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Good Clinical Practice

Overview Of Good Clinical Practice


GCP What It Is • An international ethical & scientific quality standard for designing, conducting, recording & reporting human clinical studies – EU – Japan – US

• Applies to registration studies that may have an impact on safety & welfare of human subjects


GCP Participating Parties • IRB/Ethics Committee • Investigators • Sponsor • Regulatory Authorities


GCP Key Documents • Investigator Brochure • Study Protocol • Informed Consent Document


GCP Principles 1.

Studies in accordance with Declaration of Helsinki; consistent with GCP & applicable regulatory requirements

2.

Studies initiated & continued only if anticipated benefits outweigh risks

3.

Rights, safety & welfare of human subjects take priority over interests of science & society

4.

Available non-clinical & clinical info on product adequate to support study


GCP Principles 5. Studies scientifically sound; described in clear, detailed protocol 6. Study in compliance with IRB/EC approved protocol 7. Medical care given to subjects is the responsibility of qualified medical professional(s) 8. Individuals conducting studies qualified by education, training & experience 9. Freely given informed consent obtained from every subject prior to study participation


GCP Principles 10. Study information recorded, handled & stored to allow accurate reporting, interpretation & verification 11. Confidentiality of subject records protected in accordance with applicable regulatory requirements 12. Investigational products manufactured, handled & stored in accordance with GCP & used in accordance with approved protocol 13. Systems/procedures implemented to assure quality of study


IRB/EC Roles & Responsibilities To safeguard study subjects’ rights & welfare by: • Evaluation/disposition of study proposal • Evaluation of proposed subject consent materials • Evaluation of emergency use consent methodology • Evaluation of investigator qualifications • Ongoing review of study progress (at least yearly) • Evaluation of proposed subject compensation plans


IRB/EC Composition & Operations • Membership has qualifications & experience to evaluate science, medical aspects & ethics of proposed study – ≥ 5 members – ≥ 1 member whose primary interest in nonscientific – ≥ 1 member independent of institution or study site

• Written SOPs & records • Decisions rendered at announced meetings with quorum in attendance


IRB/EC Composition & Operations • Only members participating in review should vote • Investigator may provide info on study, but should not be involved in review or vote • Nonmembers with expertise in special areas may be invited to assist with review (but cannot vote)


IRB/EC Procedures • Document group membership & qualifications • Schedule meetings & notify members • Conduct initial & ongoing review of studies • Determine ongoing review frequency • Provide expedited review of minor study changes, in accordance with regulatory requirements • Specify that no subject should be enrolled in study prior to IRB/EC approval


IRB/EC Procedures • Specify that no deviations from protocol should be initiated without prior IRB/EC approval – Emergency situations require immediate notification of IRB/EC after the fact

• Specify that Investigator should promptly report: – Protocol deviations – Changes increasing subject risk or study procedures – Serious and unexpected adverse events


IRB/EC Procedures • Notify Investigator promptly of: – Study-related decisions – Reason for decisions – Procedures for appeal of decisions


IRB/EC Required Records • Relevant records maintained ≥ 3 yr after study completion • Records available for review by regulatory authorities


IRB/EC What is Reviewed • Investigator Brochure or Report of Prior Investigations • Study protocol & amendments • Investigator qualifications • Informed consent documents, including subject recruiting tools • Other written information provided to subjects • Subject compensation plans • Adverse events • Protocol deviations


IRB/EC When Reviews Occur • Prior to study initiation at site • At least yearly during study • During study, as necessitated by: – Changes in protocol, consent documents, etc. – Changes in study investigator – Reports of serious or unanticipated device-related adverse events • At study completion or termination


Investigator Roles & Responsibilities • Qualified to conduct study • Have adequate resources to conduct study • Provide medical care to study subjects • Regular communication with IRB/EC reviewing study • Compliance with study protocol • Maintenance of investigational product accountability • Compliance with study randomization & unmasking procedures • Provide informed consent to study subjects


Investigator Responsibilities Appropriate Qualifications • Training & experience demonstrated via: – Medical license – CV – Specialized study training – GCP training

• If study responsibilities delegated, need a list of qualified persons to whom responsibilities are delegated


Investigator Responsibilities Adequate Resources • Suitable staff & good methods for keeping them apprised • Suitable facilities • Appropriate patient population – Access to disease or condition – Volume of patients with disease or condition


Investigator Responsibilities Medical Care • Make medical decisions regarding patient treatment • Adequate care for study-related adverse events • Diligence in ascertaining reason(s) for subject withdrawals from study


Investigator Responsibilities IRB/EC Communications • IRB/EC approval prior to study initiation • IRB/EC kept apprised of events & progress during study


