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INVESTIGATOR
MANUAL
All That An Investigator Needs To Know
1st Edition: August 2009


© National Healthcare Group, Research & Development Office, Singapore
www.b2bresearch.nhg.com.sg


All rights reserved. No part of this publication may be reproduced, stored in a retrieval system
or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or
otherwise without the permission of NHG Research & Development Office.


Participating Institutions
Tan Tock Seng Hospital • National University Health System • Institute of Mental Health •
National Skin Centre • Alexandra Hospital • National Healthcare Group Polyclinics •
Today, the world benefits greatly from major advances in medicine through
the conscientious and concerted efforts of the research community to translate
research knowledge into feasible clinical applications. As we benefit from the
fruits of research, and recognize the effort by the research community, no
less appreciation goes to the contribution of research participants. To ensure
that research is continually conducted in a scientifically and ethically robust
manner, guidelines and principles are developed and adhered to widely.
These include the Nuremberg Code (1946), Declaration of Helsinki (1964),
the Belmont Report (1979) and the Singapore Guidelines to Good Clinical
Practice (1998), all unanimously created to facilitate scientifically and ethically
applauded research, that promote respect, beneficence and justice in human
subject research.

In parallel with the demands of excellence in research and research ethics,
the Investigator Manual is written to guide investigators and research team
members on the ethical conduct of research conducted under the oversight of
the National Healthcare Group Domain Specific Review Board (NHG DSRB).

The Manual serves as an essential resource for investigators to carry out
research responsibly. A comprehensive toolkit for best research ethics practice,
this Manual outlines the overall governance of research, provides procedural
guidelines for meeting ethical requirements in research, and offers guidance
on key ethical issues.
Today, the world benefits greatly from major advances in medicine through
the conscientious and concerted efforts of the research community to translate
research knowledge into feasible clinical applications. As we benefit from the
fruits of research, and recognize the effort by the research community, no
less appreciation goes to the contribution of research participants. To ensure
that research is continually conducted in a scientifically and ethically robust
manner, guidelines and principles are developed and adhered to widely.
These include the Nuremberg Code (1946), Declaration of Helsinki (1964),
the Belmont Report (1979) and the Singapore Guidelines to Good Clinical
Practice (1998), all unanimously created to facilitate scientifically and ethically
applauded research, that promote respect, beneficence and justice in human
subject research.

In parallel with the demands of excellence in research and research ethics,
the Investigator Manual is written to guide investigators and research team
members on the ethical conduct of research conducted under the oversight of
the National Healthcare Group Domain Specific Review Board (NHG DSRB).

The Manual serves as an essential resource for investigators to carry out
research responsibly. A comprehensive toolkit for best research ethics practice,
this Manual outlines the overall governance of research, provides procedural
guidelines for meeting ethical requirements in research, and offers guidance
on key ethical issues.
Chapter 01: Research Governance
  1.1 NHG Human Subjects Protection Program (HSPP)             1
  1.2 The Role And Structure Of Domain Specific
       Review Board (DSRB)                                    2
  1.3 The Role Of Institutions (Investigators, Department
       Representatives, Institutional Representatives)        3
  1.4 The Definition Of Research                               6


Chapter 02: Principles Of Research Ethics
  2.1 Ethical Research                                        15
  2.2 The Belmont Report                                      16
  2.3 Code Of Ethical Practice In Human Biomedical Research   17

Chapter 03: Overview Of Application And Review Process
  3.1 Application Process                                     19
  3.2 Review Process                                          21
  3.3 Outcome Of Review                                       23
  3.4 Post Approval Reporting Requirements                    24

Chapter 04: Submissions To DSRB
  4.1 New Applications                                        26
  4.2 Study Amendments                                        29
  4.3 Continuing Review / Renewal                             32
  4.4 Unanticipated Problems Involving Risks To Subjects      35
       Or Others (UPIRTSO)
  4.5 Non-Compliance                                          40
  4.6 Study Closure                                           44

Chapter 05: Review Process
  5.1 Exempt Review                                           46
  5.2 Non-Exempt Review                                       49
  5.3 Criteria For Approval                                   55

Chapter 06: Outcome Of Review                                 57

Chapter 07: Appeals To DSRB Decision                          58
Chapter 08: Guidance On Key Ethical Issues
  8.1 Informed Consent                                  59
  8.2 Recruitment Strategy                              72
  8.3 Risk / Benefit Assessment                         76
  8.4 Data And Safety Monitoring                        79
  8.5 Privacy And Confidentiality                       84
  8.6 Conflict Of Interest                              85
  8.7 Research In Vulnerable Population                  87
  8.8 Compensation For Research Related Injuries        103
  8.9 Standing Database & Tissue Banking                107

Chapter 09: Minimum Qualifications And Training To Be
An Investigator
  9.1 Who Can Be A Principal Investigator?              113
  9.2 Minimum Training Requirements                     115

Chapter 10: Responsibilities Of Investigator            117

Chapter 11: Preparing For Audit                         124

Chapter 12: Suggested Readings                          127

Chapter 13: Appendices

   a. Participant Information Sheet Checklist           128

   b. Short Form Consent - An Example                   132

   c. Waiver Of Documentation Of Consent - Examples     134

   d. Waiver Of Consent – Examples                      136

   e. Investigator File Content                         138

    f. Pre Audit Checklist                              142

   g. Possible Questions During An Audit                146

   h. Study Review Checklist                            148

    i. Applicable Fees                                  153
1.0




1.0
RESEARCH GOVERNANCE
1.1   NHG Human Subjects Protection Program (HSPP)
1.2   The Role And Structure Of Domain Specific
      Review Boards (DSRB)
1.3   The Role Of Institutions (Investigators, Department
      Representatives, Institutional Representatives)
1.4   The Definition Of Research
1.1      NHG HUMAN SUBJECTS PROTECTION
         PROGRAM (HSPP)

NHG Human Subjects Protection Program (HSPP) aims to promote high
quality and ethical research, and to ensure protection of human subjects
participating in research in NHG, and all institutions under the oversight of
NHG DSRB (herein after referred to as “Institutions”). All parties engaging
in research involving human subjects have a part to play to ensure that
the rights, safety, and well being of research subjects are safeguarded.
The NHG HSPP is under the oversight of the Research Ethics Committee
(REC), which is appointed by the NHG Chairmen of Medical Boards (CMB)
Committee. The REC develops and implements policies and procedures
related to human subjects protection, including both the Domain Specific
Review Board (DSRB) and the Research Quality Assurance Program.




                                                                                           1




                                            1.1 NHG HUMAN SUBJECTS PROTECTION PROGRAM (HSPP)
1.2        THE ROLE AND STRUCTURE OF DOMAIN
                               SPECIFIC REVIEW BOARD (DSRB)

                     The DSRB is an independent committee constituted of medical, scientific and
                     nonscientific members, whose responsibility is to ensure the protection of
                     the rights, safety, and well-being of human subjects involved in a research
                     study by, among other things, reviewing, approving, and providing
                     continuing review of research studies, of protocols and amendments, and
                     of the methods and materials to be used in obtaining and documenting
                     informed consent of the research subjects. The DSRB is made up of five or
                     more domains, and the domains are based on broad but related disease
                     groupings.

                     The NHG CMB Committee appoints members to the DSRB. Each domain will
                     consist of at least five (5) members, who collectively have the qualifications
                     and experience to carry out the DSRB’s stated objectives and terms of
                     reference to review and evaluate the ethical and scientific aspects of the
2                    proposed research studies.

                     Other officials of institutions which conduct research under the oversight
                     of NHG DSRB, may not override the decision of DSRB (or REC, where
                     applicable).




1.2 THE ROLE AND STRUCTURE OF DOMAIN SPECIFIC REVIEW BOARD (DSRB)
1.3        THE ROLE OF INSTITUTIONS
           (INVESTIGATORS, DEPARTMENT
           REPRESENTATIVES, INSTITUTIONAL
           REPRESENTATIVES)

 The DSRB, as well as the Institutions, must approve a research proposal
 before it can be conducted in the Institutions. The protection of human
 subjects in research is a collaborative effort by DSRB and all Institutions.
 While the DSRB is an independent review committee responsible for
 ensuring that the research proposal protects the well-being, safety and
 rights of the research subjects, each Institution ensures that the proposal
 is in keeping with its overall research direction, objectives, standards and
 image.


   Principal Investigator, Co-Investigators and
   Other Study Team Members

    The “Principal Investigator” is the overall responsible person for the                            3
    proper conduct of research. In general, each study can have only one
    Principal Investigator who is responsible for the conduct of the clinical
    study. The other members of the research team should be listed as Co-
    Investigators / Collaborators. The Principal Investigator, Co-Investigators,
    and all study team members have the responsibility to comply with DSRB
    policies and applicable regulatory requirements. For multi-centre studies
    within NHG, and all institutions under the oversight of NHG DSRB, each
    institution should have a Site Principal Investigator who is responsible for
    the conduct of the study in his / her institution. One of the Site PIs should
    be designated as Principal Investigator for the study, who is responsible
    for the coordination of investigators at different institutions participating
    in the multi-centre study, including but not limited to communication with
    the DSRB.



 For more information
 Refer to Chapter 10 Responsibilities of Investigator.




1.3 THE ROLE OF INSTITUTIONS (INVESTIGATORS, DEPARTMENT REPRESENTATIVES, INSTITUTIONAL REPRESENTATIVES)
Department Representative

                         The “Department Representative” (DR) plays a key role in assuring that
                         a research study is keeping with the research objectives, image and
                         standards of the relevant departments and institutions. The role of a DR
                         is to provide an overview assessment of the significance, concept, and
                         innovation of a research study; and whether the Principal Investigator
                         is adequately trained, qualified, possesses sufficient time and resources to
                         carry out the research study. The DR will endorse all applications made to the
                         DSRB. The DR would generally be the Head / Chief or Department Research
                         Head of the Principal Investigator’s department. In some departments, alternative
                         persons may be appointed as DRs, provided he / she is able to adequately
                         perform the responsibilities of a DR. Where there is a potential conflict
                         of interest for the DR, the alternative DR or the Reporting Officer of the
                         DR (e.g. Division Head or CMB) should fulfill this role.

                         Where appropriate and available, the Head / Chief of a Division (e.g.
4                        Division of Medicine) who oversees several departments may comment
                         in lieu of one of his / her Head / Chief of department.

                         For an application that involves more than one department (whether in
                         the same institution or otherwise), only the DR of the Principal Investigator
                         is required to endorse the application. It is the Principal Investigator’s
                         responsibility to ensure that the DRs of the other departments are in
                         agreement to endorse the research study to be carried out in that
                         department. Wherever appropriate and necessary, the DSRB may
                         require endorsements from the DRs of all participating departments.




1.3 THE ROLE OF INSTITUTIONS (INVESTIGATORS, DEPARTMENT REPRESENTATIVES, INSTITUTIONAL REPRESENTATIVES)
Institutional Representative

    The “Institutional Representative” (IR) is the authority to approve any
    research study to be conducted in the institution. This authority lies with
    the CMB and CEO of that institution. The IR considers if the research is in
    keeping with the institution’s research objectives, image and standards.
    In general, the IR’s role is not to review the scientific or ethical merits
    of the research study, which will be considered by the DSRB or a grant
    approving body (if one is applying for a grant). The IR will endorse all
    applications made to the DSRB. This authority is generally delegated to
    either one of the following:-

      a. the Director of Research (or equivalent), OR

      b. the Chairperson of a specially appointed committee for this
          purpose.

    Where there is a potential conflict of interest for the IR, the CEO/CMB
    should fulfil this role.                                                                          5


    For multi-centre studies within NHG, the IRs will endorse the application
    for his/her institution.

    In the B2BResearch Online system, the DRs and IRs of each department
    and institution have been pre-determined by individval departments and
    institutions to enable automatic routing of applications for endorsement.



 For more information
 Details on electronic endorsement process are available online at
 http://www.b2bresearch.nhg.com.sg (Downloads) and in the
 Online Manual (for DRs and IRs).




1.3 THE ROLE OF INSTITUTIONS (INVESTIGATORS, DEPARTMENT REPRESENTATIVES, INSTITUTIONAL REPRESENTATIVES)
1.4          THE DEFINITION OF RESEARCH

                     All research involving patients, staff, premises, or facilities of NHG
                     institutions and all Institutions under the oversight of NHG DSRB must be
                     reviewed and approved by NHG DSRB prior to initiation.

                     All research reviewed and approved by the DSRB must comply with NHG
                     DSRB requirements as outlined in the NHG DSRB Investigator Manual. The
                     DSRB requirements are based on Declaration of Helsinki and the ethical
                     principles in the Belmont Report. The DSRB requirements are also compliant
                     with the Bioethics Advisory Committee’s recommendations outlined in the
                     Guidelines for Institution Review Boards, November 2004.

                     Research conducted in NHG may also be subject to other guidelines and
                     applicable regulations such as:

                          a. US Department of Health and Human Services (DHHS) Regulations
                                 45 CFR 46 – when the research is funded by US Federal Funds
6
                                 e.g. funded by NIH, NCI, NIAIDS etc.

                          b. US Food and Drug Administration (FDA) Regulations 21 CFR
                                 56, 21 CFR 50 – when the research is being conducted under
                                 an Investigational New Drug (IND) Application or Investigational
                                 Device Exemptions (IDE) or when the results of research are
                                 intended to be submitted to FDA.

                          c. Singapore Guideline for Good Clinical Practice (SGGCP) – All
                                 clinical trials involving medicinal products are subject to SGGCP.

                          d. Medicines Act and Medicines (Clinical Trials) Regulations 2000
                                 – All clinical trials involving medicinal products are subject to the
                                 Medicines Act and Medicines (Clinical Trials) Regulations 2000.


                        Medicines Act and Medicines (Clinical Trials) Regulations

                        The definition of clinical trial under Medicines Act (Chapter 176):

                        CLINICAL TRIAL means an investigation or series of investigations
                        consisting of the administration of one or more medicinal products of a
                        particular description by, or under the direction of:

1.4 THE DEFINITION OF RESEARCH
a. a doctor or dentist to one or more of his patients; or

  b. two or more doctors or dentists, each product being administered by
     or under the direction of one or other of those doctors or dentists to
     one or more of his patients, where (in any such case) there is evidence
     that medicinal products of that description have effects which may be
     beneficial to the patient or patients in question and the administration
     of the product or products is for the purpose of ascertaining whether,
     or to what extent the product has, or the products have, those or any
     other effects, whether beneficial or harmful.

MEDICINAL PRODUCT means any substance or article (not being
an instrument, apparatus or appliance) which is manufactured, sold,
supplied, imported or exported for use wholly or mainly in either or both
of the following ways:

  a. use by being administered to one or more human beings or animals
     for a medicinal purpose;
                                                                                             7
  b. use as an ingredient in the preparation of a substance or article
     which is to be administered to one or more human beings or
     animals for a medicinal purpose.

MEDICINAL PURPOSE means any one or more of the following
purposes:

  a. treating or preventing disease;

  b. diagnosing disease or ascertaining the existence, degree or extent
     of a physiological condition;

  c. contraception;

  d. inducing anaesthesia;

  e. otherwise preventing or interfering with the normal operation of
     a physiological function, whether permanently or temporarily,
     and whether by way of terminating, reducing or postponing, or
     increasing or accelerating, the operation of that function or in any
     other way.


                                                                1.4 THE DEFINITION OF RESEARCH
SUBJECT means a person to whom the test material is to be administered
                        in a clinical trial.

                        CLINICAL TRIAL CERTIFICATE (CTC)

                          a. In accordance with the Medicines (Clinical Trials) Regulations, no
                                 person shall conduct a clinical trial, without a valid Clinical Trial
                                 Certificate (CTC) issued by the Health Sciences Authority.

                          b. The Principal Investigator (holder of the certificate) is responsible
                                 for applying to the Health Sciences Authority for the certificate.

                          c. Every Sponsor, Principal Investigator or holder of certificate shall
                                 comply with any guidelines or instructions relating to conduct of
                                 clinical trials issued by the Health Sciences Authority, including
                                 Singapore Guideline for Good Clinical Practice (SGGCP).

                        Depar tment                of   Health     and      Human        Ser vices
8
                        (DHHS), USA

                        The definition of research and other related terms under DHHS:

                        RESEARCH          is   a    systematic   investigation,   including   research
                        development, testing, and evaluation, designed to develop or contribute
                        to generalisable knowledge.

                        RESEARCH SUBJECT OR PARTICIPANT is a living individual about whom
                        an investigator conducting research obtains data through intervention or
                        interaction with individual, or identifiable private information.

                        INTERVENTION includes both physical procedures by which data
                        are gathered and manipulations of the participant or participant’s
                        environment that are performed for research purposes.

