Assignment on Experimental Study- RCT and Non RCT, Observation Study: Cohort, Case Control, Cross sectional, Roles and responsibilities of Clinical Trial Personnel: Investigator, Study Coordinator, Sponsor, Contract Research Organization and its management Guidelines to the preparation of documents, Preparation of protocol, Investigator Brochure, Case Report Forms, Clinical Study Report Clinical Trial Monitoring-Safety Monitoring in CT
MARGINALIZATION (Different learners in Marginalized Group
Assignment on Clinical trials
1. HISTORY
The first proper clinical trial was conducted by the
physician James Lind. He concluded a dietary
supplement of an acidic quality in the experiment after
two months, sea when the sheep was already afflicated
with scurvy.
Frederick Akbar Mahomad who worked at Guy’s
Hospital in London, made substantial contributions to
the process of clinical trials, where he separated
chronic nephritis with secondary hypertension from
what we now term secondary hypertension.
2. Continue…
The first randomised curative trial was carried out at the
MRC Tuberculosis Research Unit by Sir Geoffrey Marshall .
The trial carried out between 1946-1947, aimed to test the
efficacy of the chemical streptomycin for curing pulmonary
tuberculosis. The trial was both double blind and placebo-
controlled.
The British Medical Research Council officially recognised
the importance of clinical trials from the 1930. The council
established the Therapeutic Trials Committee to advise
and assist in the arrangement of properly controlled
clinical trials on a new products that have value in disease
treatment on experimental ground.
3. INTRODUCTION
Clinical trials is a systematic investigation in human
subjects for evaluating the safety and efficacy of any
new drug.
Clinical trials are a set of test in medical research and
drug development that generate safety and efficacy
data for health interventions in human beings.
4. INTRODUCTION
• Clinical trials are conducted only when satisfactory
information has been gathered on the quality of the
nonclinical safety
• Health authority/ethics committee approval is granted in
the country where approval of the drug is sought
• Clinical trial is the main stay for bringing out new drugs to
the market
5. INTRODUCTION
EXPERIMENTAL UNIT : An experimental unit is usually
referred to as a subject from a targeted population under
study. Therefore the experimental unit is usually used to
specify the intended study population to which the results
of the study are inferred, for example the intended
population could be patients with certain diseases at
certain stages or healthy human subjects.
TREATMENT: In clinical trials a treatment can be a
placebo or any combinations of a new pharmaceutical
identity e.g., a compound or drug, a new diet, a surgical
procedure, a diagnostic test, a medical device, a healthy
education program, no treatment.
6. Continue…
TREATMENT: Other examples include sugical excision,
radiotherapy and chemotherapy as a combination of
surgical procedure and drug therapy for breast cancer;
magnetic resonance imaging (MRI) with a contrast
imaging agent as a combination of diagnostic test and a
drug for enhancement of the efficacy of a diagnostic test.
• EVALUATION: It is recommended that clinical trials
should not only evaluate the effectiveness and safety of the
treatment but also assess quality of life, impact on genetic
factors, pharmaco-economics and outcomes research
associated with treatment.
7. TYPES OF CLINICAL TRIALS
TREATMENT TRIALS: Test experimental treatments,
new combinations of drugs, or new approaches to
surgery or radiation therapy.
PREVENTION TRIALS: Look for better ways to
prevent disease in people who have never had the
disease or to prevent a disease from returning. These
approaches may include medicines, vaccines,
vitamins, minerals, or lifestyle changes.
8. Continue…
DIAGNOSTIC TRIALS : Are conducted to find better
tests or procedures for diagnosing a particular disease
or condition. Diagnostic trials usually include people
who have signs or symptoms of the disease or
condition being studies.
SCREENING (EARLY DETECTION) TRIALS: test
the best way to detect certain diseases or health
conditions.
QUALITY OF LIFE TRIALS( or supportive care
trials): explore ways to improve comfort and the
quality of life for individuals with a chronic illness.
9. PHAES OF CLINICAL TRIALS
Clinical trials involving new drugs are commonly
classified into four phases (I, II, III, & IV) each phase
of the drug approval process is treated as a separate
clinical trial. If the drug successfully passes through
phase I, II and III, it will usually be approved by the
national regulatory authority for use in the general
population .
