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Good Clinical Practice
Hoang Bao Long, M.D.
Clinical Research Coordinator
Oxford University Clinical Research Unit - Hanoi
ICE-BREAKING
2
IN A NUTSHELL
1. Research ethics
* Research governance and operation
2. Sponsor, IRB and investigator
3. Study documents
4. Obtaining informed consent
5. Adverse events
6. Monitoring
3
GAME 1 IS THIS ACCEPTABLE?
GAME 1: Is this acceptable?
SITUATION 1
• A study requires patients to come back for follow-up.
• Rate of loss-to-follow-up (LTFU) is high.
• Study team’s solution: keep patients’ insurance card until patients
come back.
5
GAME 1: Is this acceptable?
SITUATION 2
• A clinical trial investigating a new therapy.
• A man is asked to join the trial. He is informed that, to date, the
trial is safe; hence, he agrees to participate in the trial. He stays in
the study for some months, then suffers from a severe
complication and dies.
• During his participation, there has been two patients suffering
from serious complications and three mice died in the animal
trial.
6
GAME 1: Is this acceptable?
SITUATION 3
• A study will compensate for patient’s follow-up visit by paying
their transportation fee.
• An investigator thinks that patients living in a near distance will
be paid with less money. Therefore, to reduce the amount of
payment, he excludes patients living in a farther distance even
when they are eligible.
7
GAME 1: Is this acceptable?
• Situation 1:
– Patients have the right to withdraw at any time.
– Violation to respect for persons.
• Situation 2:
– The trial appears to be harmful, yet is continued without any
considerations. The patient is not adequately informed.
– Violation to respect for persons and beneficence.
• Situation 3:
– Patients are not chosen by scientific criteria.
– Violation to justice.
8
PART 1 RESEARCH ETHICS
History of research ethics
Nazi human experimentation:
Nuremberg Code &
Declaration of Helsinki
Tuskegee syphilis
experiment:
Belmont Report
ICH/GCP
10
Belmont Report
1. Respect for persons: autonomy, informed consent
2. Beneficence: “do no harm”, maximizing benefits, minimizing
risks
3. Justice: fair selection
11
Belmont Report – Respect for persons
• Autonomy: research participants can themselves make a choice.
• Coercion:
– Threats (losing care if not participating …)
– Undue inducements (too attractive financial compensation …)
• Protection of vulnerable groups:
– Pregnant women, children
– Prisoners
– Poor/unemployed people
– Ethnic minorities
12
Belmont Report – Beneficence
• Clear risks  NEVER DO
• Risks/benefits consideration:
– Expected benefits outweigh expected risks
– Unexpected adverse events occur: postpone  evaluate  decide
• Benefactors:
– Participants
– Society/community
– Researcher  avoid exploitation
13
Belmont Report – Justice
• Selection of participants: based on scientific criteria
• Equal distribution of risks/benefits
14
Belmont Report
Principles Key issues Process
Respect Autonomy Obtaining informed consent
Beneficence Risks/benefits consideration Design of study protocol
Justice Fair selection Enrollment
15
ICH/GCP
1. Protect research participants: rights, benefits, safety, & health
2. Ensure high-quality research
16
INTRO
RESEARCH GOVERNANCE
AND OPERATION
Steps to conduct a study
Protocol
design
IRB approval &
funding /
sponsoring
Implementation
• Enrollment
• Data collection
• Analysis
• Monitoring
Close-out:
reports,
publishing
Governance vs. Operation
Governance Operation
• Preparing documents:
• Agreements, contracts …
• Regulatory documents
• CRFs, ICFs, patient information
sheets …
• Application for IRB approval
• Filing documents
• Preparing materials & logistics:
• Equipment
• Logistics
• Schedules (training, initiation,
monitoring …)
• Continuous provision of support
to study sites
Research associates Research coordinators
19
PART 2
SPONSOR, IRB AND
INVESTIGATOR
Who contributes to a study?