                        INTERACTION includes communication or interpersonal contact
                        between investigator and participant.

                        PRIVATE INFORMATION includes information about behaviour that
                        occurs in a context in which an individual can reasonably expect that
                        no observation or recording is taking place, and information which has

1.4 THE DEFINITION OF RESEARCH
been provided for specific purposes by an individual and which the
individual can reasonably expect will not be made public (for example,
a medical record). Private information must be individually identifiable
(i.e., the identity of the subject is or may readily be ascertained by the
investigator or associated with the information) in order for obtaining
the information to constitute research involving human subjects.

ENGAGED – An institution becomes “engaged” in a particular non-
exempt human subjects research when its employees or agents for the
purposes of the research project obtain: (1) data about the subjects of the
research through intervention or interaction with them; (2) identifiable
private information about the subjects of the research; or (3) the informed
consent of human subjects for the research.

EMPLOYEE OR AGENT – An institution’s employees or agents refer
to individuals who: (1) act on behalf of the institution; (2) exercise
institutional authority or responsibility; or (3) perform institutionally
designated activities. “Employees and agents” can include staff, students,                 9
contractors, and volunteers, among others, regardless of whether the
individual is receiving compensation.



Food and Drug Administration (FDA), USA

The definition of clinical investigation and other related terms under FDA:

CLINICAL INVESTIGATION is any experiment that involves a test article
and one or more human participants and that is one of the following:

  a. Subject to requirements for prior submission to Food and Drug
     Administration; or

  b. Not subject to requirements for prior submission to Food and Drug
     Administration, but the results of which are intended to be submitted
     later to, or held for inspection by Food and Drug Administration as
     part of an application for a research or marketing permit.




                                                              1.4 THE DEFINITION OF RESEARCH
HUMAN SUBJECT means an individual who is or becomes a participant
                        in research, either as a recipient of the test article or as a control. A
                        subject may be either a healthy individual or a patient.

                        TEST ARTICLE means any drug for human use, biological product
                        for human use, medical device for human use, human food additive,
                        color additive, electronic product, or any other article subject to FDA
                        regulation.

                        UNDER FDA IDE the definition of human subject is a human who
                        participates in an investigation either as individual or on whom or on
                        whose specimen an investigational device is used or as a control.



                        Singapore Guideline for Good Clinical Practice (SGGCP)

                        The definition of clinical trial / study under the SGGCP:

10                      CLINICAL TRIAL / STUDY – Any investigation in human subjects
                        intended to discover or verify the clinical, pharmacological and / or
                        other pharmacodynamic effects of an investigational product(s), and / or
                        to identify any adverse reactions to an investigational product(s), and / or to
                        study absorption, distribution, metabolism, and excretion of an investigational
                        product(s) with the object of ascertaining its safety and / or efficacy. The
                        terms clinical trial and clinical study are synonymous.

                        SUBJECT / TRIAL SUBJECT – An individual who participates in a
                        clinical trial; either as a recipient of the investigational product(s) or as a
                        control.



                        Bioethics Advisory Committee (BAC) Guidelines for IRBs

                        The definition of research and other related terms under the BAC:

                        DIRECT HUMAN BIOMEDICAL RESEARCH comprises any kind of
                        human research that involves:




1.4 THE DEFINITION OF RESEARCH
a. any direct interference or interaction with the physical body of a
     human subject, and

  b. that involves a concomitant risk of physical injury or harm, however
     remote or minor

  c. Examples – A research programme would qualify as Direct Human
     Biomedical Research if it involves

     i. the administration of any drug (whether it is for the purpose of
        testing the effects or efficacy of the drug, or

     ii. whether it is a means for establishing any other objective of the
        research programme), or

     iii. the trial or use of a medical device on a human subject, or

     iv. any test of a human subject’s physiological, emotional or mental
        responses (not being tests conducted for diagnostic purposes
        with a view to the therapeutic management of a patient).
                                                                                         11
INDIRECT HUMAN BIOMEDICAL RESEARCH comprises any research
that does not qualify as Direct Human Biomedical Research, and

  a. that involves

     i. human subjects, or

     ii. human tissue, or

     iii. medical, personal or genetic information relating to both
        identifiable and anonymous individuals, and

  b. that involves that is undertaken with a view to generating data
     about

     i. medical, genetic or biological processes, diseases or conditions
        in human subjects, or

     ii. of human physiology, or

     iii. the safety, efficacy, effect or function of any device, drug,
        diagnostic, surgical or therapeutic procedure (whether invasive,
        observational or otherwise);



                                                             1.4 THE DEFINITION OF RESEARCH
Indirect Human Biomedical Research also comprises of research that is
                        conducted in human subjects whether as one of the objectives or the sole
                        objective, of the research study, trial or activity, and that has the potential
                        to affect the safety, health, welfare, dignity or privacy of

                                 i. the human subjects involved in the study, or

                                 ii. of donors of human tissue or information used in the research,
                                    or

                                 iii. of the family members of any of the human subjects or donors
                                    thereof, or

                                 iv. to which such medical, personal or genetic information relates.



                        Some Examples

                        Activities that involve systematic investigation and are designed to develop
                        or contribute to generalisable knowledge are considered research and
12                      will require review and approval by NHG DSRB. This includes clinical
                        trials, epidemiological research, retrospective medical records review
                        research, and genetic research.

                        CASE REPORTS – Case reports do not involve systematic investigation;
                        however the intent is to contribute to generalisable knowledge. Case
                        reports are not considered to be human subjects research.

                        CASE SERIES – A series of 3 or more subjects qualifies as a research
                        project and hence should be submitted for review and approval by the
                        DSRB prior to initiation.

                        DATABASE STUDIES – Research proposals for setting up a database
                        require DSRB review and approval. Databases that are not created for
                        the sole purposes of research do not require review by the DSRB, such
                        databases are termed as Standing Databases and need to be registered
                        with NHG Research and Development Office. However when data from
                        these databases is used for research related projects, each of these
                        projects would require DSRB review prior to initiation.




1.4 THE DEFINITION OF RESEARCH
TISSUE REPOSITORIES – Operation of Human Tissue Repositories and
its data management centre are subjected to oversight by the DSRB. The
DSRB will review and approve protocols specifying the conditions under
which data and specimens may be accepted and shared, and ensuring
adequate provisions to protect the privacy of subjects and maintain the
confidentiality of data. The DSRB will also review and approve a sample
collection protocol and consent document.

QUALITY ASSESSMENT AND IMPROVEMENT (QA/QI) – Activities
designed to determine if aspects of medical practice are in line with
established standards are called quality assessment. When an activity is
designed to improve the performance of medical practice in relation to
an established standard, it is called quality improvement. These projects
involve systematic investigation and usually contribute to generalisable
knowledge. Any QA or QI activity where participants are subjected
to additional risks or burdens beyond usual clinical practice will be
reviewed as research.
                                                                                            13
OUTBREAK INVESTIGATIONS – Outbreak investigations are important
activities that benefit public health. Subjecting these to research standards
might compromise these activities. So such activities are not considered
to be research and hence do not require DSRB review. However any
interventional studies conducted during an outbreak would require
review and approval by the DSRB and / or other clinical Committees.
The DSRB will make an effort to expedite the review and approval
process for such protocols.

DISEASE MANAGEMENT – Disease Management projects that do not
require the participants to undergo additional burdens or risks do not
require review and approval by the DSRB.

INFECTION CONTROL – Investigations carried out as part of an
infection control program are not considered as research and these do
not require review by the DSRB.




                                                                1.4 THE DEFINITION OF RESEARCH
Determination of Research Status

                        There are many research-like activities that are conducted as part of
                        quality improvement, infection control, disease management etc., that
                        may not meet the definition of research and hence do not need DSRB
                        review and approval. Further, new innovative therapies used by many
                        doctors during their clinical management of patients, may not necessary
                        meet the definition of research as well. Given the vague boundary
                        between research and non-research, the Principal Investigator must
                        ascertain which regulations are applicable and then apply the definitions
                        for research as described above. When in doubt whether an activity
                        requires DSRB review and approval, the Principal Investigator must write
                        to the DSRB with a summary of the proposal. The DSRB will review the
                        information and make a determination whether or not the described
                        activity meets the definition of research. The DSRB will then send a written
                        notification to the Principal Investigator with the final determination.


14




1.4 THE DEFINITION OF RESEARCH
2.0




2.0
PRINCIPLES OF
RESEARCH ETHICS
2.1   Ethical Research
2.2   The Belmont Report
2.3   Code Of Ethical Practice In
      Human Biomedical Research
2.1           ETHICAL RESEARCH

Ethical Research is research that:

    a. Upholds the core ethical principles of respect for persons,
        beneficence and justice.

    b. Protects rights, safety and well-being of human subjects.

    c. Compliant with all applicable regulations and guidelines.




                                                                                     15




                                                                   2.1 ETHICAL RESEARCH
2.2         THE BELMONT REPORT

                    The Belmont Report describes THREE core ethical principles for human
                    subject research:

                           a. Respect for persons – recognition of the personal dignity and
                              autonomy of individuals and special protection of these persons
                              with diminished autonomy, e.g. the need to obtain informed
                              consent.

                           b. Beneficence – entails an obligation to protect persons from harm
                              by maximizing anticipated benefits and minimizing possible risks
                              of harm, e.g. the need to engage in a risk / benefit analysis and to
                              minimize risks.

                           c. Justice – requires that the benefits and burdens of research be
                              distributed fairly, e.g. the need to have a reasonable inclusion and
                              exclusion criteria.
16
                         The NHG Human Subjects Protection Program follows the ethical
                         principles of The Belmont Report.




2.2 THE BELMONT REPORT
2.3       CODE OF ETHICAL PRACTICE IN HUMAN
          BIOMEDICAL RESEARCH (MOH)

The credibility of human biomedical research with society is dependent
upon the maintenance of the highest ethical standards in its conduct.
Research is ethically justifiable only if it is scientifically sound and does not
expose research subjects to unwarranted discomfort or risks without likely
benefit to the advancement of biomedical science. Research should also
abide by accepted moral standards within the community and be carried
out responsibly, in ways that respect and protect the research subjects, and
maintain scientific integrity to promote trust and accountability.

Researchers have a personal and non-delegable responsibility to ensure
the ethical conduct of their research. This Code lays down principles and
standards for ethical practice in human biomedical research in Singapore.
Researchers should use this Code as a yardstick for their conduct and
behavior. In addition, researchers should have an understanding of
research ethics, develop the knowledge, skills and attitude needed to                         17
manage ethical conflicts, and to consult with colleagues, ethics committees
and other experts when ethical issues arise.

Researchers are to uphold the principles fundamental to the protection of
human subjects. In general, researchers are expected to:

     a. Respect persons as individuals:

        i. obtain fully informed consent from subjects who are
            autonomous;

        ii. accord due protection to persons with diminished autonomy
            and who are vulnerable;

        iii. protect subject privacy and maintain data confidentiality at all
            times;

     b. Strive to promote the well-being and safety of human research
        subjects, protecting them from unnecessary risks, and never let the
        goals of research undermine this priority;




                                       2.3 CODE OF ETHICAL PRACTICE IN HUMAN BIOMEDICAL RESEARCH
c. Abide by local laws, regulations, guidelines and commonly agreed
                             standards of good practice on the conduct of human biomedical
                             research;

                          d. Embody professionalism by upholding integrity, openness, and a
                             commitment to intellectual honesty in the conduct of research, and
                             avoid any actual, potential or apparent conflict of interest;

                          e. Exercise responsible custodianship of resources under their charge
                             and be a responsible steward in the use and management of those
                             resources;

                          f. Treat all fellow researchers with dignity and respect, and managing
                             researchers under their supervision with care;

                          g. Observe the Code in all respects of their professional lives.



                     For more information
18
                     The Belmont Report is available online at http://www.hhs.gov/ohrp


                     The Code of Ethical Practice in Human Biomedical Research is available
                     online at http://www.moh.gov.sg




2.3 CODE OF ETHICAL PRACTICE IN HUMAN BIOMEDICAL RESEARCH
3.0
                                             3.0




OVERVIEW OF APPLICATION
AND REVIEW PROCESS
3.1   Application Process
3.2   Review Process
3.3   Outcome Of Review
3.4   Post Approval Reporting Requirements
3.1             APPLICATION PROCESS

  Endorsement Process by Institution
  Prior to making a submission to the DSRB, Investigators are required
  to obtain endorsements from their Department Representative and
  Institution Representative.



For more information
Refer to Chapter 1.3 The Roles of Institutions.



  Submitting a Research Study to DSRB

  The submission deadline for new research studies is the first working day
  of each month (except December), or the next working day, if the first
  falls on a weekend or public holiday.
                                                                                            19
  Research studies that qualify for expedited review, applications with
  request for exemption, or minor amendments to DSRB approved research
  studies may be submitted at any time of the month.


  All new applications are to be submitted online via
  http://www.b2bresearch.nhg.com.sg



  Triaging

  All research studies submitted to the DSRB for review will undergo
  appropriate in-depth review by triaging the research study to the DSRB
  that includes expert(s) in the disease group(s) that is (are) being studied
  in the study.


  The Principal Investigator should indicate the most appropriate DSRB
  in the B2BResearch Online Application Form. The DSRB will evaluate
  the Principal Investigator’s choice of DSRB based on the following
  considerations:



                                                                       3.1 APPLICATION PROCESS
a. PRINCIPAL INVESTIGATOR’S DISCIPLINE – A research study will
                               be triaged to the DSRB that includes his / her discipline.

                            b. DISEASE STUDIED IN THE RESEARCH STUDY – Depending on
                               the primary disease group that is being studied in the research
                               study, the study will be triaged to the DSRB that includes experts in
                               this disease group.

                          Where there is uncertainty about which domain a study should be
                          triaged to, the decision will be escalated to the Triage Board. The Triage
                          Board is a virtual board consisting of the DSRB chairpersons or their
                          deputies.



                     For more information
                     Refer to Chapter 4.1 New Applications.


                     Details on how to complete the B2BResearch Online DSRB Application
20                   Form are available online at http://www.b2bresearch.nhg.com.sg
                     ( D o w n l o ads ) an d i n t h e On l i n e Ma n u a l .


                     Details on the latest information on the disease groupings in DSRB
                     are available online at http://www.b2bresearch.nhg.com.sg.




3.1 APPLICATION PROCESS
3.2       REVIEW PROCESS

All research studies submitted will be classified under one of the following
review categories:
     a. Exempt Review

     b. Expedited Review

     c. Full Board Review

The determination of the review category is made by the DSRB. In general,
the determination is based on the level of risk in which research participants
is exposed to. Research studies that involve minimal or less than minimal
risk are reviewed under the Exempt or Expedited review categories, and
studies that involve more than minimal risk are reviewed under Full Board
Review category.

     a. EXEMPT REVIEW – Research studies that involve anonymous
                                                                                            21
        surveys & questionnaires, collection or study of anonymous
        existing data or tissue specimens, where data / tissue are either
        publicly available or subjects cannot be identified, or Public Benefit
        Programs may qualify for review by Exempt Review category.

     b. EXPEDITED REVIEW – Research studies that involve collection of
        data or biological samples via non-invasive procedures, medical
        case-notes review, surveys or interviews, may qualify for review by
        Expedited Review category.

     c. FULL BOARD REVIEW – Research studies that do not qualify for
        Exempt or Expedited Review category will be reviewed under Full
        Board Review category. Such studies may include research studies
        that involve the study of the safety and efficacy of a medicinal
        product, medical device, or research study that involve invasive
        procedures.



For more information
  Refer to Chapter 5.1 Exempt Review and Chapter 5.2 Non-Exempt Review.



                                                                            3.2 REVIEW PROCESS
Review Criteria

                       All research studies that intend to enroll human subjects must meet certain
                       criteria before study procedures can be initiated. The criteria are based
                       on the principles of autonomy, beneficence and justice as discussed in
                       the Belmont Report.

                       In general, a research study must fulfill the following criteria:

                         a. Risks are minimized, and are reasonable in relation to anticipated
                            benefits.

                         b. Selection of subjects are equitable.

                         c. Informed Consent will be sought, and appropriately documented.

                         d. Adequate provision for monitoring of data to ensure safety,
                            protection of privacy of research participants and confidentiality
                            of data collected.
22
                         e. Additional protection for vulnerable populations.



                     For more information
                     Refer to Chapter 5.3 Criteria for Approval.




3.2 REVIEW PROCESS
3.3      OUTCOME OF REVIEW

Following the review of a research study, the DSRB will reach one of the
following decisions:

    a. approve,

    b. conditionally approve,

    c. table for next convened meeting, or

    d. not approve

A research study that is reviewed under Exempt or Expedited Review
category cannot be disapproved. Instead, it will be escalated to the next
level of review or approved with modifications.