Phase 4 are post-approval studies. Before
pharmaceutical companies start clinical trials on a
drug, they conduct expensive pre-clinical studies.
14. PHASE 0 STUDY/MICRODOSING
Study of new drug in microdose to derive PK
information in human before undertaking phase 1
studies is called PHASE 0
Microdose: Less than 1/100 of the dose of a test
substance calculated to produce pharmacological
effect with a max dose<100 micrograms
Objective: To obtain preliminary efficacy, toxicity
and pharmacokinetic data
Preclinical Data: Substance toxicity study in one
species by two routes of administration
15. PHASE 0 STUDY
These are very early studies of the pharmacodynamic
and pharmacokinetic properties of a potential drug in
humans.
Microdosing approach could accelerate drug
development without compromising clinical safety.
Microdosing helps researchers select better drug
candidates for clinical trials by providing early human
PK and bioavilability data.
16. STEPS INVOLVED IN DESIGNING A
PRE-CLINICAL STUDY
Identifying a Drug Target: All drugs target specific
points in biochemical pathways. Almost all illness
except infectious diseases are caused by problems
associated with specific biochemical pathways,
identifying the appropriate target step in the
biochemical pathway is critical and can determine the
chances of success of the prospective drug molecule.
17. Continue…
Developing a Bioassay: A bioassay is a live system
that is devised to measure the effects of a drug. It
varies from a cell or tissue culture system to organs or
even a whole living being, for example a zebra fish
embryo can be used to observe the effects of drugs on
bone density, blood vessel growth, among other
systems.
Screening the Drug in Bioassay: This is a screening
test done with the bioassay to determine the safety and
effectiveness of the molecule. The drug must clear this
step.
18. Continue…
Establishing Effective and Toxic Doses: This step
involves establishing the safe and toxic dose ranges.
Future studies takes ideas from here about the dose
ranges to be tested in humans.
Filling for an Approval as an IND (investigation
new drug ): After all these steps are cleared the drug is
fit for an application to the FDA as an IND.
19. PHASE 0 STUDY
Advantages:
1. Less chances of adverse effects
2. Short duration
3. Less number of volunteers
4. Reduced cost of development
5. Reduced drug development time
20. PHASE 0 STUDY
Limitations:
1. Study mainly based on PK parameters- not efficacy
and safety based
2. Agents having different kinetic characterstics
between microdose and full dose are not evaluated
by phase 0 trials
3. Of limited use for agents having Non linear PKs
4. The laboratory parameters are very limited and
expensive researchers have to depend on labs
21. PHASE 1
INTRODUCTION
First stage of testing in human subjects
Designed to asses the safety ,tolerability,PK and PD of
drug
20-25 healthy volunteers
Patients: Anticancer drugs, AIDS therapy
Duration:6-12 months
No blinding/ open labelled
22.
23. PHASE 1 BASIC PRE-REQUISITES
Preclinical data
IND application
Approval by the regulatory authority
Protocol approval by the Ethics Committee
informed consent
Adherence to declaration of ICH-GCP guidelines, at
start as well as from time to time, during the study
24. PHASE 1 STUDY
The aim of a phase 1 trial is to determine the maximum
tolerated dose (MTD) of the new treatment
The MTD is found by escalating the treatment dose
until the dose-limiting toxicity (DLT) is reached.
Kinds of phase 1
SAD : single ascending dose studies
MAD: multiple ascending dose studies
Food effect: investigates differences in caused by food
absorption
25. Phase 1 CT’s are Designed to
obtain following information:
Safety: Determine the most significant adverse events
in human subjects.
Tolerability: the safe dose range is determined by
dose escalations and corresponding serial lab tests.
Pharmacokinetics: How the drug molecule is
absorbed in the body and its metabolites are
distributed and eliminated from the body.
Pharmacodynamics: The effects of the drug on the
body i.e. how the effects of the the drug vary with the
plasma concentration.