IRB
• Protect study
participants
Sponsor
• Fund
• Equipment
• Human resources
Investigator
• Enrollment
• Data collection
• …
Sponsor
• Funding
• Provision of human resources and equipment
• Research governance
• Investigational products
• Monitoring
• Insurance and indemnity
22
IRB
• Protect research participants: right, benefits, safety and health
• At least 5 members, with diversities
• Responsibilities:
– Reviewing study protocols
– Monitoring studies
– Making decision regarding studies: delay, request for safety data,
termination …
23
Investigator
• Carrying out studies
• Responsibilities:
– Research participants: healthcare, enrollment, obtaining informed
consent
– IRB: providing required documents, providing periodical reports,
monitoring AEs and SAEs and reporting
– Investigational product: management
– Study protocol: procedures, randomization, blinding, CRFs
24
PART 3 STUDY DOCUMENTS
STUDY
DOCUMENTS
1. Regulatory documents
2. Source documents
3. Study protocol
4. Investigational brochure
1 - Regulatory documents
• Prove:
– Study’s existence
– Legality
– Adherence to GCP and regulations
• Documents:
– Delegation log
– Study protocol, CRFs, ICFs, SOPs
– Agreements, contracts
– Correspondence
27
2 - Source documents
• Prove:
– Research participant’s existence
– Data’s accuracy
• Examples: medical records, test results, CRFs
• Requirements: original, preservable
• CRF can be source documents ONLY IF:
– No other sources can be used
– Defined in study protocol
28
Case Report Form (CRF)
• Data collection
• Two situations:
– Data copied from other documents: define Source documents
– Data written directly onto CRFs: CRF is a source document
• Filling in CRF:
– Easy to read
– Never leave blanks
– Proper correction
29
Case Report Form (CRF)
30
Filling Proper Improper
1. Write the data inside of the blank.
2. Use “x” or “v” to check.
3. Never leave blanks.
4. Correction: cross over the old data by
ONE cross, write the corrected data next
to the old data, and sign and date below
3 - Study protocol
• Investigators: adhere to study protocol
• What if NOT adhere to protocol?
– Any of these TWO consequences?
• Affecting study participants?
• Affecting data’s quality?
– YES: Protocol violation
– NO: Protocol deviation
31
4 - Investigational brochure
• Purposes:
– Application for IRB approval
– Information for investigators
• Requirements:
– Indications, contraindications, interactions, adverse reactions
– Updated annually, esp. AEs and SAEs
– Simple, easy to understand
32
GAME 2
WHEN YOU ARE IN A
RELATIONSHIP WITH
RESEARCH
GAME 2: When you are in a relationship with research
• Three groups:
– (Judge): IRB
– (Millionaire): Sponsor
– (Expert): Investigator
• Summary of a study protocol
GAME 2: When you are in a relationship with research
IRB
• Who are you?
• What documents do you request?
• What questions do you have?
Sponsor
• What documents do you provide?
• What do you need to prepare?
Investigator
• What do you need to do?
35
GAME 2: When you are in a relationship with research
Source documents
• Look at the given CRF.
• What kinds of source documents are required?
36
PART 4
OBTAINING INFORMED
CONSENT
INFORMED
CONSENT
1. A PROCESS
2. A subject VOLUNTARILY confirms
the willingness to participate
3. After having been INFORMED
4. Documented by a WRITTEN,
SIGNED and DATED informed
consent form.
Why to obtain informed consent?
• Evidence for respect for research participants
• Historical examples:
– Henrietta Lacks – HeLa immortal cell line
– Thalidomide – from miscarriage prevention to birth defects
– GlaxoSmithKline – 2004-2012: vaccine experiments on poor children,
orphanage children and soldiers
39
What needs to be done?
1. Inform potential candidates about the study
– “This is a research”
– Study procedure, investigational products (up-to-date)
– Risks/benefits, compensation/reimbursement, confidentiality
– Contact information
2. Spend time for questions
3. Ask for agreement
4. Sign and date in 2 copies of informed consent form (ICF)
5. Provide a copy of ICF
40
Special situations
• Children
– Legal representative
– Assent form (age 12-<18)
• Illiterate subjects
– Thumbprint
– Independent witness
• Subjects with cognitive impairment/coma
– Legal representative
41
What is called “RESPECT”?
• No coercion
– “You’ll receive more of my cares if you join the study” ~ “You’ll
receive less of my cares if you don’t join the study”
– “We’ll give you very much money if you join the study”
• No concealing
– Risks and adverse events
– Future use of samples
• Voluntary participation = voluntary withdrawal
42
Sample of an ICF
43
Sample of an ICF
44
Sample of an ICF
45
Sample of an ICF
46
Sample of an ICF
47
GAME 2: When you are in a relationship with research
• An investigator is to obtain informed consent
• IRB and sponsor: Is the process properly performed?