For more information
Refer to Chapter 6.0 Outcome of Review.                                               23




                                                                   3.3 OUTCOME OF REVIEW
3.4       POST APPROVAL REPORTING
                              REQUIREMENTS

                    Study Amendments

                    No deviation from, or changes to the approved study should be implemented
                    without documented approval from the DSRB, except where necessary to
                    eliminate apparent immediate hazard(s) to the study subjects, or when
                    the change(s) involves only logistical or administrative aspects of the study
                    (e.g. change of monitor or telephone number).

                    Any deviation from, or a change of, the protocol to eliminate an immediate
                    hazard should be documented and promptly reported to the DSRB within
                    7 calendar days.

                    For more information
                    Refer to Chapter 4.2 Study Amendments.

24
                    Continuing Review / Renewal

                    The DSRB will conduct continuing review of ongoing research (except
                    studies reviewed by Exempt Review category) at intervals appropriate to
                    the degree of risk, but not less than once per year.

                    The Principal Investigator should submit a completed DSRB Online Study
                    Status Report Form at least 4-6 weeks before the study approval period
                    ends (as indicated in the approval letter of the study), and in time for
                    DSRB to conduct its review and renew the approval of the study. If an
                    approval expires, no research activities, including screening, enrollment,
                    interventions, interactions, and collection of identifiable data can occur
                    after the expiry date, unless specific permission is granted by the DSRB.



                    For more information
                    Refer to Chapter 4.3 Continuing Review / Renewal.




3.4 POST APPROVAL REPORTING REQUIREMENTS
Unanticipated Problems Involving Risks To Subjects Or
Others (UPIRTSO)

The Principal Investigator is responsible for the accurate documentation,
investigation, follow-up and timely reporting of all UPIRTSOs. The criteria
for reporting are that the problems have to be (1) unexpected and (2)
related or possibly related to study. Special requirements are applicable
for reporting of events involving deaths of local research participants.



For more information
Refer to Chapter 4.4 Unanticipated Problems Invdving Risks To Subjects Or
Others (UPIRTSO).



Non–Compliance

All research should be conducted in compliance with the research       study
approved by the DSRB, SGGCP, NHG DSRB requirements, institution                            25

requirements, and applicable regulations. The Principal Investigator is
encouraged to report conduct of any non-compliance by him / herself,
members of the research team and others.



For more information
Refer to Chapter 4.5 Non-Compliance.



Study Closure

When a study is completed, the Principal Investigator should submit study
completion reports at least 4-6 weeks days after completion of the study.
Completion reports should be submitted using the Study Status Report
Form.



For more information
Refer to Chapter 4.6 Study Closure.



                                                     3.4 POST APPROVAL REPORTING REQUIREMENTS
Today, the world benefits greatly from major advances in medicine through
the conscientious and concerted efforts of the research community to translate
research knowledge into feasible clinical applications. As we benefit from the
fruits of research, and recognize the effort by the research community, no
less appreciation goes to the contribution of research participants. To ensure
that research is continually conducted in a scientifically and ethically robust
manner, guidelines and principles are developed and adhered to widely.
These include the Nuremberg Code (1946), Declaration of Helsinki (1964),
the Belmont Report (1979) and the Singapore Guidelines to Good Clinical
Practice (1998), all unanimously created to facilitate scientifically and ethically
applauded research, that promote respect, beneficence and justice in human
subject research.

In parallel with the demands of excellence in research and research ethics,
the Investigator Manual is written to guide investigators and research team
members on the ethical conduct of research conducted under the oversight of
the National Healthcare Group Domain Specific Review Board (NHG DSRB).

The Manual serves as an essential resource for investigators to carry out
research responsibly. A comprehensive toolkit for best research ethics practice,
this Manual outlines the overall governance of research, provides procedural
guidelines for meeting ethical requirements in research, and offers guidance
on key ethical issues.
4.0
SUBMISSIONS TO DSRB
                                                  4.0




4.1   New Applications
4.2   Study Amendments
4.3   Continuing Review / Renewal
4.4   Unanticipated Problems Involving Risks To
      Subjects Or Others (UPIRTSO)
4.5   Non-Compliance
4.6   Study Closure
4.1      NEW APPLICATIONS

Each DSRB meets once a month, except December . The meetings are held
in the third / fourth week of the month. The submission deadline for new
applications is the first working day of each month, or the next working
day, if the first falls on a weekend or public holiday. For example, for an
application to be reviewed in the month of April, the application must
reach the DSRB office on 1st April.

Only completed applications will be considered for DSRB review.
The Principal Investigator is strongly encouraged to submit his / her
application well before the deadline for submission to allow some time for
the DSRB to check for any missing documents / information. Incomplete
applications that are submitted on the first working day of the month will
be scheduled for review in the following month.

Research studies that qualify for expedited review or applications requesting
for exemption may be submitted at any time of the month.                                   26



  What to Submit?

  The DSRB relies solely on the documentation submitted by Principal
  Investigator for review. Therefore these material must provide the
  DSRB with sufficient information about a research study to assess if it
  adequately meets the DSRB’s criteria for approval.

  A submitted research proposal will be scheduled for DSRB review only
  when the DSRB has determined that the information and materials
  submitted are adequate descriptions of the proposed research.



  All new applications are to be submitted online via
  http://www.b2bresearch.nhg.com.sg




                                                                         4.1 NEW APPLICATIONS
A new application must include the following, but not limited to:

                           a. A duly completed B2BResearch Online DSRB Application Form.

                           b. Consent Document / Application for Waiver of Consent.

                           c. Study Protocol (for clinical trials involving drugs, medical devices
                              and surgical procedure).

                           d. Questionnaires, Surveys, Videotapes and other such research tools
                              (if used).

                           e. Copy of the Approved Grant Application (including DHHS approved
                              Study Protocol and Sample Consent Form, if one exists).

                           f. Investigator Brochure and other available safety information (for
                              industry sponsored clinical trials).

                           g. Recruitment materials intended to be seen or heard by potential
                              subjects, including email solicitations and physician letters (if
27
                              used).

                           h. Written information intended to be provided to subjects (if used).

                           i. Principal Investigator’s CV (the latest in the past one year).




                       For more information
                       Refer to Chapter 13 Appendices for ‘Applicable Fees’.




4.1 NEW APPLICATIONS
In addition, applicants may be requested to submit:

    a. Data Collection Form.

    b. Financial disclosure statement.

    c. Clinical Trial Agreement (industry sponsored research).

    d. Documentation that the study has been disapproved by other
       IRBs.

    e. Translated Consent Document and Translation Certificates (for
       industry sponsored clinical trials).

    f. Any other relevant documentation that the DSRB may specifically
       request.

    g. Any other relevant documentation to be given to subjects when, in
       the judgment of the DSRB, the additional information would add
       meaningfully to the protection of the rights, safety, and / or well-
                                                                                         28
       being of the subjects.



For more information
Details on how to complete the B2BResearch Online DSRB Application
Form are available online at http://www.b2bresearch.nhg.com.sg
(Downloads) and in the Online Manual.




                                                                       4.1 NEW APPLICATIONS
4.2       STUDY AMENDMENTS

                   No deviation from, or changes to the approved study should be implemented
                   without documented approval from the DSRB, except where necessary to
                   eliminate apparent immediate hazard(s) to the study subjects, or when
                   the change(s) involves only logistical or administrative aspects of the study
                   (e.g. change of monitor or telephone number).

                   Any deviation from, or a change of, the approved study to eliminate an
                   immediate hazard should be documented and promptly reported to the
                   DSRB within 7 calendar days.

                   The submitted amendments will be categorized according to the following
                   definitions:

                        a. CATEGORY A (Major Amendments) – Amendments that negativdy
                           affect the risk benefit ratio will be reviewed by Full Board Review.

29
                        b. CATEGORY B (Minor Amendments) – The DSRB will determine
                           if the changes to the protocol affect the risk benefit assessment.
                           Changes to the protocol that pose any increase in risk which is not
                           more than minimal risk or new procedures added that fit within the
                           categories eligible for expedited review, fall into this category.

                        c. CATEGORY C (Administrative Amendments) – Administrative
                           changes such as change in addresses, contacts, etc, and correction
                           of typographical and grammatical errors.

                   Some examples of changes that should be reviewed at a Full Board Meeting
                   include, but are not limited to:

                        a. Amendments that negatively alter the risk benefit ratio.

                        b. Changes to the inclusion / exclusion criteria that add a potentially
                           vulnerable population.

                        c. Major changes to the consent document or process that increases
                           the overall risk to the subjects involved in the study.




4.2 STUDY AMENDMENTS
d. Addition of any study procedures believed to be greater than
        minimal risk.

    e. Increase in study subjects for a study previously reviewed by Full
        Board Review.

    f. Alterations to the drug dose or delivery.

    g. Any other type of amendment to the study that in the opinion of the
        DSRB should be reviewed at a Full Board Meeting.

  A Study Amendment submission must include the following, but not
  limited to:

    a. A duly completed B2BResearch Online DSRB Study Amendment
        Form.

    b. Rationale of proposed amendments.

    c. Amended documents (both tracked and clean versions).                            30

    d. Any other documentation that the DSRB may specifically request.

    e. Any other relevant documentation to be given to subjects when, in
        the judgement of the DSRB, the additional information would add
        meaningfully to the protection of the rights, safety and / or well
        being of the subjects.



For more information
Refer to Chapter 13 Appendices for ‘Applicable Fees’.




                                                                     4.2 STUDY AMENDMENTS
The above conditions are applicable to, but not limited to, amendments
                       made to the protocols, consent documents, study sites and research
                       personnel.



                   For more information
                   Details    on     how    to    complete    the    B2BResearch      Online
                   DSRB      Study    Amendment      Form     are   available    online    at
                   http://www.b2bresearch.nhg.com.sg (Downloads) and in the
                   Online Manual.




31




4.2 STUDY AMENDMENTS
4.3       CONTINUING REVIEW / RENEWAL

The DSRB will conduct continuing review of ongoing research at intervals
appropriate to the degree of risk, but not less than once per year. Continuing
DSRB review is required as long as individually identifiable follow-up data
are collected on subjects enrolled.

The Principal Investigator should submit a completed B2BResearch Online
DSRB Study Status Report Form at least 4-6 weeks before the study approval
period ends (as indicated in the approval letter of the study).

The Principal Investigator applying for renewal of approval of a study
must submit:

     a. A duly completed B2BResearch Online DSRB Study Status Report
        Form.

     b. Any other documents as indicated in B2BResearch Online DSRB
        Study Status Report Form.                                                           32

     c. Any other documentation that the DSRB may specifically request.

     d. Any other relevant documentation to be given to subjects when, in
        the judgment of the DSRB, the additional information would add
        meaningfully to the protection of the rights, safety, and / or well-
        being of the subjects.

  A duly completed B2BResearch Online DSRB Study Status Report Form
  must indicate the status of the study, details of each as follows:

     a. NOT YET INITIATED – No research-related activities have been
        performed since first approval. The Principal Investigator is to
        provide reasons for this status.

     b. ONGOING         –   Research-related    activities   are   still   being
        performed.




                                                               4.3 CONTINUING REVIEW / RENEWAL
c. ENROLMENT CLOSED, SUBJECT FOLLOW UP ONLY – The study
                            is permanently closed to new participants, and all participants
                            have completed research-related interventions, and the research
                            remains active only for long term follow-up.

                        d. LAST PATIENT LAST VISIT OVER, DATA ANALYSIS ONGOING
                            – There will be no more contact with subjects and the remaining
                            research activities are limited to data analysis.

                        e. COMPLETED – There will be no more research activities, including
                            contact with subject or any data analysis. The Principal Investigator
                            must indicate the completion date.

                        f. WITHDRAWN – The study is stopped before DSRB approval is
                            issued. The Principal Investigator is to provide reasons for this
                            status.

                        g. TERMINATED – The study is stopped after DSRB approval is issued.
                            The Principal Investigator is to provide reasons for this status.
33

                      The DSRB takes into consideration the following information about the
                      progress of the study:

                        a. Subject recruitment.

                        b. Number and reasons for withdrawal of subjects.

                        c. Unanticipated problems involving risks to subjects or others
                            (UPIRTSO) including serious adverse events since last review.

                        d. Study Amendments since last review.

                        e. Assessment of the current risk, potential benefits, and the overall
                            risk / benefit ratio of the study.

                        f. Research findings, if any.

                        g. Complaints about the research, if any.

                        h. Non-compliance reports, if any.




4.3 CONTINUING REVIEW / RENEWAL
i. Any other relevant information, especially information about the
          risks associated with the research.

  Data Safety Monitoring Board Reports

  When a clinical trial is subject to oversight by a Data Safety Monitoring
  Board (DSMB) whose responsibilities include review of adverse events,
  interim findings and relevant literature, the DSRB conducting the renewal
  process may request for and rely on a current statement from the DSMB
  indicating that it has reviewed study-wide adverse events, interim
  findings and any recent literature that may be relevant to the research, in
  lieu of requiring that this information be submitted directly to the DSRB.


  However, the DSRB must still receive and review reports of local, on-site
  unanticipated problems involving risks to subjects or others (UPIRTSO)
  and any other information needed to ensure that its continuing review
  is substantive and meaningful. Evaluation reports other than that of a
  DSMB may also be accepted provided the evaluation meets the criteria                     34
  listed above.



For more information
Refer to Chapter 8.4 Data And Safety Monitoring.


Details     on     how      to   complete       the   B2BResearch     Online
DSRB      Study    Status    Report   Form      are   available   online   at
http://www.b2bresearch.nhg.com.sg (Downloads) and in the
Online Manual.




                                                              4.3 CONTINUING REVIEW / RENEWAL
4.4        UNANTICIPATED PROBLEMS INVOLVING
                                RISKS TO SUBJECTS OR OTHERS (UPIRTSO)

                     ADVERSE EVENT – Any untoward or unfavorable medical occurrence in
                     a patient or clinical investigation subject administered a pharmaceutical
                     product and which does not necessarily have a causal relationship with this
                     treatment.

                     UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR
                     OTHERS - A problem that is (1) unexpected, (2) related or possibly related
                     and (3) suggests that the research places subject or others at greater risk of
                     harm.

                        Reportable Events

                        The Principal Investigator is responsible for the accurate documentation,
                        investigation, follow-up and timely reporting of the following problems.
35                      These problems have to be (1) unexpected and (2) related or possibly
                        related to the study:


                        These are not necessarily unanticipated problem involving risks to
                        participants or others. These are the problems that the DSRB wants
                        promptly reported to ensure that among the reported problems will be the
                        problems that are unanticipated problems involving risks to participants
                        or others.


                        Examples:

                           a. Adverse event (any harm experienced by a participant regardless
                              of whether the event was internal (on-site) or external (off-site) and
                              regardless of whether the event meets the FDA definition of “serious
                              adverse event”), which in the opinion of the Principal Investigator
                              are both unexpected and related.

                              i. An unexpected adverse event is one, where the nature and
                                  severity of which is not consistent with information in the
                                  relevant source documents.




4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
ii. An adverse event is “related to the research procedures” when
      there are facts (evidence) or arguments to suggest a causal
      relationship.

b. Information that indicates a change to the risks or potential benefits
   of the research. For example:

   i. An interim analysis or safety monitoring report indicates that
      frequency or magnitude of harms or benefits may be different
      than initially presented to the DSRB.

   ii. A paper is published from another study that shows that the
      risks or potential benefits of your research may be different than
      initially presented to the DSRB.

c. A breach of confidentiality.

d. Change in FDA labeling or withdrawal from marketing of a drug,
   device, or biologic used in a research protocol.
                                                                                          36
e. Change to the protocol taken without prior DSRB review to eliminate
   an apparent immediate hazard to a research participant.

f. Incarceration of a participant in a protocol not approved to enroll
   prisoners.

g. Event that requires prompt reporting to the sponsor.

h. Sponsor imposed suspension for risk.

i. Complaint of a participant when the complaint indicates unexpected
   risks or cannot be resolved by the research team.

j. Protocol violation (meaning an accidental or unintentional change
   to the DSRB approved protocol) that harmed participants or others
   or that indicates participants or others may be at increased risk of
   harm.

k. Unanticipated adverse device effect (any serious adverse effect on
   health or safety or any life-threatening problem or death caused
   by, or associated with, a device, if that effect, problem, or death
   was not previously identified in nature, severity, or degree of


                  4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
incidence in the investigational plan or application [including a
                              supplementary plan or application], or any other unanticipated
                              serious problem associated with a device that relates to the rights,
                              safety, or welfare of subjects).