26. SINGLE ASCENDING DOSE
STUDIES(SAD)
Small groups of subjects are given a single dose of the
drug while they are observed and tested for a period of
time
If no adverse effects – dose is escalated with 3 new
healthy subjects
If toxicity is observed then – 3 more subjects are given
the same dose
If found toxicity – the dose is considered as max.
tolerated dose (MTD)
27. MULTIPLE ASCENDING DOSE
STUDIES (MAD)
Conducted to understand the pharmacokinetics and
pharmacodynamics of multiple doses of the drug
A group of patients receives multiple low doses of the
drug
Samples of blood and other fluids are collected at
various time points
Analyzed : how the drug is processed within the body
29. LIMITATIONS OF PHASE 1 STUDIES
Trial restricted to homogenous subjects
Performance extrapolated to heterogeneous market
place
30. PHASE 2
Therapeutic extrapolatory trial
20-300 subjects
To confirm effectiveness, monitor side effects ,futher
evaluate safety
First in patients ( who have the disease that the drugs
is expected to treat )
Duration : 6 months to several years
31. PHASE 2 OBJECTIVES
Efficacy in patients ( primary objective)
Safety issues (secondary objectives)
Optimum dose finding-
dose efficacy relationship
Therapeutic dose regimen
Duration of therapy
Frequency of administration
Therapeutic window
32. PHASE 2 STUDIES PRE-REQUISITES
Review of phase 1 data
Innovator/experts
IRB
DCGI
Prior approval by IRB and DCGI is mandatory
For new actions of a marketed drug, start with phase 2
(phase 1 exemption obtained )
33. PHASE 2 STUDY
Phase 2 types:
Phase 2A : designed to assess dosing requirements
(how much drug should be given )
Phase2B : designed to study efficacy ( how well the
drug works at the precribed doses)
34. PHASE 2 CLINICAL TRIAL
PHASE 2A PHASE 2B
Early phase
Pilot clinical trials
20-200 patients
Not multicentric
Single blind comparison
with a standard drug
Late phase
Pivotal clinical trials
50-300 patients
Multicentric
Double blind comparison
with placebo or standard
drug
35. PHASE 3
Therapeutic confirmatory trials
Large scale, multicentre, randomised controlled trials
Target population: several 100 to 3000 patients
Takes a long time : up to 5 years
To establish efficacy of the drug against existing
therapy in larger number of patients , methods of
usage,to collect safety data etc.
36. PHASE 3 OBJECTIVES
To assess overall and relative therapeutic value of the
new drug efficacy, safety and special properties
To determine optimal dosage schedule for use in
general
The dosage schedule in CT’s should be as close as
possible to its anticipated clinical use
37. PHASE 3 : PRE-REQUISITES
Efficacy and dose schedule defined in Phase 2 studies
No gross ADR’s
Long term preclinical safety studies completed –
chronic toxicity, reproductive toxicity and
carcinogenicity
Marketing inputs favorable
IRB and DCGI approval obtained
38. PHASE 3 STUDIES
Phase 3 studies types:
Phase 3A: to get sufficient and significant data.
Phase 3B: allows patients to continue the treatment,
label expansion, additional safety data.
Phase 3B studies are known as “label expansion” to
show the drug works for additional types of
patients/diseases beyond the original use for which
the drug was approved for marketing.