48
PART 5 ADVERSE EVENTS
ADVERSE
EVENTS
Any signs / symptoms / diseases /
abnormal lab tests
• New
• Worsening
During the study
Severe vs. serious
• Serious:
– Death
– Life-threatening
– Hospitalization (initial / prolonged)
– Disability – significant / persistent
– Congenital anomaly
– Emergency intervention required
• Severe: depending on the scale to each individual condition
51
Severe vs. serious
• Severe but not serious:
– Severe headache (VAS 10)
– Generalized rash, but not with respiratory failure or shock
• Serious but not severe:
– Mild chest pain but requires hospitalization
52
Expected vs. unexpected
• Expected: documented
• Unexpected adverse events:
– Assess relativeness to investigational product:
• Definite
• Likely
• Possible
• Probable
• Unlikely
– Reporting: sponsor, IRB, other study sites, research participants
53
PART 6 MONITORING
When to monitor?
• Pre-implementation monitoring
• Implementation monitoring:
– Regulatory documents
– Study procedures
– CRFs
– ICFs
– AEs, SAEs
– Data entry
• Post-implementation monitoring
55
Why to monitor?
• Research participants:
– Informed consent
– Risks/harms of study procedures
– Sample collection, transfer and storage
• Data quality
– Data collection
– Data entry
• Confidentiality: data storage, data transfer …
• Logistics
56
Monitoring vs. Auditing vs. Inspection
Monitoring Auditing Inspection
Who? Monitor: sponsor,
CRO
Auditor: sponsor,
IRB
Inspector: regulatory
agencies
What? Participants, study
procedures
Study procedures,
monitoring
Suspected problems
Frequency Optional Once throughout
the study
Depending
Report to Sponsor Sponsor, IRB Regulatory agencies
Friendly Serious Punishment
57
GAME 2: When you are in a relationship with research
Situation 1
A patient comes to you on day 3 for follow-up. She doesn’t have
any significant health problems, and just wants to come early.
58
GAME 2: When you are in a relationship with research
Situation 2
Look at this CRF and find out errors in the CRF.
59
GAME 2: When you are in a relationship with research
Situation 3
The research nurse takes 10 mL of blood and separates into 2 tubes.
He sends one tube to one research lab unit for the study lab tests,
and the other tube to another lab unit for another study which
investigates only on blood specimens.
60
GAME 2: When you are in a relationship with research
Situation 4
The pharmacy assistance reveals to the evaluation investigator that
the current patient is in the placebo group.
61
GAME 2: When you are in a relationship with research
Situation 5
A new research nurse doesn’t remember the exact follow-up
duration and makes an appointment with a new patient earlier than
the follow-up days in the protocol. The patient comes back earlier
and is examined. The follow-up CRF is filled in and a blood sample
is taken.
62
GAME 2: When you are in a relationship with research
Situation 6
Look at this ICF and find out errors in the ICF.
63
THE END
Thank you for listening!

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140712 fsh presentation - good clinical practice hoang bao long

  • 1. Good Clinical Practice Hoang Bao Long, M.D. Clinical Research Coordinator Oxford University Clinical Research Unit - Hanoi
  • 3. IN A NUTSHELL 1. Research ethics * Research governance and operation 2. Sponsor, IRB and investigator 3. Study documents 4. Obtaining informed consent 5. Adverse events 6. Monitoring 3
  • 4. GAME 1 IS THIS ACCEPTABLE?