Investigator Responsibilities Protocol Compliance • Conduct study in accordance with protocol • May not deviate from protocol without Sponsor/IRB approval • Document deviations from protocol


Investigator Responsibilities Investigational Product Accountability • Maintain accountability at study site • Document product receipt & disposition • Maintain product in a secure area • Use product only in accordance with protocol • Disallow use of product by anyone not registered with study


Investigator Responsibilities Randomization Procedures & Unmasking • Follow study randomization procedures • Unmask only in accordance with protocol • Document noncompliance or premature unmasking


Investigator Responsibilities Subject Informed Consent • Comply with regulatory requirements • Update consent documents as necessary • Inform subject that study involves “investigational” product • May not coerce subject to participate • May not waive subject’s legal rights • Keep subject informed of new information regarding study


Investigator Responsibilities Subject Informed Consent • Provide informed consent in understandable language • Give subject the chance to ask questions • If subject can’t read, need impartial witness • If subject is “disadvantaged”, need legally authorized witness • Get subject consent in writing prior to initiation of study procedures • Give subject a copy of signed consent document


Investigator Responsibilities Required Records & Reports • Essential regulatory document file(s) – Protocol & amendments – Approved informed consent documents – Product accountability documentation – Investigator qualifications & agreements – IRB correspondence – Study delegation list – Subject screening/enrollment logs – Study monitoring reports – Calibration/maintenance logs – Memos to file


Investigator Responsibilities Required Records & Reports • Source documentation • Data capture forms (study-specific) • Data clarification forms • Fully executed informed consent documents


Investigator Responsibilities Required Records & Reports • Written periodic status reports to IRB/EC • Written reports of protocol deviations to Sponsor & IRB/EC • Serious or unanticipated product-related adverse events to Sponsor & IRB/EC • Notification of study suspension or termination to IRB/EC • Final study report to IRB/EC • Retain ≥ 2 yr


Sponsor Roles & Responsibilities • Study quality assurance • Appropriately qualified medical personnel to advise on study • Utilization of qualified personnel in study design & operations • Study management, data handling & record keeping • Investigator selection & training • Definition/allocation of study responsibilities


Sponsor Roles & Responsibilities • Facilitation of communications between Investigators • Study compensation (investigators and/or subjects) & financing • Regulatory authority notification/submission • Confirmation of IRB/EC review/approval • Investigational product information • Investigational product manufacturing, packaging, labeling & coding • Investigational product supply & handling


Sponsor Roles & Responsibilities • Record access • Ongoing safety evaluation & reporting • Serious/unanticipated adverse event reporting • Study monitoring • Study noncompliance procedures • Study termination or suspension notification • Study reports


Sponsor Roles & Responsibilities • Sponsor may transfer responsibilities to CRO – Transfer must be documented in writing – Sponsor still has ultimate responsibility for study quality and data integrity


Study Protocol Components • General administrative info • Background • Study purpose & objectives • Study design • Subject eligibility requirements • How subjects will be treated • How safety & efficacy will be assessed • Sample size justification & statistical analysis methods


Study Protocol Components • How data will be captured & maintained • Monitoring procedures • Proposed informed consent document


Informed Consent Document Components • Statement that study involves “research” & product “experimental” (if applicable) • Study purpose • Number of expected study subjects to be enrolled • Study treatment(s) & probability for random assignment • Study exams & procedures for duration of trial • Subject’s responsibilities • Foreseeable risks to subject (embryo, fetus, nursing infant)


Informed Consent Document Components • Expected benefits • Alternatives procedures or therapies & associated risk/benefit • Compensation available in event of study-related injury or sickness • Anticipated payments to subject for study participation • Anticipated expenses to subject for study participation • Statement that participation is voluntary


Informed Consent Document Components • Description of extent to which confidentiality can be assured • Commitment to keep subject apprised on new information that may affect subject’s willingness to participate in study • Contact info for questions re: subject rights; trialrelated adverse events • Circumstances under which subject’s participation may be terminated


Investigator Brochure What It Is A compilation of clinical & non-clinical data on the product that is relevant to the product’s study in humans

Necessary for Investigator & IRB/EC review to assess the risks/benefits associated with study


Investigator Brochure Components Product formulation summary Introduction/background info regarding product & investigational plan • Investigational product physical, chemical & pharmaceutical properties & formulation • Non-clinical studies • Human clinical studies • Summary of data & guidance for Investigator


Good Clinical Practice Reference Documents & Links • ICH - E6: Guideline for Good Clinical Practice • 21 CFR 50 - Informed Consent • 21 CFR 56 - Institutional Review Board • http://www.ich.org/cache/compo/276-254-1.html

• http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.c

Overview Of Good Clinical Practice  

Overview Of Good Clinical Practice