39. PHASE 3
Phase 3A Phase 3B
Prior to NDA
Generates data on safety
and efficacy
• After the NDA but prior to
the approval and launch
These may supplement or
complete the earlier trials
or may be directed to
Phase 4 trials
40. PHASE 3: End of Clinical Trial
Activities
Sponsor: Expert committee review of efficacy, safety
and potential sales (profit)
Go-No Go decision to file new drug application with
DCGI
Expert review by DCGI’s committee
DCGI approval
NCE marketed – phase 4 begins
41. PHASE 4
Done after drug has been marketed
Post marketing Surveillance (PMS)
No fixed durarion/patient population
Studies continue to collect data about effects in various
populations and side effects from long term use
These are primarily observational or non-experimental
in nature
42. PHASE 4 : OBJECTIVES
Confirm the efficacy and safety profile in large
populations during practice
Detect the unknown/rare adverse drug reactions
Evaluations of over-dosage
Identifications of new indications
Dose refinement : evaluation of new formulations,
dosages, durations of treatment
43. PHASE 4 STUDY
Helps to detect rare ADRs, drug interactions
Also to explore new uses for drugs (sometimes called
Phase 5)
Periodic Safety Update Reports
To be submitted by the manufacturer every 6 months
for 2 years and then annually for next 2 years after
marketing approval
Harmful effects discovered may result in a drug being
no longer sold, or restricted to certain uses
44. Continue…
Evaluation in different age groups /types of
patients
Comparative benefit-risk assessment
Benefit-cost assessment (pharmacoeconomics)
Drug usage in the community
Quality of life assessment
45. REPORTING TIMELINES IN INDIA
Clinical trials Post marketing
Site to sponsor: 24 hrs
Site to EC: 7 working days
Sponsor to DCGI: 14
calendar days
Sponsor to other
investigators: 14 calendar
days
Site to sponsor: 24 hrs
Sponsor to DCGI : 15
calendar days
46. REPORTING OF ADR
If health care personal suspects that a particular
medication is associated with an adverse event
observed during the course of caring for a patient , he
can report the ADR to a formal reporting system
Various reporting systems are :
WHO International System
USFDA –Medwatch
INDIA-National Pharmacovigilance Programme
47. CLINICAL TRIALS DESIGN
The basic considerations that needs to be kept in mind
while designing a trial are as follows:
Objective of the Trial: The medical questions that
need to be answered should be clearly formulated so
that necessary resources such as the number of
subjects, study duration, study endpoints for
evaluation of the study drug , facility/equipment, and
clinical inference for addressing these questions, the
objective may be more than one and may be
segregated into primary and secondary as
demonstrated by the example of lung cancer.
48. Continue…
Primary Objectives: This is a randomised, parallel
group trial to demonstrate that the one- year survival
of patients with pre-treated advanced(stage 3B/4)
non-small cell lung cancer (NSCLC) receiving the oral
investigational drug is not inferior to those receiving
intravenous(4) docetaxel.
Secondary Objectives: These are to evaluate overall
survival , time to progression, response rate, time to
response, improvement in quality of life and
qualitative and quantitative toxicities.
49. Continue…
Target Population and Patient Selection: In clinical
trials a set of eligibility criteria is usually developed to
define the target patient population from which
qualified patients can be recruited to enrol the studies.
Typically a set of eligibility criteria is used to roughly
outline the target patient population, while the set of
exclusion criteria is used to fine tune the target patient
population by removing the expected sources of
variability. To be eligible for the intended study,
patients must meet all the inclusion criteria .
50. Continue…
Selection of Controls: In clinical trials, bias and
variability can occur in many ways depending on the
experimental conditions . These have impact on the
accuracy and reliability of statistical and clinical
inference of the trials, since definitive efficacy data
are unobtainable and data on adverse events can be
difficult to interpret.
FDA requires that adequate well controlled clinical
trials be conducted to provide an unbiased and valid
evaluation of the effectiveness and safety of study
medicine.
51. Continue…
Statistical Considerations: At the planning stage some
statistical considerations regarding the manner in which
the data will be tabulated and analysed at the end of the
study should be carefully considered. These considerations
include the primary and secondary response variables, the
criteria for efficacy and safety assessment, sample size
estimation, possible interim analysis and data monitoring,
statistical and clinical inference.
Other Considerations: In addition to these
considerations, some other issues are dependent on
individual trials e.g. treatment duration, patient
compliance, missing value and drop outs.
52. NON-RANDOMISED CONTROLLED
CT’S DESIGNS
In non-randomised controlled trials, participants are
allocated into treatment and control arms by the
investigator. In these trials, control groups can be
concurrent controls or historical controls. When using
a historical control, all subjects in the trial receive the
study medicine: the results are either compared to the
patient’s history for example a patient living with a
chronic illness or a previous study control group.
53. RANDOMISED CONTROLLED CT
DESIGNS
In randomised controlled trials, trial paticipants are
randomly assigned to either treatment or control arms.
The process of randomly assigning a trial participant
to treatment or control arms is called randomisation.
Different tools can be used to randomise (closed
envelops, computer generated sequences, random
numbers). There are two components to
randomisation: the generation of a random sequence
and the implementation of that random sequence,
ideally in a way that keeps participants unware of the
sequence. Randomisation removes potential for bias.
