the legally authorized representative cannot be promptly reached and informed.
T/F the IC should be written in technical medical language?
False-
All information pertinent to the clinical investigation, including at least the following, shall be provided In writing
and in native, non-technical language that is understandable to the subject (or the subject’s legally authorized
representative).
Informed Consent Elements: List basic elements of the IC
- Description and Purpose
- Potential Benefits
- Risks and inconveniences for subject (or when applicable embryo, fetus, nursing infant)
- Alternative Procedures
- Confidentiality
- Compensation
- Anticipated expenses, if any, to be borne by the subject for participating in the clinical investigation.
- Information on the role of sponsor’s representative In the clinical Investigation
- Contact Persons
- Statement declaring that new findings or the reasons for any amendment to the CIP that affect the
subject’s continued participation shall be made available to the subject - Statement indicating that, upon subject’s approval, the subject’s personal physician will be informed of the
subject’s participation in the clinical investigation. - Termination
Informed Consent Elements: Description and Purpose:
Name the 8 elements of this section
1) statement that the clinical investigation involves research;
2) purpose of the clinical Investigation;
3) anticipated duration of the clinical investigation, and extent of the involvement and responsibilities of
each subject during the clinical investigation;
4) description of the lnvestlgational device and comparator, if any;
5) description of all procedures Involving the subject;
6) aspects of the clinical investigation that are experimental;
7) description of the clinical investigation, Including a mention of any comparison groups and the
method of assignment to each group;
8) number of subjects expected to participate In the clinical investigation.
Informed Consent Elements: Potential Benefits: List the 2 elements of this section
1) description of benefits for the subject that can reasonably be expected (if there Is no direct
therapeutic benefit anticipated, this shall be noted);
2) description of potential benefits for others.
Informed Consent Elements: Risks and Inconveniences:
Name the 4 elements of this section
1) description of residual risks Identified by the risk analysis;
2) description of risks associated with the clinical procedures required by the CIP;
3) statement that unanticipated risks may occur;
4) description of inconveniences.
Informed Consent Elements: Alternative Procedures:
Name the 1 elements of this section
information on alternative treatments or procedures that may be available to the subject, and their
potential benefits and risks.
Informed Consent Elements: Confidentiality:
Name the 4 elements of this section
1) statement confirming that subject participation Is confidential;
2) statement confirming that records Identifying the subject will be kept confidential to the extent allowed
by the law;
3) statement confirming that the subject understands that regulatory authorities, EC representatives and
sponsor’s representatives involved in the clinical investigation will have direct access to medical
records;
4) statement Indicating that clinical Investigation results may be published without disclosing the
subject’s identity.
NOTE Additional requirements regarding personal data protection can be requested as per national or regional
regulations.
Informed Consent Elements: Compensation:
Name the 3 elements of this section
1) Information about provisions for compensation available in the event of Injury arising from
participation in the clinical investigation;
2) information about additional health care for subjects who suffer from an adverse event as a result of
participating In the clinical investigation;
3) information on financial compensation for participation, if applicable.
Informed Consent Elements: Contact Persons:
Name the 3 elements of this section
1) whom to contact with questions about the clinical investigation;
2) whom to contact in the event of injury;
3) whom to contact with questions about subject’s rights.
Informed Consent Elements: Termination:
Name the 2 elements of this section
1) circumstances under which the subject’s participation can be terminated by the principal investigator,
if applicable;
2) circumstances under which the sponsor can suspend or prematurely terminate the clinical
investigation.
What should the informed consent signature contain?
a) the voluntary agreement to participate in the clinical investigation and follow the investigator’s
instructions;
b) a statement declaring that refusal of participation incurs no penalty for the subject;
c) a statement declaring that discontinuation at any time Incurs no penalty for the subject;
d) a statement with regard to the possible consequences of withdrawal;
e) an acknowledgement of the information provided and confirmation that all the subject’s questions were
answered;
f) a statement confirming that the subject or his/her legally authorized representative agrees to the use of
the subject’s relevant personal data for the purpose of the clinical investigation;
g) a statement confirming that the subject or his/her legally authorized representative agrees that sponsor’s
representatives, regulatory authorities and EC representatives will be granted direct access to the
subject’s medical records.
