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Agenday History
y ICH E6
y Good Clinical Practice
y FDA Guidelines
y References
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THE NUREMBERG CODEy In 1947 the War Crimes Tribunal meeting at Nuremberg
convicted 23 German defendants, most of whom were
physicians, of performing criminal experiments onhuman subjects. The Tribunal propounded ten
standards to guide physicians in carrying out
experiments on human subjects in the future.
y Resulted in the requirement of Informed Consent,among other requirements
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Declaration of Helsinki - 1964y The World Medical Association (WMA) has developed
the Declaration of Helsinki as a statement of ethical
principles for medical research involving humansubjects, including research on identifiable human
material and data.
y Wide adoption of the principles set forth in the
Nuremberg Code.
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Declaration of HelsinkiWORLD MEDICAL ASSOCIATION DECLARATION OF HELSINKI
Ethical Principles for Medical Research Involving Human Subjects
y Adopted by the18th WMA General Assembly Helsinki, Finland,
June 1964
y and amended by the
y 29th WMA General Assembly, Tokyo, Japan, October 1975
y 35th WMA General Assembly, Venice, Italy, October 1983
y
41st WMA General Assembly, Hong Kong, September 1989y 48th WMA General Assembly, Somerset West, Republic of
South Africa, October 1996
y 52nd WMA General Assembly, Edinburgh, Scotland, October
2000
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The Belmont Report - 1979y Ethical Principles and Guidelines for the protection of Human
Subjects of Research (The National Commission for the Protection
of Human Subjects of Biomedical and Behavioral Research)
y Three basic ethical principles, applied through:
y Informed Consent
y Systematic assessment of Risks and Benefits
y Fair procedures and outcomes in selection of subjects
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Good Clinical Practice: ICH E6 (1996)
y Good Clinical Practice Guideline (ICH E6) includes protection of
human rights for subjects in clinical trial.
y
It also provides assurance of the safety and efficacy of the newlydeveloped compounds or medical devices (includes IVDs).
y Good Clinical Practice Guidelines include standards on how
clinical trials should be conducted, define the roles and
responsibilities of clinical trial sponsors, clinical research
investigators, and monitors (clinical research associates).
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ICH GCP E6 - Sectionsy IRB/Ethics Committee
y Investigator
y
Sponsory Clinical Trial Protocol
y Investigators Brochure
y Essential Documents for the Conduct of a Clinical Trial
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Principles of ICH E6 GCPy Clinical trials should be conducted in accordance with the ethical
principles that have their origin in the Declaration of Helsinki.
y Risks should be weighed against potential benefits.
y Rights, safety and well being of the trial subjects are the most
important considerations.
y Available clinical and nonclinical information on the investigational
product should be adequate to support the clinical trial.
y Clinical trials should be scientifically sound and described in a
clear, detailed protocol
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Principles of ICH E6 GCPy The trial should be conducted in compliance with a protocol that
has received prior institutional review board (IRB) approval.
y
The medical care and medical decisions made on behalf ofsubjects should always be the responsibility of a qualified
physician.
y Each individual involved in conducting a trial should be qualified
by education, training and experience.
y
Freely given informed consent should be obtained from everysubject prior to participation in a clinical trial.
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Principles of ICH E6 GCPy All clinical trial information should be recorded, handled and
stored in a way that allows accurate reporting, interpretation and
verification
y The confidentiality of records that could identify subjects should
be protected. Confidentiality must be maintained according to
applicable regulations.
y Investigational product should be manufactured, handled and
stored according to good manufacturing practice (GMP) and used
according to the approved protocol.
y Systems with procedures that assure the quality of the trial should
be implemented (SOPs).
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IRB Responsibilitiesy To safeguard the rights, safety and well-being of all trial subjects
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Investigator Responsibilitesy Qualified by education, training and experience
y Familiar with appropriate use of the investigational product
y Aware of and able to comply with GCP
y Have adequate resources to complete the trial
y Provide appropriate medical care for trial subjects
y Run the trial with IRB/EC approval. This includes informed consent of trial
subjects
y
Comply with the protocol, including appropriate subject enrollment, accuratedata entry, and reporting of deviations and adverse events
y Have source documentation available for monitoring and audits as needed
y Submit a final report to the Sponsor and IRB at the conclusion of the trial
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Sponsor Responsibilitiesy QA/QC
y Implement and maintain written SOPs.
y Secure written agreements from all involved parties to ensuredirect access to all trial-related source data, documents and
reports for monitoring and audits.
y Apply QC to each stage of data handling to ensure data
integrity.
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Sponsor Responsibilityy Medical Expertise
y Designate appropriately qualified medical personnel to advise
on trial-related medical questions or problems.
y Trial Design
y Utilize qualified personnel as appropriate through all stages of
the trial process (protocol and CRF design, analyses planning,
interim and final reports).
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Sponsor Responsibilityy Trial Management/Data Handling/Recordkeeping
y Utilize appropriately qualified individuals to supervise
y Overall conduct
y Handle data
y Verify data
y Conduct statistical analyses
y Prepare trial reports
y If using electronic data capture, ensure the system isvalidated and SOPs are in place.