55. DIFFERENT DESIGNS OF TRIALS
Parallel Group Design: A parallel group design is a
complete randomised design in which each patient
receives one and only one treatment in a random
fashion. Basically there are twotypes of parallel group
design for comparative clinical trials, namely, group
comparison (or parallel-group) designs and matched
pairs parallel designs. The simplest group comparison
parallel group design is two group parallel design
which compares two treatments (e.g. a treatment
group vs. a control group). Each treatment group
usually, but not necessarily, contains approximately
the same number of patients.
56. Continue…
Run in Periods : before patients enter in clinical trial,
a run in or lead in period of placebo, no active
treatment, dietary control, or active maintenance
therapy e.g. diuretic and digoxin in heart failure is
usually employed prior to randomisation. The
inclusion of a run in period prior to the active
treatment has the following advantages:
It act as a washout period to remove effects of previous
therapy
It helps in identifying placebo responders
57. Continue…
It can be used to obtain baseline data and to evaluate if
patients fulfils study entry criteria
It can be used as a training period for patients,
investigators and their staff
It provides useful information regarding patient
compliance
It can be used to estimate and compare the magnitude
of possible placebo effects between groups
58. Cross Over Design
In the crossover design each subject is randomized to a
sequence of two or more treatments and hence act as his
own control for treatment comparisons. This simple
manoeuvre is attractive primarily because it reduces the
number of subjects and usually the number of assesments
needed to achieve a specific power, sometimes to a marked
extent. In the simplest 2*2 crossover design each subject
receives each of two treatments in randomised order in two
sucessive treatment periods, often separated by a washout
period. Numerous variations exit, such as designs in which
each subject receives a subset of n>2 treatments or ones in
which treatments are repeated with a subject.
59. Titration Designs
For phase 1 safety and tolerance studies, Rodda et al.
(1988) classify traditional designs as follows:
Rising single dose design
Rising single dose cross over design
Alternative panel rising single dose design
Alternative panel rising single dose cross over design
Parallel panel rising multiple dose design
Alternative panel rising multiple dose design
60. Factorial Designs
In a factorial design two or more treatments are evaluated
simultaneously through the use of varying combinations of
the treatments. The simplest example is 2*2 factorial
design in which subjects are randomly allocated to one of
the four possible combinations of two treatments , A and B
say. These are A alone, B alone, both A and B and neither A
nor B. The statistical test of interaction may lack power to
detect an interaction if the simple size was calculated
based on the test for main effects. This consideration is
important when this design is used for examining the joint
effects A and B in particular, if the treatments are likely to
be used together.
61. Matched Pair Trial Design
In the matched pair design, participants are first
matched in pairs according to certain characteristics.
Then, each member of a pair is randomly assigned to
one of the two different study subgroups. This allows
comparison between similar study participants who
undergo different study procedures.
After screening, participants are matched into pairs.
Within each pair one participant is randomised into
treatment A while the other is randomised onto
treartment B.
62. Stratification
Stratification also allows for comparison between
similar study participants who undergo different study
procedures. All study participants are grouped
according to one or more factors for example age,
gender, lifestyle factors, concomitant medication
before being randomised. This ensures balanced
allocation within each combination.
63. Cluster Sampling
Randomised trials can also use cluster sampling. In
cluster sampling, suitable geographical areas are found
for instance, city, region etc. A number of these
geographical areas are then randomly chosen. For each
of these chosen geoghraphical areas, a proportionate
subsample from the members of the study sample in
that area are chosen and these subsamples are then
combined into a sample group.
64. Withdrawal Trials
In a withdrawal trial, the participant receives a test
treatment for a specified time and are then
randomised to continue either with the test treatment
or a placebo (withdrawal of active tharapy).
During a withdrawal trial, after the first specified
period of time has elapsed, participants are
randomised into two groups, one of which receive the
active treatment.
65. Cohort Studies
A cohort study is a particular form of longitudinal
study (panel study) that sample a cohort ( a group of
people who share a defining characteristic, typically
who experienced a common event in a selected
period,such as birth) performing a cross-section at
intervals through time. A cohort study is a panel study,
but a panel study is not always a cohort study as
individuals in a panel study do not always share a
common characteristic.