                     Assessment of Reported Problems

                        The Principal Investigator must make a judgment about the expectedness,
                        of a reported problem. If the problem is an adverse event, the Principal
                        Investigator must make a judgment about the causality of the adverse
                        event. The Principal Investigator must also analyze the event and state
                        whether protocol / consent form revisions are required.

                        ASSESSMENT OF EXPECTEDNESS – The Principal Investigator must
                        state whether the problem is expected or unexpected. An unexpected
                        problem is one, where the nature and severity of which is not consistent
                        with information in the relevant source document (s). For a medicinal
37                      product not yet approved for marketing in Singapore, the Investigator
                        Brochure will serve as the source document. Reports that add significant
                        information on specificity or severity of a known, already documented
                        serious adverse event constitute unexpected events. For example, a
                        problem more specific or more severe than described in the Investigator’s
                        Brochure would be considered unexpected. An unexpected problem is
                        also one that is not consistent with the expected natural progression of any
                        underlying disease, disorder, or condition of the subject(s) experiencing
                        the adverse event and the subject’s predisposing risk factor profile for the
                        adverse event.

                        ASSESSMENT OF CAUSALITY – For adverse events, the Principal
                        Investigator should evaluate the event and assess causality. The expression
                        ‘reasonable causal relationship’ is meant to convey in general that there
                        are facts (evidence) or arguments to suggest a causal relationship. For
                        purposes of reporting, adverse event reports associated with marketed
                        drugs usually imply causality. The following conditions might help to
                        assess causality:




4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
a. The event has a reasonable temporal relationship to the
       intervention.

    b. The event could not have been produced by the underlying disease
       states.

    c. The event could not have been due to other non-study
       interventions.

    d. The event follows a known pattern of response to the intervention.

    e. The event disappears with cessation of intervention.



  Reporting Requirements

  The Principal Investigator must report the reportable events described
  above (i.e. (1) unexpected and (2) related or possibly related) within 7
  days, unless the report involves the death of a local participant, in which
  case the report needs to be provided to the DSRB in 24 hours.                                 38

    a. All problems involving local deaths should be reported immediately
       – within 24 hours after first knowledge by the investigator,
       regardless of the causality and expectedness of the death.

    b. All other problems must be reported as soon as possible but not later
       than 7 calendar days after first knowledge by the investigator.



Special Considerations

In certain circumstances, for example, in studies whereby the study design
requires long term treatment-free follow up till death, the requirement to
report all local deaths, regardless of causality and expectedness of the
death event, within 24 hours of first knowledge by PI, does not provide
additional information that would add meaningfully to the protection of
the rights, safety and / or wellbeing of the subjects. The DSRB may alter




                        4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
the reporting requirements of local deaths, provided that the rights, safety
                     and / or wellbeing of the research participants continues to be protected,
                     and provided that the REC and CMB (where applicable) has approved the
                     specific procedure.

                     Serious Adverse Events (SAE)


                     As an additional requirement for sponsored clinical trials, investigators
                     are required to report the following in accordance with Singapore Good
                     Clinical Practice guidelines.


                     Investigators report all serious adverse events (SAEs) to the sponsor except
                     for those SAEs that the protocol or other document (e.g., Investigator’s
                     Brochure) identifies as not needing immediate reporting. The investigator
                     follows regulatory requirements related to the reporting of unexpected
                     serious adverse drug reactions to the appropriate regulatory authority and
                     the DSRB.
39
                     Investigators report adverse events or laboratory abnormalities identified in
                     the protocol as critical to safety evaluations to the sponsor according to the
                     reporting requirements and within the time periods specified by the sponsor
                     in the protocol.


                     For reports of deaths, the investigator supplies the sponsor and the DSRB
                     with any additional requested information (e.g. autopsy reports and terminal
                     medical reports).



                     For more information
                     Details on how to complete the B2BResearch Online DSRB UPIRTSO Form
                     are available online at http://www.b2bresearch.nhg.com.sg
                     (Downloads) and in the Online Manual.




4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
4.5      NON-COMPLIANCE

All research conducted in NHG institutions should be in compliance with
the research proposal approved by the DSRB, with SGGCP, with NHG
DSRB requirements, institution requirements, and applicable regulations.

COMPLIANCE is adherence to all the trial-related requirements,
good clinical practice requirements, and the applicable regulatory
requirements.

NON-COMPLIANCE is a failure by an Investigator to abide by the policies
and procedures of DSRB or applicable regulations governing the protection
of human subject research.

  Some examples of non-compliance include, but are not limited to:

    a. Failure to obtain approval for research.

    b. Failure to obtain renewal of approval for research.                               40

    c. Failure to obtain informed consent when required.

    d. Failure to file an adverse event report.

    e. Performance of an unapproved research procedure.

    f. Performance of research at an unapproved site.

    g. Failure to submit study amendments for review and approval.

    h. Failure to adhere to the approved protocol.

    i. Any other failure to adhere to regulations, policies, and procedures
       related to research.

  SERIOUS NON-COMPLIANCE is an act or omission to act that has the
  potential to increase a physical, psychological, safety, or privacy risk to
  research participants.




                                                                         4.5 NON-COMPLIANCE
CONTINUING NON-COMPLIANCE is a repeated pattern, act, or
                     omission to act that suggests a future likelihood of reoccurrence of the
                     non-compliance.



                     Reporting to the DSRB

                     The Principal Investigator is encouraged to report conduct of any non-
                     compliance by him / herself, members of the research team or others by
                     submitting a duly completed B2BResearch Online DSRB Non-Compliance /
                     Protocol Deviation Form.

                     Reporter’s name will not be disclosed to the individuals involved in the
                     non-compliance event, unless disclosure is required to reconcile the
                     situation.

                     The DSRB may receive an allegation / a report of non-compliance by
                     many means that include, but are not limited to:
41
                       a. Voluntary notification by the Principal Investigator.

                       b. The Principal Investigator’s non-response to DSRB’s queries /
                           reminders for renewal.

                       c. Information given by other staff of the institution.

                       d. Information given by other members of the research team.

                       e. Monitoring reports.

                       f. Audit reports.

                       g. Complaints from research subjects.

                     If the non-compliance is valid and is neither serious nor continuing, the
                     DSRB will require the Principal Investigator to provide an explanation
                     and outline a corrective action to avoid repeating the non-compliance. If




4.5 NON-COMPLIANCE
the Principal Investigator’s reply is not satisfactory or is not forthcoming,
this is handled as a serious / continuing non-compliance.

If the allegation of non-compliance is determined to be serious or
continuing, the DSRB will conduct an inquiry and will provide an
opportunity to the Principal Investigator to respond in person at a
convened meeting, informal conference or in writing.



Outcome of DSRB Inquiry

If the DSRB accepts the Principal Investigator’s explanation, the DSRB will
inform the Principal Investigator within 30 days from the date the DSRB
receives the explanation.


If the DSRB rejects the Principal Investigator’s explanation, or if the
Principal Investigator fails to respond within the stipulated timeframe,
the DSRB will determine if the Principal Investigator should remain
                                                                                         42
eligible to continue to conduct research studies at institutions under
DSRB governance and make a recommendation for further actions that
include, but are not limited to:

  a. Referring the study for an independent audit.

  b. Modification of the Study Protocol.

  c. Modification of the information disclosed during the consent
     process.

  d. Additional information provided to past participants.

  e. Notification of current participants (required when such information
     may relate to participants’ willingness to continue to take part in
     the research).

  f. Requirement that current participants re-consent to participation.

  g. Modification of the continuing review schedule.




                                                                         4.5 NON-COMPLIANCE
h. Monitoring of the research.

                         i. Monitoring of the consent.

                         j. Suspension of the research.

                         k. Termination of the research.

                         l. Obtaining more information pending a final decision.

                         m. Referral to other organizational entities (e.g. legal counsel, risk
                            management, institutional official).

                         n. Mandating the Investigator to attend training programmes.

                         o. Requiring the Investigator to work with a senior researcher (mentor)
                            for a period of time.

                         p. Disqualifying the Investigator from conducting any research for a
                            period of time.
43
                         q. Other actions appropriate for the local context.




                       Special Circumstances

                       UNAPPROVED RESEARCH – When unapproved research is discovered,
                       the DSRB and the institution will act promptly to halt the research, ensure
                       remedial action regarding any breach of regulatory or institutional
                       human subject protection requirements.



                     For more information
                     Details on how to complete the B2BResearch Online DSRB Non
                     Compliance / Protocol Deviation Form are available online at
                     http://www.b2bresearch.nhg.com.sg (Downloads) and in the
                     Online Manual.




4.5 NON-COMPLIANCE
4.6       STUDY CLOSURE
A research study is said to be completed when all of the following
criteria are fulfilled:

     a. The research is permanently closed to the enrollment of new
        participants.

     b. All participants have completed all research-related interventions.

     c. Collection and analysis of individually identifiable data has been
        completed.

When a study is completed, the Principal Investigator should submit study
completion reports 4-6 weeks after completion of the study. Completion
reports should be submitted using the B2BResearch Online DSRB Study
Status Report Form.

The DSRB will review the B2BResearch Online DSRB Study Status Report
Form and obtain any outstanding information or documentation from
                                                                                               44
the Principal Investigator. If there are inconsistencies or if clarification is
needed, the DSRB will request additional information.


  Study Suspension / Termination by Institution,
  Principal Investigator or Sponsor

  When a study is suspended or terminated by the Institution, Principal
  Investigator or the sponsor, the Principal Investigator should submit a
  report within 7 days.


  Expired Study

  If a Principal Investigator has failed to provide continuing review information
  to the DSRB or the DSRB has not approved a research study by the specified
  approval expiry date, the DSRB approval expires. No research activities,
  including recruitment, advertising screening, enrollment, interventions,
  interactions, and collection of identifiable data can occur on the expiration
  date or after, unless specific permission is granted by the DSRB.


  Study Suspension / Termination by DSRB

  The DSRB may decide, at a convened meeting to suspend or terminate

                                                                                4.6 STUDY CLOSURE
a study that is not being conducted in accordance with the DSRB’s
                     requirements or that has been associated with unexpected serious harm
                     to the research subjects. However, the DSRB may suspend / terminate a
                     research on an urgent basis, to eliminate immediate harm to subjects.
                     This would be reported to the DSRB at the next convened meeting.

                     Some examples of situations when a DSRB may suspend / terminate a
                     research study include, but not limited to:

                       a. Inappropriate involvement of human subjects in research.

                       b. Inhibition of the rights or welfare of participants.

                       c. Serious or continuing non-compliance with regulations or DSRB
                          policies.

                       d. New information regarding increased risk to human participants.

                       e. Expiry of approval.
45
                     Reactivation following Suspension

                     The Sponsor / PI may request to reactivate studies that were put on hold
                     either by the Sponsor / PI themselves or by the DSRB. The request for
                     reactivation will be reviewed either as a continuing review or as a new
                     study submission based on the following considerations:

                       a. Duration since suspension.

                       b. Circumstances surrounding suspension.

                       c. Enrollment status of the study.

                       d. Level of risk involved in the study.

                       e. Any other issue deemed significant by the IRB membership.


                    For more information
                    Details   on    how  to complete the B2BResearch  Online
                    DSRB Study Status Report Form are available online at
                    http://www.b2bresearch.nhg.com.sg (Downloads) and in the
                    Online Manual.


4.6 STUDY CLOSURE
5.0
REVIEW PROCESS
                              5.0


5.1   Exempt Review
5.2   Non-Exempt Review
5.3   Criteria For Approval
5.1      EXEMPT REVIEW

The DSRB may determine that a research activity that falls under any of the
following categories qualifies for exemption:


Categories of Research

  EXEMPTION CATEGORY 1 – NORMAL EDUCATIONAL PRACTICES
  AND SETTINGS - Research conducted in established or commonly
  accepted educational settings, involving normal educational practices,
  such as:

    a. Research     on    regular   and   special   education    instructional
        strategies and;

    b. Research on the effectiveness of or the comparison among
        instructional techniques, curricula, or classroom management
        methods.
                                                                                            46

  EXEMPTION CATEGORY 2 – ANONYMOUS EDUCATIONAL TESTS,
  SURVEYS, INTERVIEWS, OR OBSERVATIONS - Research involving the
  use of educational tests (cognitive, diagnostic, aptitude, achievement),
  survey procedures, interview procedures, or observations of public
  behaviour, unless:

    a. Information obtained is recorded in such a manner that human
        subjects can be identified, directly or indirectly through identifiers
        linked to the subjects.

    b. Any disclosure of the human subjects’ responses outside of the
        research could reasonably place subjects at risk of criminal or
        civil liability or be damaging to the subjects’ financial standing,
        employability, or reputation.




                                                                             5.1 EXEMPT REVIEW
EXEMPTION CATEGORY 3 – IDENTIFIABLE SUBJECTS IN SPECIAL
                    CIRCUMSTANCES - Research involving the use of educational tests,
                    (cognitive, diognostic, aptitude, achievement), survey procedures,
                    interview procedures, or observation of public behavior that is not
                    exempted under Excemption Category 2, if:

                      a. The human subjects are elected or appointed public officials or
                         candidates for public office.

                      b. Statute(s) require(s) without exception that the confidentiality of the
                         personally identifiable information will be maintained throughout
                         the research and thereafter.

                    EXEMPTION CATEGORY 4 – COLLECTION OF EXISTING DATA -
                    Research involving the collection or study of existing data, documents,
                    records, pathological specimens, or diagnostic specimens, if these
                    sources are publicly available or if the information is recorded by the
                    investigator in such a manner that subjects cannot be identified, directly
47                  or through identifiers linked to the subjects. The reviewed material should
                    be in existence at the time the research is proposed and should not be
                    prospectively collected.

                    EXEMPTION CATEGORY 5 – PUBLIC BENEFIT OR SERVICE PROGRAMS
                    Research and demonstration projects which are conducted by or subject
                    to the approval of department or agency heads, and which are designed
                    to study, evaluate, or otherwise examine:

                      a. Public benefit or service programs.

                      b. Procedures for obtaining benefits or services under those
                         programs.

                      c. Possible changes in or alternatives to those programs or
                         procedures.

                      d. Possible changes in methods or levels of payment for benefits or
                         services under those programs.




5.1 EXEMPT REVIEW
EXEMPTION CATEGORY 6 – TASTE AND FOOD EVALUATION
  AND ACCEPTANCE STUDIES - Taste and food quality evaluation and
  consumer acceptance studies,

     a. if wholesome foods without additives are consumed, or

     b. if a food is consumed that contains a food ingredient at or below
         the level and for a use found to be safe, or agricultural chemical or
         environmental contaminant at or below the level found to be safe.



  Special Circumstances

  The criteria for exemption do not apply for:

     a. Research involving prisoners.

     b. Research involving children when the research involves survey or
         interview procedures or observations of public behaviour, except
         when the investigator(s) do not participate in the activities being                        48
         observed.

     c. FDA-regulated research.

  The determination of whether a research study meets the criteria for
  Exempt Review is made by the DSRB.



For more information
Details     on    h ow     to   complete        the    B2 BR e s e a rc h   O n l in e
D SRB E x e mp t Ap p l i c a t i o n F o r m a r e a v a i l a b l e o n l i n e a t
http://www.b2bresearch.nhg.com.sg (Downloads) and in the
Online Manual.




                                                                                     5.1 EXEMPT REVIEW
5.2        NON-EXEMPT REVIEW

                    Expedited Review

                    Expedited Review process may be used for:

                          a. Initial Review of new research proposals.

                          b. Continuing Review.

                          c. Review of Study Amendments.

                          d. Review of Modifications requested by DSRB to secure approval.


                        The DSRB will determine if a proposed research study qualifies for a
                        review by expedited process. To qualify for such, a research proposal
                        must meet the following criteria:

                          a. The research proposal presents no more than minimal risk to
49                           research subjects. Minimal risk is defined as “the probability and
                             magnitude of harm or discomfort anticipated in the research are
                             not greater in and of themselves than those ordinarily encountered
                             in daily life or during the performance of routine physical or
                             psychological examinations or tests”.

                          b. Identification of subjects and / or their responses does not
                             reasonably place them at risk of criminal or civil liability or be
                             damaging to their financial standing, employability, insurability,
                             reputation, or be stigmatizing, unless reasonable and appropriate
                             protections will be implemented so that risks related to invasion
                             of privacy and breach of confidentiality are no greater than
                             minimal.

                          c. The research is not classified.

                          d. The research activity is listed in the Categories of Research stated
                             below.




5.2 NON-EXEMPT REVIEW
Categories of Research

CATEGORY 1 – Clinical studies of drugs and medical devices only when
one of the following is met:

  a. Research on drugs for which an investigational new drug
     application is not required.

  b. Research on a medical device for which an investigational device
     exemption application is not required or the medical device is
     cleared / approved for marketing and the medical device is being
     used in accordance with its cleared / approved labeling.