T/F?
If new information becomes available that can significantly affect a subject’s future health and medical care, that information shall be provided to the subject(s) affected in written form. If relevant, all affected subjects shall be asked to confirm their continuing Informed consent in writing.
True
When evaluating risk for a trial, it should be estimated in accordance of what?
T/F it should be estimated after the trial starts?
Risks associated with the investigational device shall be estimated in accordance with ISO 14971 prior to
conducting a clinical investigation.
False
Where should the risk analysis of the study go?
IB
A summary of the risk analysis, including an
identification of residual risks, shall be included in the 18.
T/F - The risk analysis shall include or refer to an objective review of published and available unpublished medical and scientific data
True
The ______ shall also be used as a basis for identifying anticipated adverse device effects characterized
by their nature, incidence, severity and outcome.
RISK ANALYSIS
The decision to embark upon a clinical Investigation of a medical device requires that the residual risk(s), as
identified in the risk analysis, as well as risk(s) to the subject associated with the clinical procedure required by the CIP be __________ against the anticipated benefits to the subjects.
balanced
The anticipated adverse device effects shall be documented where? And why?
The CIP and IC
This enables compliance with any reporting requirements for anticipated and unanticipated SADEs.
The justification for the design of the clinical investigation shall be based on the evaluation of _____ _____ and the results of a _________ _________
pre-clinical data
clinical evaluation.
What does a clinical evaluation include?
includes an assessment and analysis of clinical data concerning safety or performance
of the investigatlonal device or similar devices or therapies.
The evaluation shall be relevant to the intended
purpose of the investlgational device and the proposed method of use. This Is a scientific activity that shall be
done with rigour and objectivity according to scientific standards using the principles of GHTF clinical
evaluation (see Reference [6])
what shall be used to determine and justify the optimal design of the clinical investigation.
The results of the clinical evaluation
what shall also help identify relevant endpoints and confounding factors to be taken into
consideration, and serve to justify the choice of comparator(s).
The results of the clinical evaluation
The clinical investigation shall be designed to evaluate whether the_______ _______ is suitable for the
purpose(s) and the population(s) for which it is intended. It shall be designed in such a way as to ensure that
the results obtained have clinical relevance and scientific validity and address the clinical investigation
objectives.
investigational device
T/F -
The need to conduct a clinical Investigation to meet regulatory requirements Is determined by the applicable
national regulations.
True
Who agrees to the CIP and CIP ammendments?
agreed upon between the sponsor, the coordinating
investigator and all principal investigators, and are recorded with a justification for each amendment.
Whats the purpose of the IB?
The purpose of the IB is to provide the principal investigator with sufficient safety or performance data from
pre-clinical investigations or clinical investigations to justify human exposure to the investigatlonal device
specified in the CIP.
The IB shall not be updated throughout the course of the clinical Investigation as significant new information
becomes available (e.g. a significant change in risk, etc.).
False
The IB shall be updated throughout the course of the clinical Investigation as significant new information
becomes available (e.g. a significant change in risk, etc.).
T/F -
The principal investigator(s) shall acknowledge the receipt of the IB and all subsequent amendments, and
shall keep all information confidential.
True
What assessments drive the development of the monitoring plan?
The sponsor shall assess the extent and nature of monitoring appropriate for the clinical investigation,
Including the strategy for source data verification, based on considerations such as the objective, design,
complexity, size, critical data points and endpoints of the clinical Investigation
T/F
The lnvestigational device, the instructions for use or the packaging shall indicate that the investigational
device is exclusively for use in a clinical Investigation, If required by national regulations.
True