A cohort study is a quasi-experiment used in medicine,
nursing, psychology, social science and ecology.
66. Continue…
For instance , in medicine , it is an analysis of risk
factor and follows a group of people who typically do
not have a given disease and uses correlations to
determine the absolute risk of subject contraction. It is
one type of clinical study design and should be
compared with a cross-sectional study. Cohort studies
are largely about the life histories of segments of
populations and the individual people who constitute
these segments.
67. Continue…
Indicators of cohort study:
When there is a strong association between cause and
effect , established by any observational study
When the exposure is rare, but incidence of disease
among exposed is high
When people’s attrition can be minimised
When resources are sample
Cohort studies can be retrospective(looking back in
time) or prospective(requiring the collection of new
data).
68. Continue…
Advantage of prospective cohort study data is that it
can help determine risk factors for contracting a new
disease because it is a longitudinal observation of the
individual through time and the collection of data at
regular intervals so recall error is reduced.
In a cohort study the population under investigation
consists of individuals who are at risk of developing a
specific or health outcome.
69. ROLES AND RESPONSIBILITIES OF
THE CLINICAL RESEARCH TEAM
The Research Team
Need sufficient study staff to perform clinical research
efficiently and effectively:
Appropriate skill set and training
GCP ( Good Clinical Practice ) standards
Follow protocol requirements
70. RESEARCH TEAM
Principal Investigator (PI)
Sub Investigator (Sub I)
Clinical Research Nurse Coordinator (CRNC)
Clinical Research Coordinator (CRC)
Regulatory Coordinator
Key Personnel
71. Principal Investigator
An individual who conducts a clinical investigation or
in the event of an investigation conducted by a team of
individuals is the responsible leader of the team.
Principal Investigators responsibilities can be found in
the following sections of the regulations:
IND trials
IDE trials
ICH E6 Guidelines
The investigator must also be aware of any local rules
or regulation in addition to those outlined in the CFR
72. INVESTIGATOR STATEMENT
A contract between the sponsor and the investigator in
which the investigator agrees to comply with the protocol
and all regulations pertaining to clinical research
Signed before a clinical trial involving an investigational
drug or biologic can begin
Not a regulatory requirement, used frequently in IND
(Investigational New Drug) studies
Investigators participating in IDE (Investigational Device
Exemption) studies do not complete a form FDA , but
similar information is collected by the sponsor sometimes
called an investigator agreement
73. Continued...
Investigators must understand and adhere to federal
regulations.....it’s the law
The regulations are in place to protect the rights, safety
and welfare of study subjects
74. Clinical Research Coordinator
Manages and conducts the day to day study activities
in accordance with the protocol, applicable regulations
and GCP requirements
Vital to the success of a trial
Come from a variety of backgrounds
The responsibilities of CRC have expanded to beyond
the clinical management of subjects to much more
sophisticated expertise in compliance, research
administration, marketing, fiscal and legal activities
75. Continued...
CRC qualities:
Attention to detail
Excellent communication skills
Flexibility
Ability to work independently
Organizational skills
Grit / can do attitude
76. DATA MANAGER
Manage the collection of data throughout the course
of a clinical trial. This person –
Enters the data
Works with the principal investigator and research
nurse to identify what data will be tracked
Provides data to monitoring agencies
Prepares summaries for final data analysis
77. STAFF PHYSICIAN OR NURSE
Helps take care of the patients during a clinical trial.
This person-
Treats patients according to the clinical trial protocol
Assesses and records how each patient responds to the
treatment and the side effects they may have
Works with the principal investigator and research
nurse to report trends of how patients are doing on the
treatment
Manage each patient’s care
78. Additional Research Personnel
Sub-investigator : A member of the research team
designated and supervised by the PI to perform critical
study related procedures and to make important study
related decisions
The FDA regards sub investigators as those individuals
authorized to make medical judgements and decisions
regarding study subjects
CRNC Clinical Research Nurse Coordinator
Certain protocol related activities may require a license
or certificate of training (ex. Administration of
medications or Glasgow Coma Scale)
79. Additional Research Personnel
Regulatory Coordinator/ specialist
Prepares and maintains IRB submissions and
regulatory documents
Tracks study progress in clinical trial management
systems
Key Personnel
Personnel considered to be of primary importance to
the successful conduct of a research project
80. Continued...
DCGI under CDSCO has the Prime responsibility for
regulating CTs in India
Declaration of Helsinki by WMA provides Ethical
Guidelines & Principles to the Physicians, other
participants & Human subjects
ICMR code includes statement of general & specific
principles on research using human subjects in
biomedical research.