CATEGORY 2 – Collection of blood samples by finger stick, heel stick,
ear stick, or venipuncture as follows:

  a. From healthy, non-pregnant adults who weigh at least 50 kgs. For
     these subjects, the amounts drawn may not exceed 550 ml in an 8
     week period and collection may not occur more frequently than 2                    50
     times per week.

  b. From other adults and children, considering the age, weight, and
     health of the subjects, the collection procedure, the amount of blood
     to be collected, and the frequency with which it will be collected.
     For these subjects, the amount drawn may not exceed the lesser of
     50 ml or 3 ml per kg in an 8 week period and collection may not
     occur more frequently than 2 times per week.




                                                                     5.2 NON-EXEMPT REVIEW
CATEGORY 3 – Prospective collection of biological specimens for
                        research purposes by noninvasive means.

                        Examples:

                          a. Hair and nail clippings in a non-disfiguring manner.

                          b. Deciduous teeth at time of exfoliation or if routine patient care
                             indicates a need for extraction.

                          c. Permanent teeth if routine patient care indicates a need for
                             extraction.

                          d. Excreta and external secretions (including sweat).

                          e. Uncannulated saliva collected either in an unstimulated fashion or
                             stimulated by chewing gum base or wax or by applying a dilute
                             citric solution to the tongue.

51                        f. Placenta removed at delivery.

                          g. Amniotic fluid obtained at the time of rupture of the membrane
                             prior to or during labor.

                          h. Supra- and subgingival dental plaque and calculus, provided the
                             collection procedure is not more invasive than routine prophylactic
                             scaling of the teeth and the process is accomplished in accordance
                             with accepted prophylactic techniques.

                          i. Mucosal and skin cells collected by buccal scraping or swab, skin
                             swab, or mouth washings.

                          j. Sputum collected after saline mist nebulization.




5.2 NON-EXEMPT REVIEW
CATEGORY 4 – Collection of data through noninvasive procedures (not
involving general anesthesia or sedation) routinely employed in clinical
practice, excluding procedures involving x-rays or microwaves. Where
medical devices are employed, they must be cleared / approved for
marketing. (Studies intended to evaluate the safety and effectiveness
of the medical device are not generally eligible for expedited review,
including studies of cleared medical devices for new indications).

Examples:

  a. Physical sensors that are applied either to the surface of the body
     or at a distance and do not involve input of significant amounts of
     energy into the subject or an invasion of the subject’s privacy.

  b. Weighing or testing sensory acuity.

  c. Magnetic resonance imaging.

  d. Electrocardiography,      electroencephalography,      thermography,
                                                                                         52
     detection of naturally occurring radioactivity, electroretinography,
     ultrasound, diagnostic infrared imaging, doppler blood flow, and
     echocardiography.

  e. Moderate exercise, muscular strength testing, body composition
     assessment, and flexibility testing where appropriate given the
     age, weight, and health of the individual.

CATEGORY 5 – Research involving materials (data, documents,
records, or specimens) that have been collected, or will be collected solely
for non-research purposes (such as medical treatment or diagnosis).

CATEGORY 6 – Collection of data from voice, video, digital, or image
recordings made for research purposes.

CATEGORY 7 – Research on individual or group characteristics
or behavior (including, but not limited to, research on perception,
cognition, motivation, identity, language, communication, cultural