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Investigator Selectiony Investigators qualified by training and experience
y Must have adequate resources
y Must agree to conduct the trial according to GCP
y Must agree to comply with the protocol, data reporting
y Must agree to permit monitoring, auditing
y Must agree to retain essential documents
y Should sign the protocol (or alternate document) to confirm
agreement
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Confirmation of review by IRBy Sponsor must obtain from the investigator
y Name/address of the institutions IRB
y Documented approval of IRB approval of the protocol, current
informed consent and any other written information provided
to the subjects
y If any modifications are made to the protocol, updated
approvals from the IRB must be obtained.
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Investigational Producty Investigational product must be manufactured, packaged and
labeled according to applicable GMP.
y Sufficient safety and efficacy data must be available to support the
current clinical trial.
y The sponsor is responsible for maintaining records documenting
shipment, receipt, disposition, return and destruction of
investigational product.
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Monitoringy Monitoring ensures:
y The rights and well-being of subjects are protected
y Reported trial data are accurate, complete and verifiable
y Conduct of the trial is in compliance with the currently
approved protocol, and in compliance with GCP
y Sponsor is responsible for ensuring the trial is adequately
monitored
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Monitorsy Monitors should be appropriately trained
y Scientific and/or clinical knowledge to monitor the trial
adequately.
y A monitors qualifications should be documented
y Monitors should be familiar with the product, protocol,
informed consent, SOPs, GCP
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Monitorsy Monitors responsibilities
y Ensure and verify proper conduct and documentation of the
trial
y Verify investigator qualifications and resources
y Verify proper informed consent procedures
y Ensure all site personnel are informed about the trial and
any updates
y Verify data entry on CRFs is consistent with source
documentation
y Verify that adverse events are reported in accordance with
the protocol and within time periods required by GCP
y Verify that the investigator is maintaining the essential
documents
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Monitoring Reporty There should be an established monitoring SOP
y Monitoring reports should be completed after each monitoring visit
y
Date, site, name of monitor, site personnel visitedy Summary of what was reviewed, significant findings,
deviations and deficiencies, actions to be taken to secure
compliance
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Auditsy Independent and separate from monitoring
y Evaluate trial conduct and compliance with the protocol, SOPs,
GCP
y Auditors are independent of the clinical trial
y Qualified by training and experience, documented
y Written audit SOP
y What, how, frequency, content of audit reports
y Audit plany Audit report
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Clinical Trial Protocoly Contents include:
y Protocol title, number, date, amendment
y
Name and address of sponsor and monitory Name and title of person authorized to sign the protocol and
amendments for the sponsor
y Name and title of the investigator(s), contact information of the
sites (may be in a separate document)
y
Clinical laboratory information and other medical/technicaldepartments involved in the trial
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Clinical Trial Protocoly Background information
y Trial objectives and purpose
y Trial Design
y Specific statement of the primary and secondary endpoints
y Type/design of trial to be conducted and schematic diagram
of trial design, procedures and stages
y Description of measures taken to avoid bias
y
Expected duration of subject participation, includingdiscontinuation criteria
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Clinical Trial Protocoly Selection and withdrawal of subjects
y Inclusion/exclusion criteria
y Any withdrawal criteria
y Treatment of subjects
y Treatment to be administered
y Assessment of efficacy and safety
y Specification of efficacy and safety parameters
y Procedures for recording and reporting adverse events
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Clinical Trial Protocoly Statistics
y Description of the statistical methods to be employed
y Number of subjects to be enrolled, including number at each
site for multi-site trialsy Criteria for termination of a trial
y Procedure for accounting for missing, unused and unverified
data
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Essential Documentsy Documents that individually and collectively permit evaluation of a
trial and the quality of the data produced.
y Demonstrate the compliance of the investigator, sponsor and
monitor with the standards of GCPy Essential documents are audited by independent auditors and
inspected by regulatory authorities (i.e., FDA) to confirm the
validity of trial conduct and integrity of data collection
y Trial Master Files should be established at the beginning of the
trial, and confirmed at the monitors close-out visit
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FDA Guideline for the Monitoring of Clinical Investigations
y Monitors must be appropriately trained and qualified
y Written monitoring procedures must be in place
y A sponsor is responsible for assuring, through personal contact
between the monitor and each investigator, that the investigatorclearly understands and accepts the obligations incurred inundertaking the clinical investigation
y Prior to the initiation of a clinical trial, the sponsor shouldconduct a pre-assessment visit
y A sponsor is responsible for assuring, through personal contactbetween the monitor and each investigator, that the investigator
clearly understands and accepts the obligations incurred inundertaking the clinical investigation
y The sponsor is responsible for assuring the data submitted to theFDA are accurate and complete.
y The monitor or sponsor must maintain a record of each on-site visit(monitoring reports)
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Referencesy The Nuremburg Code
y The Declaration of Helsinki
y The Belmont Report
y International Conference on Harmonization E6 - Good Clinical
Practice Guidelines
y http://www.fda.gov/ScienceResearch/SpecialTopics/Running
ClinicalTrials/GuidancesInformationSheetsandNotices/defau
lt.htm
y FDA Guideline for the Monitoring of Clinical Investigations
y http://www.fda.gov/RegulatoryInformation/Guidances/ucm12
6400.htm
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