81. Continued...
ICH-GCP Guidelines unified standard for EU, Japan &
USA to facilitate the mutual acceptance of Clinical
Data by the Regulatory Authorities in these
jurisdiction
Indian GCP Guidelines are in line with WHO, ICH,
USFDA and European GCP Guidelines as well as ICMR
code
Drugs and Cosmetics Act 1940 & schedule Y tells the
requirement and guidelines on Clinical Trials for
import & manufacture of new drug in India
82. Continued...
Clinical trials are different than routine Medical care
India became a member of WTO in 1995 and agreed to
adhere to product & process patent regime from 2006
India provides excellent environment for CT: in terms
of less cost, speed, quality parameters of global clinical
trials leading to significant growth in clinical trial
outsourcing to India
Study team at trial site include investigator, co-
investigator, study coordinator, nurse, pharmacist.
83. Continued...
Unblinded personnel
(coordination/nurse/pharmacist) are required in
blinded trials for dispensing the trial medications to
the study subjects
Clear delegation of duties to the study team members
is essential for the smooth execution of a clinical trial
84. Continued...
Individual Member of the study team can be delegated
specific trial duties such as :
Administration of ICF
Recruitment of Subjects
Correspondence with EC/CRO/Sponsors
Storage, dispensing & Accountability of Drugs
Completion of source documents
Completion of CRF
Medical Management of the trial subject
85. Continued...
Reporting of SAE (Adverse Events)
Escalations, resolutions, management of deviations
Logistics management
Resolution of data enquiries
Patients visit scheduling, protocol compliance & follow
up
Maintenance of site master file
Compliance with GCP & regulatory guidelines
Tracking of payments/ study grants
86. INFRASTRUCTRUAL REQUIREMENTS
Space for storing trial documents & materials
Communication facility
Local laboratory facility
USG/ Biopsy / CT-Scan /MRI Scan facility
Wards /ICU/ Operation theatre facility
Archival facility
SOP
Lockable trial rooms/ storage cabinets
National or internationally accredited laboratories
Well defined quality control standards
87. Well defined rules & requaltions of the site
SOP for trials & subject recruitment
Recruit study coordinator, research staff
Ensure storage & archival facility
Tripartite/ bipartite agreement
88. Sponsor/CRO forwards the following documents to
the clinical investigator for review & completion:
Study protocol
Patient information sheet & PIC
Investigator brochure
Case record form
Insurance/ indemnity certificate
Patient diaries/ questionnaire
Format of understanding by investigator
89. Draft of CTA between investigator & sponsor/ CRO
Regulatory clearance ( DCGI ) NOC
No. Of copies of above documents for EC application
90. Site is selected for CT after sucessful evaluation of the
site by the sponsor/ CRO
Careful CTA drafting& suggestions can avoid issues
like, payment delays, frequent amendments, retain
dedicated study personnel.
Investigators training meeting is conducted to provide
a uniform understanding of protocol & process to all
the paricipants
91.
92.
93.
94.
95.
96. RESEARCH STUDY DOCUMENTATION
STUDY AND SUBJECT REQUIREMENT:
Study specific should be able to recreate the study
form the study documentation. All study from the
study documentation. All study documents related to
the study are generally found in the regulatory
file/binder.
Subject specific: should tell the story of the subjects
participation in the study and the conduct of the
study. Use case report forms and source records to
document.
97. PROTOCOL LEVEL DOCUMENTATION
REQUIREMENT
ICH-E6 GCP
Investigator : ensure the accuracy, completeness,
legibility and timelines of CRF data and in all required
reports
CRF data is consistent with the source documents or
the discrepancies should be explained
Maintain study documents as specified in Essential
documents or regulatory requirements take measures
to prevent accidental or premature destruction of
these documents.