                                                                      5.2 NON-EXEMPT REVIEW
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Nhg+investigator+manual+ +1st+edition

  • 1. INVESTIGATOR MANUAL All That An Investigator Needs To Know
  • 2. 1st Edition: August 2009 © National Healthcare Group, Research & Development Office, Singapore www.b2bresearch.nhg.com.sg All rights reserved. No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise without the permission of NHG Research & Development Office. Participating Institutions Tan Tock Seng Hospital • National University Health System • Institute of Mental Health • National Skin Centre • Alexandra Hospital • National Healthcare Group Polyclinics •
  • 3. Today, the world benefits greatly from major advances in medicine through the conscientious and concerted efforts of the research community to translate research knowledge into feasible clinical applications. As we benefit from the fruits of research, and recognize the effort by the research community, no less appreciation goes to the contribution of research participants. To ensure that research is continually conducted in a scientifically and ethically robust manner, guidelines and principles are developed and adhered to widely. These include the Nuremberg Code (1946), Declaration of Helsinki (1964), the Belmont Report (1979) and the Singapore Guidelines to Good Clinical Practice (1998), all unanimously created to facilitate scientifically and ethically applauded research, that promote respect, beneficence and justice in human subject research. In parallel with the demands of excellence in research and research ethics, the Investigator Manual is written to guide investigators and research team members on the ethical conduct of research conducted under the oversight of the National Healthcare Group Domain Specific Review Board (NHG DSRB). The Manual serves as an essential resource for investigators to carry out research responsibly. A comprehensive toolkit for best research ethics practice, this Manual outlines the overall governance of research, provides procedural guidelines for meeting ethical requirements in research, and offers guidance on key ethical issues.
  • 4. Today, the world benefits greatly from major advances in medicine through the conscientious and concerted efforts of the research community to translate research knowledge into feasible clinical applications. As we benefit from the fruits of research, and recognize the effort by the research community, no less appreciation goes to the contribution of research participants. To ensure that research is continually conducted in a scientifically and ethically robust manner, guidelines and principles are developed and adhered to widely. These include the Nuremberg Code (1946), Declaration of Helsinki (1964), the Belmont Report (1979) and the Singapore Guidelines to Good Clinical Practice (1998), all unanimously created to facilitate scientifically and ethically applauded research, that promote respect, beneficence and justice in human subject research. In parallel with the demands of excellence in research and research ethics, the Investigator Manual is written to guide investigators and research team members on the ethical conduct of research conducted under the oversight of the National Healthcare Group Domain Specific Review Board (NHG DSRB). The Manual serves as an essential resource for investigators to carry out research responsibly. A comprehensive toolkit for best research ethics practice, this Manual outlines the overall governance of research, provides procedural guidelines for meeting ethical requirements in research, and offers guidance on key ethical issues.
  • 5. Chapter 01: Research Governance 1.1 NHG Human Subjects Protection Program (HSPP) 1 1.2 The Role And Structure Of Domain Specific Review Board (DSRB) 2 1.3 The Role Of Institutions (Investigators, Department Representatives, Institutional Representatives) 3 1.4 The Definition Of Research 6 Chapter 02: Principles Of Research Ethics 2.1 Ethical Research 15 2.2 The Belmont Report 16 2.3 Code Of Ethical Practice In Human Biomedical Research 17 Chapter 03: Overview Of Application And Review Process 3.1 Application Process 19 3.2 Review Process 21 3.3 Outcome Of Review 23 3.4 Post Approval Reporting Requirements 24 Chapter 04: Submissions To DSRB 4.1 New Applications 26 4.2 Study Amendments 29 4.3 Continuing Review / Renewal 32 4.4 Unanticipated Problems Involving Risks To Subjects 35 Or Others (UPIRTSO) 4.5 Non-Compliance 40 4.6 Study Closure 44 Chapter 05: Review Process 5.1 Exempt Review 46 5.2 Non-Exempt Review 49 5.3 Criteria For Approval 55 Chapter 06: Outcome Of Review 57 Chapter 07: Appeals To DSRB Decision 58
  • 6. Chapter 08: Guidance On Key Ethical Issues 8.1 Informed Consent 59 8.2 Recruitment Strategy 72 8.3 Risk / Benefit Assessment 76 8.4 Data And Safety Monitoring 79 8.5 Privacy And Confidentiality 84 8.6 Conflict Of Interest 85 8.7 Research In Vulnerable Population 87 8.8 Compensation For Research Related Injuries 103 8.9 Standing Database & Tissue Banking 107 Chapter 09: Minimum Qualifications And Training To Be An Investigator 9.1 Who Can Be A Principal Investigator? 113 9.2 Minimum Training Requirements 115 Chapter 10: Responsibilities Of Investigator 117 Chapter 11: Preparing For Audit 124 Chapter 12: Suggested Readings 127 Chapter 13: Appendices a. Participant Information Sheet Checklist 128 b. Short Form Consent - An Example 132 c. Waiver Of Documentation Of Consent - Examples 134 d. Waiver Of Consent – Examples 136 e. Investigator File Content 138 f. Pre Audit Checklist 142 g. Possible Questions During An Audit 146 h. Study Review Checklist 148 i. Applicable Fees 153
  • 7. 1.0 1.0 RESEARCH GOVERNANCE 1.1 NHG Human Subjects Protection Program (HSPP) 1.2 The Role And Structure Of Domain Specific Review Boards (DSRB) 1.3 The Role Of Institutions (Investigators, Department Representatives, Institutional Representatives) 1.4 The Definition Of Research
  • 8.
  • 9. 1.1 NHG HUMAN SUBJECTS PROTECTION PROGRAM (HSPP) NHG Human Subjects Protection Program (HSPP) aims to promote high quality and ethical research, and to ensure protection of human subjects participating in research in NHG, and all institutions under the oversight of NHG DSRB (herein after referred to as “Institutions”). All parties engaging in research involving human subjects have a part to play to ensure that the rights, safety, and well being of research subjects are safeguarded. The NHG HSPP is under the oversight of the Research Ethics Committee (REC), which is appointed by the NHG Chairmen of Medical Boards (CMB) Committee. The REC develops and implements policies and procedures related to human subjects protection, including both the Domain Specific Review Board (DSRB) and the Research Quality Assurance Program. 1 1.1 NHG HUMAN SUBJECTS PROTECTION PROGRAM (HSPP)
  • 10. 1.2 THE ROLE AND STRUCTURE OF DOMAIN SPECIFIC REVIEW BOARD (DSRB) The DSRB is an independent committee constituted of medical, scientific and nonscientific members, whose responsibility is to ensure the protection of the rights, safety, and well-being of human subjects involved in a research study by, among other things, reviewing, approving, and providing continuing review of research studies, of protocols and amendments, and of the methods and materials to be used in obtaining and documenting informed consent of the research subjects. The DSRB is made up of five or more domains, and the domains are based on broad but related disease groupings. The NHG CMB Committee appoints members to the DSRB. Each domain will consist of at least five (5) members, who collectively have the qualifications and experience to carry out the DSRB’s stated objectives and terms of reference to review and evaluate the ethical and scientific aspects of the 2 proposed research studies. Other officials of institutions which conduct research under the oversight of NHG DSRB, may not override the decision of DSRB (or REC, where applicable). 1.2 THE ROLE AND STRUCTURE OF DOMAIN SPECIFIC REVIEW BOARD (DSRB)
  • 11. 1.3 THE ROLE OF INSTITUTIONS (INVESTIGATORS, DEPARTMENT REPRESENTATIVES, INSTITUTIONAL REPRESENTATIVES) The DSRB, as well as the Institutions, must approve a research proposal before it can be conducted in the Institutions. The protection of human subjects in research is a collaborative effort by DSRB and all Institutions. While the DSRB is an independent review committee responsible for ensuring that the research proposal protects the well-being, safety and rights of the research subjects, each Institution ensures that the proposal is in keeping with its overall research direction, objectives, standards and image. Principal Investigator, Co-Investigators and Other Study Team Members The “Principal Investigator” is the overall responsible person for the 3 proper conduct of research. In general, each study can have only one Principal Investigator who is responsible for the conduct of the clinical study. The other members of the research team should be listed as Co- Investigators / Collaborators. The Principal Investigator, Co-Investigators, and all study team members have the responsibility to comply with DSRB policies and applicable regulatory requirements. For multi-centre studies within NHG, and all institutions under the oversight of NHG DSRB, each institution should have a Site Principal Investigator who is responsible for the conduct of the study in his / her institution. One of the Site PIs should be designated as Principal Investigator for the study, who is responsible for the coordination of investigators at different institutions participating in the multi-centre study, including but not limited to communication with the DSRB. For more information Refer to Chapter 10 Responsibilities of Investigator. 1.3 THE ROLE OF INSTITUTIONS (INVESTIGATORS, DEPARTMENT REPRESENTATIVES, INSTITUTIONAL REPRESENTATIVES)
  • 12. Department Representative The “Department Representative” (DR) plays a key role in assuring that a research study is keeping with the research objectives, image and standards of the relevant departments and institutions. The role of a DR is to provide an overview assessment of the significance, concept, and innovation of a research study; and whether the Principal Investigator is adequately trained, qualified, possesses sufficient time and resources to carry out the research study. The DR will endorse all applications made to the DSRB. The DR would generally be the Head / Chief or Department Research Head of the Principal Investigator’s department. In some departments, alternative persons may be appointed as DRs, provided he / she is able to adequately perform the responsibilities of a DR. Where there is a potential conflict of interest for the DR, the alternative DR or the Reporting Officer of the DR (e.g. Division Head or CMB) should fulfill this role. Where appropriate and available, the Head / Chief of a Division (e.g. 4 Division of Medicine) who oversees several departments may comment in lieu of one of his / her Head / Chief of department. For an application that involves more than one department (whether in the same institution or otherwise), only the DR of the Principal Investigator is required to endorse the application. It is the Principal Investigator’s responsibility to ensure that the DRs of the other departments are in agreement to endorse the research study to be carried out in that department. Wherever appropriate and necessary, the DSRB may require endorsements from the DRs of all participating departments. 1.3 THE ROLE OF INSTITUTIONS (INVESTIGATORS, DEPARTMENT REPRESENTATIVES, INSTITUTIONAL REPRESENTATIVES)
  • 13. Institutional Representative The “Institutional Representative” (IR) is the authority to approve any research study to be conducted in the institution. This authority lies with the CMB and CEO of that institution. The IR considers if the research is in keeping with the institution’s research objectives, image and standards. In general, the IR’s role is not to review the scientific or ethical merits of the research study, which will be considered by the DSRB or a grant approving body (if one is applying for a grant). The IR will endorse all applications made to the DSRB. This authority is generally delegated to either one of the following:- a. the Director of Research (or equivalent), OR b. the Chairperson of a specially appointed committee for this purpose. Where there is a potential conflict of interest for the IR, the CEO/CMB should fulfil this role. 5 For multi-centre studies within NHG, the IRs will endorse the application for his/her institution. In the B2BResearch Online system, the DRs and IRs of each department and institution have been pre-determined by individval departments and institutions to enable automatic routing of applications for endorsement. For more information Details on electronic endorsement process are available online at http://www.b2bresearch.nhg.com.sg (Downloads) and in the Online Manual (for DRs and IRs). 1.3 THE ROLE OF INSTITUTIONS (INVESTIGATORS, DEPARTMENT REPRESENTATIVES, INSTITUTIONAL REPRESENTATIVES)
  • 14. 1.4 THE DEFINITION OF RESEARCH All research involving patients, staff, premises, or facilities of NHG institutions and all Institutions under the oversight of NHG DSRB must be reviewed and approved by NHG DSRB prior to initiation. All research reviewed and approved by the DSRB must comply with NHG DSRB requirements as outlined in the NHG DSRB Investigator Manual. The DSRB requirements are based on Declaration of Helsinki and the ethical principles in the Belmont Report. The DSRB requirements are also compliant with the Bioethics Advisory Committee’s recommendations outlined in the Guidelines for Institution Review Boards, November 2004. Research conducted in NHG may also be subject to other guidelines and applicable regulations such as: a. US Department of Health and Human Services (DHHS) Regulations 45 CFR 46 – when the research is funded by US Federal Funds 6 e.g. funded by NIH, NCI, NIAIDS etc. b. US Food and Drug Administration (FDA) Regulations 21 CFR 56, 21 CFR 50 – when the research is being conducted under an Investigational New Drug (IND) Application or Investigational Device Exemptions (IDE) or when the results of research are intended to be submitted to FDA. c. Singapore Guideline for Good Clinical Practice (SGGCP) – All clinical trials involving medicinal products are subject to SGGCP. d. Medicines Act and Medicines (Clinical Trials) Regulations 2000 – All clinical trials involving medicinal products are subject to the Medicines Act and Medicines (Clinical Trials) Regulations 2000. Medicines Act and Medicines (Clinical Trials) Regulations The definition of clinical trial under Medicines Act (Chapter 176): CLINICAL TRIAL means an investigation or series of investigations consisting of the administration of one or more medicinal products of a particular description by, or under the direction of: 1.4 THE DEFINITION OF RESEARCH
  • 15. a. a doctor or dentist to one or more of his patients; or b. two or more doctors or dentists, each product being administered by or under the direction of one or other of those doctors or dentists to one or more of his patients, where (in any such case) there is evidence that medicinal products of that description have effects which may be beneficial to the patient or patients in question and the administration of the product or products is for the purpose of ascertaining whether, or to what extent the product has, or the products have, those or any other effects, whether beneficial or harmful. MEDICINAL PRODUCT means any substance or article (not being an instrument, apparatus or appliance) which is manufactured, sold, supplied, imported or exported for use wholly or mainly in either or both of the following ways: a. use by being administered to one or more human beings or animals for a medicinal purpose; 7 b. use as an ingredient in the preparation of a substance or article which is to be administered to one or more human beings or animals for a medicinal purpose. MEDICINAL PURPOSE means any one or more of the following purposes: a. treating or preventing disease; b. diagnosing disease or ascertaining the existence, degree or extent of a physiological condition; c. contraception; d. inducing anaesthesia; e. otherwise preventing or interfering with the normal operation of a physiological function, whether permanently or temporarily, and whether by way of terminating, reducing or postponing, or increasing or accelerating, the operation of that function or in any other way. 1.4 THE DEFINITION OF RESEARCH
  • 16. SUBJECT means a person to whom the test material is to be administered in a clinical trial. CLINICAL TRIAL CERTIFICATE (CTC) a. In accordance with the Medicines (Clinical Trials) Regulations, no person shall conduct a clinical trial, without a valid Clinical Trial Certificate (CTC) issued by the Health Sciences Authority. b. The Principal Investigator (holder of the certificate) is responsible for applying to the Health Sciences Authority for the certificate. c. Every Sponsor, Principal Investigator or holder of certificate shall comply with any guidelines or instructions relating to conduct of clinical trials issued by the Health Sciences Authority, including Singapore Guideline for Good Clinical Practice (SGGCP). Depar tment of Health and Human Ser vices 8 (DHHS), USA The definition of research and other related terms under DHHS: RESEARCH is a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalisable knowledge. RESEARCH SUBJECT OR PARTICIPANT is a living individual about whom an investigator conducting research obtains data through intervention or interaction with individual, or identifiable private information. INTERVENTION includes both physical procedures by which data are gathered and manipulations of the participant or participant’s environment that are performed for research purposes. INTERACTION includes communication or interpersonal contact between investigator and participant. PRIVATE INFORMATION includes information about behaviour that occurs in a context in which an individual can reasonably expect that no observation or recording is taking place, and information which has 1.4 THE DEFINITION OF RESEARCH
  • 17. been provided for specific purposes by an individual and which the individual can reasonably expect will not be made public (for example, a medical record). Private information must be individually identifiable (i.e., the identity of the subject is or may readily be ascertained by the investigator or associated with the information) in order for obtaining the information to constitute research involving human subjects. ENGAGED – An institution becomes “engaged” in a particular non- exempt human subjects research when its employees or agents for the purposes of the research project obtain: (1) data about the subjects of the research through intervention or interaction with them; (2) identifiable private information about the subjects of the research; or (3) the informed consent of human subjects for the research. EMPLOYEE OR AGENT – An institution’s employees or agents refer to individuals who: (1) act on behalf of the institution; (2) exercise institutional authority or responsibility; or (3) perform institutionally designated activities. “Employees and agents” can include staff, students, 9 contractors, and volunteers, among others, regardless of whether the individual is receiving compensation. Food and Drug Administration (FDA), USA The definition of clinical investigation and other related terms under FDA: CLINICAL INVESTIGATION is any experiment that involves a test article and one or more human participants and that is one of the following: a. Subject to requirements for prior submission to Food and Drug Administration; or b. Not subject to requirements for prior submission to Food and Drug Administration, but the results of which are intended to be submitted later to, or held for inspection by Food and Drug Administration as part of an application for a research or marketing permit. 1.4 THE DEFINITION OF RESEARCH
  • 18. HUMAN SUBJECT means an individual who is or becomes a participant in research, either as a recipient of the test article or as a control. A subject may be either a healthy individual or a patient. TEST ARTICLE means any drug for human use, biological product for human use, medical device for human use, human food additive, color additive, electronic product, or any other article subject to FDA regulation. UNDER FDA IDE the definition of human subject is a human who participates in an investigation either as individual or on whom or on whose specimen an investigational device is used or as a control. Singapore Guideline for Good Clinical Practice (SGGCP) The definition of clinical trial / study under the SGGCP: 10 CLINICAL TRIAL / STUDY – Any investigation in human subjects intended to discover or verify the clinical, pharmacological and / or other pharmacodynamic effects of an investigational product(s), and / or to identify any adverse reactions to an investigational product(s), and / or to study absorption, distribution, metabolism, and excretion of an investigational product(s) with the object of ascertaining its safety and / or efficacy. The terms clinical trial and clinical study are synonymous. SUBJECT / TRIAL SUBJECT – An individual who participates in a clinical trial; either as a recipient of the investigational product(s) or as a control. Bioethics Advisory Committee (BAC) Guidelines for IRBs The definition of research and other related terms under the BAC: DIRECT HUMAN BIOMEDICAL RESEARCH comprises any kind of human research that involves: 1.4 THE DEFINITION OF RESEARCH
  • 19. a. any direct interference or interaction with the physical body of a human subject, and b. that involves a concomitant risk of physical injury or harm, however remote or minor c. Examples – A research programme would qualify as Direct Human Biomedical Research if it involves i. the administration of any drug (whether it is for the purpose of testing the effects or efficacy of the drug, or ii. whether it is a means for establishing any other objective of the research programme), or iii. the trial or use of a medical device on a human subject, or iv. any test of a human subject’s physiological, emotional or mental responses (not being tests conducted for diagnostic purposes with a view to the therapeutic management of a patient). 11 INDIRECT HUMAN BIOMEDICAL RESEARCH comprises any research that does not qualify as Direct Human Biomedical Research, and a. that involves i. human subjects, or ii. human tissue, or iii. medical, personal or genetic information relating to both identifiable and anonymous individuals, and b. that involves that is undertaken with a view to generating data about i. medical, genetic or biological processes, diseases or conditions in human subjects, or ii. of human physiology, or iii. the safety, efficacy, effect or function of any device, drug, diagnostic, surgical or therapeutic procedure (whether invasive, observational or otherwise); 1.4 THE DEFINITION OF RESEARCH
  • 20. Indirect Human Biomedical Research also comprises of research that is conducted in human subjects whether as one of the objectives or the sole objective, of the research study, trial or activity, and that has the potential to affect the safety, health, welfare, dignity or privacy of i. the human subjects involved in the study, or ii. of donors of human tissue or information used in the research, or iii. of the family members of any of the human subjects or donors thereof, or iv. to which such medical, personal or genetic information relates. Some Examples Activities that involve systematic investigation and are designed to develop or contribute to generalisable knowledge are considered research and 12 will require review and approval by NHG DSRB. This includes clinical trials, epidemiological research, retrospective medical records review research, and genetic research. CASE REPORTS – Case reports do not involve systematic investigation; however the intent is to contribute to generalisable knowledge. Case reports are not considered to be human subjects research. CASE SERIES – A series of 3 or more subjects qualifies as a research project and hence should be submitted for review and approval by the DSRB prior to initiation. DATABASE STUDIES – Research proposals for setting up a database require DSRB review and approval. Databases that are not created for the sole purposes of research do not require review by the DSRB, such databases are termed as Standing Databases and need to be registered with NHG Research and Development Office. However when data from these databases is used for research related projects, each of these projects would require DSRB review prior to initiation. 1.4 THE DEFINITION OF RESEARCH
  • 21. TISSUE REPOSITORIES – Operation of Human Tissue Repositories and its data management centre are subjected to oversight by the DSRB. The DSRB will review and approve protocols specifying the conditions under which data and specimens may be accepted and shared, and ensuring adequate provisions to protect the privacy of subjects and maintain the confidentiality of data. The DSRB will also review and approve a sample collection protocol and consent document. QUALITY ASSESSMENT AND IMPROVEMENT (QA/QI) – Activities designed to determine if aspects of medical practice are in line with established standards are called quality assessment. When an activity is designed to improve the performance of medical practice in relation to an established standard, it is called quality improvement. These projects involve systematic investigation and usually contribute to generalisable knowledge. Any QA or QI activity where participants are subjected to additional risks or burdens beyond usual clinical practice will be reviewed as research. 13 OUTBREAK INVESTIGATIONS – Outbreak investigations are important activities that benefit public health. Subjecting these to research standards might compromise these activities. So such activities are not considered to be research and hence do not require DSRB review. However any interventional studies conducted during an outbreak would require review and approval by the DSRB and / or other clinical Committees. The DSRB will make an effort to expedite the review and approval process for such protocols. DISEASE MANAGEMENT – Disease Management projects that do not require the participants to undergo additional burdens or risks do not require review and approval by the DSRB. INFECTION CONTROL – Investigations carried out as part of an infection control program are not considered as research and these do not require review by the DSRB. 1.4 THE DEFINITION OF RESEARCH
  • 22. Determination of Research Status There are many research-like activities that are conducted as part of quality improvement, infection control, disease management etc., that may not meet the definition of research and hence do not need DSRB review and approval. Further, new innovative therapies used by many doctors during their clinical management of patients, may not necessary meet the definition of research as well. Given the vague boundary between research and non-research, the Principal Investigator must ascertain which regulations are applicable and then apply the definitions for research as described above. When in doubt whether an activity requires DSRB review and approval, the Principal Investigator must write to the DSRB with a summary of the proposal. The DSRB will review the information and make a determination whether or not the described activity meets the definition of research. The DSRB will then send a written notification to the Principal Investigator with the final determination. 14 1.4 THE DEFINITION OF RESEARCH
  • 23. 2.0 2.0 PRINCIPLES OF RESEARCH ETHICS 2.1 Ethical Research 2.2 The Belmont Report 2.3 Code Of Ethical Practice In Human Biomedical Research
  • 24.
  • 25. 2.1 ETHICAL RESEARCH Ethical Research is research that: a. Upholds the core ethical principles of respect for persons, beneficence and justice. b. Protects rights, safety and well-being of human subjects. c. Compliant with all applicable regulations and guidelines. 15 2.1 ETHICAL RESEARCH
  • 26. 2.2 THE BELMONT REPORT The Belmont Report describes THREE core ethical principles for human subject research: a. Respect for persons – recognition of the personal dignity and autonomy of individuals and special protection of these persons with diminished autonomy, e.g. the need to obtain informed consent. b. Beneficence – entails an obligation to protect persons from harm by maximizing anticipated benefits and minimizing possible risks of harm, e.g. the need to engage in a risk / benefit analysis and to minimize risks. c. Justice – requires that the benefits and burdens of research be distributed fairly, e.g. the need to have a reasonable inclusion and exclusion criteria. 16 The NHG Human Subjects Protection Program follows the ethical principles of The Belmont Report. 2.2 THE BELMONT REPORT
  • 27. 2.3 CODE OF ETHICAL PRACTICE IN HUMAN BIOMEDICAL RESEARCH (MOH) The credibility of human biomedical research with society is dependent upon the maintenance of the highest ethical standards in its conduct. Research is ethically justifiable only if it is scientifically sound and does not expose research subjects to unwarranted discomfort or risks without likely benefit to the advancement of biomedical science. Research should also abide by accepted moral standards within the community and be carried out responsibly, in ways that respect and protect the research subjects, and maintain scientific integrity to promote trust and accountability. Researchers have a personal and non-delegable responsibility to ensure the ethical conduct of their research. This Code lays down principles and standards for ethical practice in human biomedical research in Singapore. Researchers should use this Code as a yardstick for their conduct and behavior. In addition, researchers should have an understanding of research ethics, develop the knowledge, skills and attitude needed to 17 manage ethical conflicts, and to consult with colleagues, ethics committees and other experts when ethical issues arise. Researchers are to uphold the principles fundamental to the protection of human subjects. In general, researchers are expected to: a. Respect persons as individuals: i. obtain fully informed consent from subjects who are autonomous; ii. accord due protection to persons with diminished autonomy and who are vulnerable; iii. protect subject privacy and maintain data confidentiality at all times; b. Strive to promote the well-being and safety of human research subjects, protecting them from unnecessary risks, and never let the goals of research undermine this priority; 2.3 CODE OF ETHICAL PRACTICE IN HUMAN BIOMEDICAL RESEARCH
  • 28. c. Abide by local laws, regulations, guidelines and commonly agreed standards of good practice on the conduct of human biomedical research; d. Embody professionalism by upholding integrity, openness, and a commitment to intellectual honesty in the conduct of research, and avoid any actual, potential or apparent conflict of interest; e. Exercise responsible custodianship of resources under their charge and be a responsible steward in the use and management of those resources; f. Treat all fellow researchers with dignity and respect, and managing researchers under their supervision with care; g. Observe the Code in all respects of their professional lives. For more information 18 The Belmont Report is available online at http://www.hhs.gov/ohrp The Code of Ethical Practice in Human Biomedical Research is available online at http://www.moh.gov.sg 2.3 CODE OF ETHICAL PRACTICE IN HUMAN BIOMEDICAL RESEARCH
  • 29. 3.0 3.0 OVERVIEW OF APPLICATION AND REVIEW PROCESS 3.1 Application Process 3.2 Review Process 3.3 Outcome Of Review 3.4 Post Approval Reporting Requirements
  • 30.
  • 31. 3.1 APPLICATION PROCESS Endorsement Process by Institution Prior to making a submission to the DSRB, Investigators are required to obtain endorsements from their Department Representative and Institution Representative. For more information Refer to Chapter 1.3 The Roles of Institutions. Submitting a Research Study to DSRB The submission deadline for new research studies is the first working day of each month (except December), or the next working day, if the first falls on a weekend or public holiday. 19 Research studies that qualify for expedited review, applications with request for exemption, or minor amendments to DSRB approved research studies may be submitted at any time of the month. All new applications are to be submitted online via http://www.b2bresearch.nhg.com.sg Triaging All research studies submitted to the DSRB for review will undergo appropriate in-depth review by triaging the research study to the DSRB that includes expert(s) in the disease group(s) that is (are) being studied in the study. The Principal Investigator should indicate the most appropriate DSRB in the B2BResearch Online Application Form. The DSRB will evaluate the Principal Investigator’s choice of DSRB based on the following considerations: 3.1 APPLICATION PROCESS
  • 32. a. PRINCIPAL INVESTIGATOR’S DISCIPLINE – A research study will be triaged to the DSRB that includes his / her discipline. b. DISEASE STUDIED IN THE RESEARCH STUDY – Depending on the primary disease group that is being studied in the research study, the study will be triaged to the DSRB that includes experts in this disease group. Where there is uncertainty about which domain a study should be triaged to, the decision will be escalated to the Triage Board. The Triage Board is a virtual board consisting of the DSRB chairpersons or their deputies. For more information Refer to Chapter 4.1 New Applications. Details on how to complete the B2BResearch Online DSRB Application 20 Form are available online at http://www.b2bresearch.nhg.com.sg ( D o w n l o ads ) an d i n t h e On l i n e Ma n u a l . Details on the latest information on the disease groupings in DSRB are available online at http://www.b2bresearch.nhg.com.sg. 3.1 APPLICATION PROCESS
  • 33. 3.2 REVIEW PROCESS All research studies submitted will be classified under one of the following review categories: a. Exempt Review b. Expedited Review c. Full Board Review The determination of the review category is made by the DSRB. In general, the determination is based on the level of risk in which research participants is exposed to. Research studies that involve minimal or less than minimal risk are reviewed under the Exempt or Expedited review categories, and studies that involve more than minimal risk are reviewed under Full Board Review category. a. EXEMPT REVIEW – Research studies that involve anonymous 21 surveys & questionnaires, collection or study of anonymous existing data or tissue specimens, where data / tissue are either publicly available or subjects cannot be identified, or Public Benefit Programs may qualify for review by Exempt Review category. b. EXPEDITED REVIEW – Research studies that involve collection of data or biological samples via non-invasive procedures, medical case-notes review, surveys or interviews, may qualify for review by Expedited Review category. c. FULL BOARD REVIEW – Research studies that do not qualify for Exempt or Expedited Review category will be reviewed under Full Board Review category. Such studies may include research studies that involve the study of the safety and efficacy of a medicinal product, medical device, or research study that involve invasive procedures. For more information Refer to Chapter 5.1 Exempt Review and Chapter 5.2 Non-Exempt Review. 3.2 REVIEW PROCESS
  • 34. Review Criteria All research studies that intend to enroll human subjects must meet certain criteria before study procedures can be initiated. The criteria are based on the principles of autonomy, beneficence and justice as discussed in the Belmont Report. In general, a research study must fulfill the following criteria: a. Risks are minimized, and are reasonable in relation to anticipated benefits. b. Selection of subjects are equitable. c. Informed Consent will be sought, and appropriately documented. d. Adequate provision for monitoring of data to ensure safety, protection of privacy of research participants and confidentiality of data collected. 22 e. Additional protection for vulnerable populations. For more information Refer to Chapter 5.3 Criteria for Approval. 3.2 REVIEW PROCESS
  • 35. 3.3 OUTCOME OF REVIEW Following the review of a research study, the DSRB will reach one of the following decisions: a. approve, b. conditionally approve, c. table for next convened meeting, or d. not approve A research study that is reviewed under Exempt or Expedited Review category cannot be disapproved. Instead, it will be escalated to the next level of review or approved with modifications. For more information Refer to Chapter 6.0 Outcome of Review. 23 3.3 OUTCOME OF REVIEW
  • 36. 3.4 POST APPROVAL REPORTING REQUIREMENTS Study Amendments No deviation from, or changes to the approved study should be implemented without documented approval from the DSRB, except where necessary to eliminate apparent immediate hazard(s) to the study subjects, or when the change(s) involves only logistical or administrative aspects of the study (e.g. change of monitor or telephone number). Any deviation from, or a change of, the protocol to eliminate an immediate hazard should be documented and promptly reported to the DSRB within 7 calendar days. For more information Refer to Chapter 4.2 Study Amendments. 24 Continuing Review / Renewal The DSRB will conduct continuing review of ongoing research (except studies reviewed by Exempt Review category) at intervals appropriate to the degree of risk, but not less than once per year. The Principal Investigator should submit a completed DSRB Online Study Status Report Form at least 4-6 weeks before the study approval period ends (as indicated in the approval letter of the study), and in time for DSRB to conduct its review and renew the approval of the study. If an approval expires, no research activities, including screening, enrollment, interventions, interactions, and collection of identifiable data can occur after the expiry date, unless specific permission is granted by the DSRB. For more information Refer to Chapter 4.3 Continuing Review / Renewal. 3.4 POST APPROVAL REPORTING REQUIREMENTS
  • 37. Unanticipated Problems Involving Risks To Subjects Or Others (UPIRTSO) The Principal Investigator is responsible for the accurate documentation, investigation, follow-up and timely reporting of all UPIRTSOs. The criteria for reporting are that the problems have to be (1) unexpected and (2) related or possibly related to study. Special requirements are applicable for reporting of events involving deaths of local research participants. For more information Refer to Chapter 4.4 Unanticipated Problems Invdving Risks To Subjects Or Others (UPIRTSO). Non–Compliance All research should be conducted in compliance with the research study approved by the DSRB, SGGCP, NHG DSRB requirements, institution 25 requirements, and applicable regulations. The Principal Investigator is encouraged to report conduct of any non-compliance by him / herself, members of the research team and others. For more information Refer to Chapter 4.5 Non-Compliance. Study Closure When a study is completed, the Principal Investigator should submit study completion reports at least 4-6 weeks days after completion of the study. Completion reports should be submitted using the Study Status Report Form. For more information Refer to Chapter 4.6 Study Closure. 3.4 POST APPROVAL REPORTING REQUIREMENTS
  • 38. Today, the world benefits greatly from major advances in medicine through the conscientious and concerted efforts of the research community to translate research knowledge into feasible clinical applications. As we benefit from the fruits of research, and recognize the effort by the research community, no less appreciation goes to the contribution of research participants. To ensure that research is continually conducted in a scientifically and ethically robust manner, guidelines and principles are developed and adhered to widely. These include the Nuremberg Code (1946), Declaration of Helsinki (1964), the Belmont Report (1979) and the Singapore Guidelines to Good Clinical Practice (1998), all unanimously created to facilitate scientifically and ethically applauded research, that promote respect, beneficence and justice in human subject research. In parallel with the demands of excellence in research and research ethics, the Investigator Manual is written to guide investigators and research team members on the ethical conduct of research conducted under the oversight of the National Healthcare Group Domain Specific Review Board (NHG DSRB). The Manual serves as an essential resource for investigators to carry out research responsibly. A comprehensive toolkit for best research ethics practice, this Manual outlines the overall governance of research, provides procedural guidelines for meeting ethical requirements in research, and offers guidance on key ethical issues.
  • 39. 4.0 SUBMISSIONS TO DSRB 4.0 4.1 New Applications 4.2 Study Amendments 4.3 Continuing Review / Renewal 4.4 Unanticipated Problems Involving Risks To Subjects Or Others (UPIRTSO) 4.5 Non-Compliance 4.6 Study Closure
  • 40.
  • 41. 4.1 NEW APPLICATIONS Each DSRB meets once a month, except December . The meetings are held in the third / fourth week of the month. The submission deadline for new applications is the first working day of each month, or the next working day, if the first falls on a weekend or public holiday. For example, for an application to be reviewed in the month of April, the application must reach the DSRB office on 1st April. Only completed applications will be considered for DSRB review. The Principal Investigator is strongly encouraged to submit his / her application well before the deadline for submission to allow some time for the DSRB to check for any missing documents / information. Incomplete applications that are submitted on the first working day of the month will be scheduled for review in the following month. Research studies that qualify for expedited review or applications requesting for exemption may be submitted at any time of the month. 26 What to Submit? The DSRB relies solely on the documentation submitted by Principal Investigator for review. Therefore these material must provide the DSRB with sufficient information about a research study to assess if it adequately meets the DSRB’s criteria for approval. A submitted research proposal will be scheduled for DSRB review only when the DSRB has determined that the information and materials submitted are adequate descriptions of the proposed research. All new applications are to be submitted online via http://www.b2bresearch.nhg.com.sg 4.1 NEW APPLICATIONS
  • 42. A new application must include the following, but not limited to: a. A duly completed B2BResearch Online DSRB Application Form. b. Consent Document / Application for Waiver of Consent. c. Study Protocol (for clinical trials involving drugs, medical devices and surgical procedure). d. Questionnaires, Surveys, Videotapes and other such research tools (if used). e. Copy of the Approved Grant Application (including DHHS approved Study Protocol and Sample Consent Form, if one exists). f. Investigator Brochure and other available safety information (for industry sponsored clinical trials). g. Recruitment materials intended to be seen or heard by potential subjects, including email solicitations and physician letters (if 27 used). h. Written information intended to be provided to subjects (if used). i. Principal Investigator’s CV (the latest in the past one year). For more information Refer to Chapter 13 Appendices for ‘Applicable Fees’. 4.1 NEW APPLICATIONS
  • 43. In addition, applicants may be requested to submit: a. Data Collection Form. b. Financial disclosure statement. c. Clinical Trial Agreement (industry sponsored research). d. Documentation that the study has been disapproved by other IRBs. e. Translated Consent Document and Translation Certificates (for industry sponsored clinical trials). f. Any other relevant documentation that the DSRB may specifically request. g. Any other relevant documentation to be given to subjects when, in the judgment of the DSRB, the additional information would add meaningfully to the protection of the rights, safety, and / or well- 28 being of the subjects. For more information Details on how to complete the B2BResearch Online DSRB Application Form are available online at http://www.b2bresearch.nhg.com.sg (Downloads) and in the Online Manual. 4.1 NEW APPLICATIONS
  • 44. 4.2 STUDY AMENDMENTS No deviation from, or changes to the approved study should be implemented without documented approval from the DSRB, except where necessary to eliminate apparent immediate hazard(s) to the study subjects, or when the change(s) involves only logistical or administrative aspects of the study (e.g. change of monitor or telephone number). Any deviation from, or a change of, the approved study to eliminate an immediate hazard should be documented and promptly reported to the DSRB within 7 calendar days. The submitted amendments will be categorized according to the following definitions: a. CATEGORY A (Major Amendments) – Amendments that negativdy affect the risk benefit ratio will be reviewed by Full Board Review. 29 b. CATEGORY B (Minor Amendments) – The DSRB will determine if the changes to the protocol affect the risk benefit assessment. Changes to the protocol that pose any increase in risk which is not more than minimal risk or new procedures added that fit within the categories eligible for expedited review, fall into this category. c. CATEGORY C (Administrative Amendments) – Administrative changes such as change in addresses, contacts, etc, and correction of typographical and grammatical errors. Some examples of changes that should be reviewed at a Full Board Meeting include, but are not limited to: a. Amendments that negatively alter the risk benefit ratio. b. Changes to the inclusion / exclusion criteria that add a potentially vulnerable population. c. Major changes to the consent document or process that increases the overall risk to the subjects involved in the study. 4.2 STUDY AMENDMENTS
  • 45. d. Addition of any study procedures believed to be greater than minimal risk. e. Increase in study subjects for a study previously reviewed by Full Board Review. f. Alterations to the drug dose or delivery. g. Any other type of amendment to the study that in the opinion of the DSRB should be reviewed at a Full Board Meeting. A Study Amendment submission must include the following, but not limited to: a. A duly completed B2BResearch Online DSRB Study Amendment Form. b. Rationale of proposed amendments. c. Amended documents (both tracked and clean versions). 30 d. Any other documentation that the DSRB may specifically request. e. Any other relevant documentation to be given to subjects when, in the judgement of the DSRB, the additional information would add meaningfully to the protection of the rights, safety and / or well being of the subjects. For more information Refer to Chapter 13 Appendices for ‘Applicable Fees’. 4.2 STUDY AMENDMENTS
  • 46. The above conditions are applicable to, but not limited to, amendments made to the protocols, consent documents, study sites and research personnel. For more information Details on how to complete the B2BResearch Online DSRB Study Amendment Form are available online at http://www.b2bresearch.nhg.com.sg (Downloads) and in the Online Manual. 31 4.2 STUDY AMENDMENTS
  • 47. 4.3 CONTINUING REVIEW / RENEWAL The DSRB will conduct continuing review of ongoing research at intervals appropriate to the degree of risk, but not less than once per year. Continuing DSRB review is required as long as individually identifiable follow-up data are collected on subjects enrolled. The Principal Investigator should submit a completed B2BResearch Online DSRB Study Status Report Form at least 4-6 weeks before the study approval period ends (as indicated in the approval letter of the study). The Principal Investigator applying for renewal of approval of a study must submit: a. A duly completed B2BResearch Online DSRB Study Status Report Form. b. Any other documents as indicated in B2BResearch Online DSRB Study Status Report Form. 32 c. Any other documentation that the DSRB may specifically request. d. Any other relevant documentation to be given to subjects when, in the judgment of the DSRB, the additional information would add meaningfully to the protection of the rights, safety, and / or well- being of the subjects. A duly completed B2BResearch Online DSRB Study Status Report Form must indicate the status of the study, details of each as follows: a. NOT YET INITIATED – No research-related activities have been performed since first approval. The Principal Investigator is to provide reasons for this status. b. ONGOING – Research-related activities are still being performed. 4.3 CONTINUING REVIEW / RENEWAL
  • 48. c. ENROLMENT CLOSED, SUBJECT FOLLOW UP ONLY – The study is permanently closed to new participants, and all participants have completed research-related interventions, and the research remains active only for long term follow-up. d. LAST PATIENT LAST VISIT OVER, DATA ANALYSIS ONGOING – There will be no more contact with subjects and the remaining research activities are limited to data analysis. e. COMPLETED – There will be no more research activities, including contact with subject or any data analysis. The Principal Investigator must indicate the completion date. f. WITHDRAWN – The study is stopped before DSRB approval is issued. The Principal Investigator is to provide reasons for this status. g. TERMINATED – The study is stopped after DSRB approval is issued. The Principal Investigator is to provide reasons for this status. 33 The DSRB takes into consideration the following information about the progress of the study: a. Subject recruitment. b. Number and reasons for withdrawal of subjects. c. Unanticipated problems involving risks to subjects or others (UPIRTSO) including serious adverse events since last review. d. Study Amendments since last review. e. Assessment of the current risk, potential benefits, and the overall risk / benefit ratio of the study. f. Research findings, if any. g. Complaints about the research, if any. h. Non-compliance reports, if any. 4.3 CONTINUING REVIEW / RENEWAL
  • 49. i. Any other relevant information, especially information about the risks associated with the research. Data Safety Monitoring Board Reports When a clinical trial is subject to oversight by a Data Safety Monitoring Board (DSMB) whose responsibilities include review of adverse events, interim findings and relevant literature, the DSRB conducting the renewal process may request for and rely on a current statement from the DSMB indicating that it has reviewed study-wide adverse events, interim findings and any recent literature that may be relevant to the research, in lieu of requiring that this information be submitted directly to the DSRB. However, the DSRB must still receive and review reports of local, on-site unanticipated problems involving risks to subjects or others (UPIRTSO) and any other information needed to ensure that its continuing review is substantive and meaningful. Evaluation reports other than that of a DSMB may also be accepted provided the evaluation meets the criteria 34 listed above. For more information Refer to Chapter 8.4 Data And Safety Monitoring. Details on how to complete the B2BResearch Online DSRB Study Status Report Form are available online at http://www.b2bresearch.nhg.com.sg (Downloads) and in the Online Manual. 4.3 CONTINUING REVIEW / RENEWAL