98. STUDY DOCUMENTATION
To verify that subject rights and welfare were protected
To ensure the integrity and credibility of the collected data
To ensure the study was conducted in compliance with the
protocol, regulations, institutional requirements
All documentation by study staff, including investigators,
coordinators, assistants and anyone who has study related
contact with the participant
Study related documents/data study staff initiate, receive
or send
Documentation by other clinical provider
Documentation by other entities involved in the study
99. REGULATORY DOCUMENTATION
Regulatory files are the repository for a study’s
essential documents.
Before any trial can begin, federal and sponsor
required regulatory documents will be collected
Usually the originals are kept at the site and copies are
provided to the sponsor.
100. Regulatory file
Keep one regulatory file for each study:
Binder
Filling cabinet drawer
Electronic
Documents are filled in order under each main tab and are
organised in reverse chronological order (the most recently
dated item is filled at the front of the section)
As the contents exceed the capacity of one binder or file
box, additional binders/boxes are added. The table of
contents should list the binder or box number in which
each section is located
101. Files will have varying documents depending on
regulations being followed
Subject files are kept separately
Keep file audit ready
102. Required documents
Signed, IRB approved protocol and amendments and
any SOPs if not spelled out in protocol
IRB approved consent forms
IRB approved letters
IRB member roster
Delegation of authority log
Form 1572, if applicable
Financial disclosure forms
Training records of staff
103. Subject specific documentations
Attributable: it should be obvious who wrote or did what
contemporaneous: the notation, signature and date need
to be completed at the same time and as close to event as
possible
Legible: capable of being read
In a human readable format
Print name if signature is illegible
Original: for recording of the information (paper,
electronic)
Accurate: errors have been identified and corrected
104. Source data
All information in original records and certified copies
of original records of clinical findings, observations or
other activities in a clinical trial necessary for the
reconstruction and evaluation of the study
Confirmation of subject existence and observations
Substantiation of study data integrity
105. Source documents
All information in original records and certified copies
of original records ...
Includes clinical findings, observations and other
study activities
The first time data is captured : napkin, report, log,
database
106. Data collection tools
Record of the protocol required data for the study
Forms the basis for analysis of the study data
Standardizes the collection of data to help ensure that
the medical, statistical, regulatory and data
management needs of the study are met
CRF and databases
107. CRF
Can be paper or electronic
Information is complete, accurate and legible
All fields are completed : use ND or NA ( follow SOP)
DIRECT ELECTRONIC DATA CAPTURE
Diaries: participants are asked to enter data into a
device provided by sponsor on regular basis
Collection of direct responses from participants to
questionnaries
Directly enter source information in a database
108. Importance of documentation
Over the past 5 years, 25-30% of all warning letters
from the FDA to investigators were related to
inadequate/inaccurate records
This is the 2nd most sited deficiency in the country
109. RESEARCH DOCUMENTATION
Source documents: are original records and certified
copies of original clinical findings and observations, or
other activities in a clinical trial necessary for the
reconstruction and evaluation of the trial.
Case report form(CRF) : a printed, optical or
electronic document designed to record all of the
protocol required information to be reported to the
sponsor for each trial subject to capture essential
source data about the subject for analysis to answer the
hypothesis of a study.
110. Data management : is the responsibility of the research
staff and a host of other IT professionals related to
collecting, entering, securing and preserving data as a
valuable and reproducible resources for the outcome of the
study
Data integrity: includes the development of policies and
ethical practices for consistent procedures that properly
manage the full data lifecycle needs for the outcome of the
clinical trial. The principal investigator (PI) is the person
responsible for data integrity, but must reply on the team of
research professional in IT and the research coordinator to
uphold the policies.
111. REFRENCE
http://www.google.com
http://www.slideshare.net
Wikipedia
“Publishing and Presenting clinical Research”,third
edition by S. Warren
“Practical Guide to Clinical Data Management”, third
edition by P.S.
“Fundamentals of Clinical Trials”, 4th edition by F.M.
Lawrence