  • 50. 4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO) ADVERSE EVENT – Any untoward or unfavorable medical occurrence in a patient or clinical investigation subject administered a pharmaceutical product and which does not necessarily have a causal relationship with this treatment. UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS - A problem that is (1) unexpected, (2) related or possibly related and (3) suggests that the research places subject or others at greater risk of harm. Reportable Events The Principal Investigator is responsible for the accurate documentation, investigation, follow-up and timely reporting of the following problems. 35 These problems have to be (1) unexpected and (2) related or possibly related to the study: These are not necessarily unanticipated problem involving risks to participants or others. These are the problems that the DSRB wants promptly reported to ensure that among the reported problems will be the problems that are unanticipated problems involving risks to participants or others. Examples: a. Adverse event (any harm experienced by a participant regardless of whether the event was internal (on-site) or external (off-site) and regardless of whether the event meets the FDA definition of “serious adverse event”), which in the opinion of the Principal Investigator are both unexpected and related. i. An unexpected adverse event is one, where the nature and severity of which is not consistent with information in the relevant source documents. 4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
  • 51. ii. An adverse event is “related to the research procedures” when there are facts (evidence) or arguments to suggest a causal relationship. b. Information that indicates a change to the risks or potential benefits of the research. For example: i. An interim analysis or safety monitoring report indicates that frequency or magnitude of harms or benefits may be different than initially presented to the DSRB. ii. A paper is published from another study that shows that the risks or potential benefits of your research may be different than initially presented to the DSRB. c. A breach of confidentiality. d. Change in FDA labeling or withdrawal from marketing of a drug, device, or biologic used in a research protocol. 36 e. Change to the protocol taken without prior DSRB review to eliminate an apparent immediate hazard to a research participant. f. Incarceration of a participant in a protocol not approved to enroll prisoners. g. Event that requires prompt reporting to the sponsor. h. Sponsor imposed suspension for risk. i. Complaint of a participant when the complaint indicates unexpected risks or cannot be resolved by the research team. j. Protocol violation (meaning an accidental or unintentional change to the DSRB approved protocol) that harmed participants or others or that indicates participants or others may be at increased risk of harm. k. Unanticipated adverse device effect (any serious adverse effect on health or safety or any life-threatening problem or death caused by, or associated with, a device, if that effect, problem, or death was not previously identified in nature, severity, or degree of 4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
  • 52. incidence in the investigational plan or application [including a supplementary plan or application], or any other unanticipated serious problem associated with a device that relates to the rights, safety, or welfare of subjects). Assessment of Reported Problems The Principal Investigator must make a judgment about the expectedness, of a reported problem. If the problem is an adverse event, the Principal Investigator must make a judgment about the causality of the adverse event. The Principal Investigator must also analyze the event and state whether protocol / consent form revisions are required. ASSESSMENT OF EXPECTEDNESS – The Principal Investigator must state whether the problem is expected or unexpected. An unexpected problem is one, where the nature and severity of which is not consistent with information in the relevant source document (s). For a medicinal 37 product not yet approved for marketing in Singapore, the Investigator Brochure will serve as the source document. Reports that add significant information on specificity or severity of a known, already documented serious adverse event constitute unexpected events. For example, a problem more specific or more severe than described in the Investigator’s Brochure would be considered unexpected. An unexpected problem is also one that is not consistent with the expected natural progression of any underlying disease, disorder, or condition of the subject(s) experiencing the adverse event and the subject’s predisposing risk factor profile for the adverse event. ASSESSMENT OF CAUSALITY – For adverse events, the Principal Investigator should evaluate the event and assess causality. The expression ‘reasonable causal relationship’ is meant to convey in general that there are facts (evidence) or arguments to suggest a causal relationship. For purposes of reporting, adverse event reports associated with marketed drugs usually imply causality. The following conditions might help to assess causality: 4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
  • 53. a. The event has a reasonable temporal relationship to the intervention. b. The event could not have been produced by the underlying disease states. c. The event could not have been due to other non-study interventions. d. The event follows a known pattern of response to the intervention. e. The event disappears with cessation of intervention. Reporting Requirements The Principal Investigator must report the reportable events described above (i.e. (1) unexpected and (2) related or possibly related) within 7 days, unless the report involves the death of a local participant, in which case the report needs to be provided to the DSRB in 24 hours. 38 a. All problems involving local deaths should be reported immediately – within 24 hours after first knowledge by the investigator, regardless of the causality and expectedness of the death. b. All other problems must be reported as soon as possible but not later than 7 calendar days after first knowledge by the investigator. Special Considerations In certain circumstances, for example, in studies whereby the study design requires long term treatment-free follow up till death, the requirement to report all local deaths, regardless of causality and expectedness of the death event, within 24 hours of first knowledge by PI, does not provide additional information that would add meaningfully to the protection of the rights, safety and / or wellbeing of the subjects. The DSRB may alter 4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
  • 54. the reporting requirements of local deaths, provided that the rights, safety and / or wellbeing of the research participants continues to be protected, and provided that the REC and CMB (where applicable) has approved the specific procedure. Serious Adverse Events (SAE) As an additional requirement for sponsored clinical trials, investigators are required to report the following in accordance with Singapore Good Clinical Practice guidelines. Investigators report all serious adverse events (SAEs) to the sponsor except for those SAEs that the protocol or other document (e.g., Investigator’s Brochure) identifies as not needing immediate reporting. The investigator follows regulatory requirements related to the reporting of unexpected serious adverse drug reactions to the appropriate regulatory authority and the DSRB. 39 Investigators report adverse events or laboratory abnormalities identified in the protocol as critical to safety evaluations to the sponsor according to the reporting requirements and within the time periods specified by the sponsor in the protocol. For reports of deaths, the investigator supplies the sponsor and the DSRB with any additional requested information (e.g. autopsy reports and terminal medical reports). For more information Details on how to complete the B2BResearch Online DSRB UPIRTSO Form are available online at http://www.b2bresearch.nhg.com.sg (Downloads) and in the Online Manual. 4.4 UNANTICIPATED PROBLEMS INVOLVING RISKS TO SUBJECTS OR OTHERS (UPIRTSO)
  • 55. 4.5 NON-COMPLIANCE All research conducted in NHG institutions should be in compliance with the research proposal approved by the DSRB, with SGGCP, with NHG DSRB requirements, institution requirements, and applicable regulations. COMPLIANCE is adherence to all the trial-related requirements, good clinical practice requirements, and the applicable regulatory requirements. NON-COMPLIANCE is a failure by an Investigator to abide by the policies and procedures of DSRB or applicable regulations governing the protection of human subject research. Some examples of non-compliance include, but are not limited to: a. Failure to obtain approval for research. b. Failure to obtain renewal of approval for research. 40 c. Failure to obtain informed consent when required. d. Failure to file an adverse event report. e. Performance of an unapproved research procedure. f. Performance of research at an unapproved site. g. Failure to submit study amendments for review and approval. h. Failure to adhere to the approved protocol. i. Any other failure to adhere to regulations, policies, and procedures related to research. SERIOUS NON-COMPLIANCE is an act or omission to act that has the potential to increase a physical, psychological, safety, or privacy risk to research participants. 4.5 NON-COMPLIANCE
  • 56. CONTINUING NON-COMPLIANCE is a repeated pattern, act, or omission to act that suggests a future likelihood of reoccurrence of the non-compliance. Reporting to the DSRB The Principal Investigator is encouraged to report conduct of any non- compliance by him / herself, members of the research team or others by submitting a duly completed B2BResearch Online DSRB Non-Compliance / Protocol Deviation Form. Reporter’s name will not be disclosed to the individuals involved in the non-compliance event, unless disclosure is required to reconcile the situation. The DSRB may receive an allegation / a report of non-compliance by many means that include, but are not limited to: 41 a. Voluntary notification by the Principal Investigator. b. The Principal Investigator’s non-response to DSRB’s queries / reminders for renewal. c. Information given by other staff of the institution. d. Information given by other members of the research team. e. Monitoring reports. f. Audit reports. g. Complaints from research subjects. If the non-compliance is valid and is neither serious nor continuing, the DSRB will require the Principal Investigator to provide an explanation and outline a corrective action to avoid repeating the non-compliance. If 4.5 NON-COMPLIANCE
  • 57. the Principal Investigator’s reply is not satisfactory or is not forthcoming, this is handled as a serious / continuing non-compliance. If the allegation of non-compliance is determined to be serious or continuing, the DSRB will conduct an inquiry and will provide an opportunity to the Principal Investigator to respond in person at a convened meeting, informal conference or in writing. Outcome of DSRB Inquiry If the DSRB accepts the Principal Investigator’s explanation, the DSRB will inform the Principal Investigator within 30 days from the date the DSRB receives the explanation. If the DSRB rejects the Principal Investigator’s explanation, or if the Principal Investigator fails to respond within the stipulated timeframe, the DSRB will determine if the Principal Investigator should remain 42 eligible to continue to conduct research studies at institutions under DSRB governance and make a recommendation for further actions that include, but are not limited to: a. Referring the study for an independent audit. b. Modification of the Study Protocol. c. Modification of the information disclosed during the consent process. d. Additional information provided to past participants. e. Notification of current participants (required when such information may relate to participants’ willingness to continue to take part in the research). f. Requirement that current participants re-consent to participation. g. Modification of the continuing review schedule. 4.5 NON-COMPLIANCE
  • 58. h. Monitoring of the research. i. Monitoring of the consent. j. Suspension of the research. k. Termination of the research. l. Obtaining more information pending a final decision. m. Referral to other organizational entities (e.g. legal counsel, risk management, institutional official). n. Mandating the Investigator to attend training programmes. o. Requiring the Investigator to work with a senior researcher (mentor) for a period of time. p. Disqualifying the Investigator from conducting any research for a period of time. 43 q. Other actions appropriate for the local context. Special Circumstances UNAPPROVED RESEARCH – When unapproved research is discovered, the DSRB and the institution will act promptly to halt the research, ensure remedial action regarding any breach of regulatory or institutional human subject protection requirements. For more information Details on how to complete the B2BResearch Online DSRB Non Compliance / Protocol Deviation Form are available online at http://www.b2bresearch.nhg.com.sg (Downloads) and in the Online Manual. 4.5 NON-COMPLIANCE
  • 59. 4.6 STUDY CLOSURE A research study is said to be completed when all of the following criteria are fulfilled: a. The research is permanently closed to the enrollment of new participants. b. All participants have completed all research-related interventions. c. Collection and analysis of individually identifiable data has been completed. When a study is completed, the Principal Investigator should submit study completion reports 4-6 weeks after completion of the study. Completion reports should be submitted using the B2BResearch Online DSRB Study Status Report Form. The DSRB will review the B2BResearch Online DSRB Study Status Report Form and obtain any outstanding information or documentation from 44 the Principal Investigator. If there are inconsistencies or if clarification is needed, the DSRB will request additional information. Study Suspension / Termination by Institution, Principal Investigator or Sponsor When a study is suspended or terminated by the Institution, Principal Investigator or the sponsor, the Principal Investigator should submit a report within 7 days. Expired Study If a Principal Investigator has failed to provide continuing review information to the DSRB or the DSRB has not approved a research study by the specified approval expiry date, the DSRB approval expires. No research activities, including recruitment, advertising screening, enrollment, interventions, interactions, and collection of identifiable data can occur on the expiration date or after, unless specific permission is granted by the DSRB. Study Suspension / Termination by DSRB The DSRB may decide, at a convened meeting to suspend or terminate 4.6 STUDY CLOSURE
  • 60. a study that is not being conducted in accordance with the DSRB’s requirements or that has been associated with unexpected serious harm to the research subjects. However, the DSRB may suspend / terminate a research on an urgent basis, to eliminate immediate harm to subjects. This would be reported to the DSRB at the next convened meeting. Some examples of situations when a DSRB may suspend / terminate a research study include, but not limited to: a. Inappropriate involvement of human subjects in research. b. Inhibition of the rights or welfare of participants. c. Serious or continuing non-compliance with regulations or DSRB policies. d. New information regarding increased risk to human participants. e. Expiry of approval. 45 Reactivation following Suspension The Sponsor / PI may request to reactivate studies that were put on hold either by the Sponsor / PI themselves or by the DSRB. The request for reactivation will be reviewed either as a continuing review or as a new study submission based on the following considerations: a. Duration since suspension. b. Circumstances surrounding suspension. c. Enrollment status of the study. d. Level of risk involved in the study. e. Any other issue deemed significant by the IRB membership. For more information Details on how to complete the B2BResearch Online DSRB Study Status Report Form are available online at http://www.b2bresearch.nhg.com.sg (Downloads) and in the Online Manual. 4.6 STUDY CLOSURE
  • 61. 5.0 REVIEW PROCESS 5.0 5.1 Exempt Review 5.2 Non-Exempt Review 5.3 Criteria For Approval
  • 62.
  • 63. 5.1 EXEMPT REVIEW The DSRB may determine that a research activity that falls under any of the following categories qualifies for exemption: Categories of Research EXEMPTION CATEGORY 1 – NORMAL EDUCATIONAL PRACTICES AND SETTINGS - Research conducted in established or commonly accepted educational settings, involving normal educational practices, such as: a. Research on regular and special education instructional strategies and; b. Research on the effectiveness of or the comparison among instructional techniques, curricula, or classroom management methods. 46 EXEMPTION CATEGORY 2 – ANONYMOUS EDUCATIONAL TESTS, SURVEYS, INTERVIEWS, OR OBSERVATIONS - Research involving the use of educational tests (cognitive, diagnostic, aptitude, achievement), survey procedures, interview procedures, or observations of public behaviour, unless: a. Information obtained is recorded in such a manner that human subjects can be identified, directly or indirectly through identifiers linked to the subjects. b. Any disclosure of the human subjects’ responses outside of the research could reasonably place subjects at risk of criminal or civil liability or be damaging to the subjects’ financial standing, employability, or reputation. 5.1 EXEMPT REVIEW
  • 64. EXEMPTION CATEGORY 3 – IDENTIFIABLE SUBJECTS IN SPECIAL CIRCUMSTANCES - Research involving the use of educational tests, (cognitive, diognostic, aptitude, achievement), survey procedures, interview procedures, or observation of public behavior that is not exempted under Excemption Category 2, if: a. The human subjects are elected or appointed public officials or candidates for public office. b. Statute(s) require(s) without exception that the confidentiality of the personally identifiable information will be maintained throughout the research and thereafter. EXEMPTION CATEGORY 4 – COLLECTION OF EXISTING DATA - Research involving the collection or study of existing data, documents, records, pathological specimens, or diagnostic specimens, if these sources are publicly available or if the information is recorded by the investigator in such a manner that subjects cannot be identified, directly 47 or through identifiers linked to the subjects. The reviewed material should be in existence at the time the research is proposed and should not be prospectively collected. EXEMPTION CATEGORY 5 – PUBLIC BENEFIT OR SERVICE PROGRAMS Research and demonstration projects which are conducted by or subject to the approval of department or agency heads, and which are designed to study, evaluate, or otherwise examine: a. Public benefit or service programs. b. Procedures for obtaining benefits or services under those programs. c. Possible changes in or alternatives to those programs or procedures. d. Possible changes in methods or levels of payment for benefits or services under those programs. 5.1 EXEMPT REVIEW
  • 65. EXEMPTION CATEGORY 6 – TASTE AND FOOD EVALUATION AND ACCEPTANCE STUDIES - Taste and food quality evaluation and consumer acceptance studies, a. if wholesome foods without additives are consumed, or b. if a food is consumed that contains a food ingredient at or below the level and for a use found to be safe, or agricultural chemical or environmental contaminant at or below the level found to be safe. Special Circumstances The criteria for exemption do not apply for: a. Research involving prisoners. b. Research involving children when the research involves survey or interview procedures or observations of public behaviour, except when the investigator(s) do not participate in the activities being 48 observed. c. FDA-regulated research. The determination of whether a research study meets the criteria for Exempt Review is made by the DSRB. For more information Details on h ow to complete the B2 BR e s e a rc h O n l in e D SRB E x e mp t Ap p l i c a t i o n F o r m a r e a v a i l a b l e o n l i n e a t http://www.b2bresearch.nhg.com.sg (Downloads) and in the Online Manual. 5.1 EXEMPT REVIEW
  • 66. 5.2 NON-EXEMPT REVIEW Expedited Review Expedited Review process may be used for: a. Initial Review of new research proposals. b. Continuing Review. c. Review of Study Amendments. d. Review of Modifications requested by DSRB to secure approval. The DSRB will determine if a proposed research study qualifies for a review by expedited process. To qualify for such, a research proposal must meet the following criteria: a. The research proposal presents no more than minimal risk to 49 research subjects. Minimal risk is defined as “the probability and magnitude of harm or discomfort anticipated in the research are not greater in and of themselves than those ordinarily encountered in daily life or during the performance of routine physical or psychological examinations or tests”. b. Identification of subjects and / or their responses does not reasonably place them at risk of criminal or civil liability or be damaging to their financial standing, employability, insurability, reputation, or be stigmatizing, unless reasonable and appropriate protections will be implemented so that risks related to invasion of privacy and breach of confidentiality are no greater than minimal. c. The research is not classified. d. The research activity is listed in the Categories of Research stated below. 5.2 NON-EXEMPT REVIEW
  • 67. Categories of Research CATEGORY 1 – Clinical studies of drugs and medical devices only when one of the following is met: a. Research on drugs for which an investigational new drug application is not required. b. Research on a medical device for which an investigational device exemption application is not required or the medical device is cleared / approved for marketing and the medical device is being used in accordance with its cleared / approved labeling. CATEGORY 2 – Collection of blood samples by finger stick, heel stick, ear stick, or venipuncture as follows: a. From healthy, non-pregnant adults who weigh at least 50 kgs. For these subjects, the amounts drawn may not exceed 550 ml in an 8 week period and collection may not occur more frequently than 2 50 times per week. b. From other adults and children, considering the age, weight, and health of the subjects, the collection procedure, the amount of blood to be collected, and the frequency with which it will be collected. For these subjects, the amount drawn may not exceed the lesser of 50 ml or 3 ml per kg in an 8 week period and collection may not occur more frequently than 2 times per week. 5.2 NON-EXEMPT REVIEW
  • 68. CATEGORY 3 – Prospective collection of biological specimens for research purposes by noninvasive means. Examples: a. Hair and nail clippings in a non-disfiguring manner. b. Deciduous teeth at time of exfoliation or if routine patient care indicates a need for extraction. c. Permanent teeth if routine patient care indicates a need for extraction. d. Excreta and external secretions (including sweat). e. Uncannulated saliva collected either in an unstimulated fashion or stimulated by chewing gum base or wax or by applying a dilute citric solution to the tongue. 51 f. Placenta removed at delivery. g. Amniotic fluid obtained at the time of rupture of the membrane prior to or during labor. h. Supra- and subgingival dental plaque and calculus, provided the collection procedure is not more invasive than routine prophylactic scaling of the teeth and the process is accomplished in accordance with accepted prophylactic techniques. i. Mucosal and skin cells collected by buccal scraping or swab, skin swab, or mouth washings. j. Sputum collected after saline mist nebulization. 5.2 NON-EXEMPT REVIEW
  • 69. CATEGORY 4 – Collection of data through noninvasive procedures (not involving general anesthesia or sedation) routinely employed in clinical practice, excluding procedures involving x-rays or microwaves. Where medical devices are employed, they must be cleared / approved for marketing. (Studies intended to evaluate the safety and effectiveness of the medical device are not generally eligible for expedited review, including studies of cleared medical devices for new indications). Examples: a. Physical sensors that are applied either to the surface of the body or at a distance and do not involve input of significant amounts of energy into the subject or an invasion of the subject’s privacy. b. Weighing or testing sensory acuity. c. Magnetic resonance imaging. d. Electrocardiography, electroencephalography, thermography, 52 detection of naturally occurring radioactivity, electroretinography, ultrasound, diagnostic infrared imaging, doppler blood flow, and echocardiography. e. Moderate exercise, muscular strength testing, body composition assessment, and flexibility testing where appropriate given the age, weight, and health of the individual. CATEGORY 5 – Research involving materials (data, documents, records, or specimens) that have been collected, or will be collected solely for non-research purposes (such as medical treatment or diagnosis). CATEGORY 6 – Collection of data from voice, video, digital, or image recordings made for research purposes. CATEGORY 7 – Research on individual or group characteristics or behavior (including, but not limited to, research on perception, cognition, motivation, identity, language, communication, cultural 5.2 NON-EXEMPT REVIEW