  • 5. GAME 1: Is this acceptable? SITUATION 1 • A study requires patients to come back for follow-up. • Rate of loss-to-follow-up (LTFU) is high. • Study team’s solution: keep patients’ insurance card until patients come back. 5
  • 6. GAME 1: Is this acceptable? SITUATION 2 • A clinical trial investigating a new therapy. • A man is asked to join the trial. He is informed that, to date, the trial is safe; hence, he agrees to participate in the trial. He stays in the study for some months, then suffers from a severe complication and dies. • During his participation, there has been two patients suffering from serious complications and three mice died in the animal trial. 6
  • 7. GAME 1: Is this acceptable? SITUATION 3 • A study will compensate for patient’s follow-up visit by paying their transportation fee. • An investigator thinks that patients living in a near distance will be paid with less money. Therefore, to reduce the amount of payment, he excludes patients living in a farther distance even when they are eligible. 7
  • 8. GAME 1: Is this acceptable? • Situation 1: – Patients have the right to withdraw at any time. – Violation to respect for persons. • Situation 2: – The trial appears to be harmful, yet is continued without any considerations. The patient is not adequately informed. – Violation to respect for persons and beneficence. • Situation 3: – Patients are not chosen by scientific criteria. – Violation to justice. 8
  • 10. History of research ethics Nazi human experimentation: Nuremberg Code & Declaration of Helsinki Tuskegee syphilis experiment: Belmont Report ICH/GCP 10
  • 11. Belmont Report 1. Respect for persons: autonomy, informed consent 2. Beneficence: “do no harm”, maximizing benefits, minimizing risks 3. Justice: fair selection 11
  • 12. Belmont Report – Respect for persons • Autonomy: research participants can themselves make a choice. • Coercion: – Threats (losing care if not participating …) – Undue inducements (too attractive financial compensation …) • Protection of vulnerable groups: – Pregnant women, children – Prisoners – Poor/unemployed people – Ethnic minorities 12
  • 13. Belmont Report – Beneficence • Clear risks  NEVER DO • Risks/benefits consideration: – Expected benefits outweigh expected risks – Unexpected adverse events occur: postpone  evaluate  decide • Benefactors: – Participants – Society/community – Researcher  avoid exploitation 13
  • 14. Belmont Report – Justice • Selection of participants: based on scientific criteria • Equal distribution of risks/benefits 14
  • 15. Belmont Report Principles Key issues Process Respect Autonomy Obtaining informed consent Beneficence Risks/benefits consideration Design of study protocol Justice Fair selection Enrollment 15
  • 16. ICH/GCP 1. Protect research participants: rights, benefits, safety, & health 2. Ensure high-quality research 16
  • 18. Steps to conduct a study Protocol design IRB approval & funding / sponsoring Implementation • Enrollment • Data collection • Analysis • Monitoring Close-out: reports, publishing
  • 19. Governance vs. Operation Governance Operation • Preparing documents: • Agreements, contracts … • Regulatory documents • CRFs, ICFs, patient information sheets … • Application for IRB approval • Filing documents • Preparing materials & logistics: • Equipment • Logistics • Schedules (training, initiation, monitoring …) • Continuous provision of support to study sites Research associates Research coordinators 19
  • 20. PART 2 SPONSOR, IRB AND INVESTIGATOR
  • 21. Who contributes to a study? IRB • Protect study participants Sponsor • Fund • Equipment • Human resources Investigator • Enrollment • Data collection • …
  • 22. Sponsor • Funding • Provision of human resources and equipment • Research governance • Investigational products • Monitoring • Insurance and indemnity 22
  • 23. IRB • Protect research participants: right, benefits, safety and health • At least 5 members, with diversities • Responsibilities: – Reviewing study protocols – Monitoring studies – Making decision regarding studies: delay, request for safety data, termination … 23
  • 24. Investigator • Carrying out studies • Responsibilities: – Research participants: healthcare, enrollment, obtaining informed consent – IRB: providing required documents, providing periodical reports, monitoring AEs and SAEs and reporting – Investigational product: management – Study protocol: procedures, randomization, blinding, CRFs 24
  • 25. PART 3 STUDY DOCUMENTS
  • 26. STUDY DOCUMENTS 1. Regulatory documents 2. Source documents 3. Study protocol 4. Investigational brochure
  • 27. 1 - Regulatory documents • Prove: – Study’s existence – Legality – Adherence to GCP and regulations • Documents: – Delegation log – Study protocol, CRFs, ICFs, SOPs – Agreements, contracts – Correspondence 27
  • 28. 2 - Source documents • Prove: – Research participant’s existence – Data’s accuracy • Examples: medical records, test results, CRFs • Requirements: original, preservable • CRF can be source documents ONLY IF: – No other sources can be used – Defined in study protocol 28
  • 29. Case Report Form (CRF) • Data collection • Two situations: – Data copied from other documents: define Source documents – Data written directly onto CRFs: CRF is a source document • Filling in CRF: – Easy to read – Never leave blanks – Proper correction 29
  • 30. Case Report Form (CRF) 30 Filling Proper Improper 1. Write the data inside of the blank. 2. Use “x” or “v” to check. 3. Never leave blanks. 4. Correction: cross over the old data by ONE cross, write the corrected data next to the old data, and sign and date below
  • 31. 3 - Study protocol • Investigators: adhere to study protocol • What if NOT adhere to protocol? – Any of these TWO consequences? • Affecting study participants? • Affecting data’s quality? – YES: Protocol violation – NO: Protocol deviation 31
  • 32. 4 - Investigational brochure • Purposes: – Application for IRB approval – Information for investigators • Requirements: – Indications, contraindications, interactions, adverse reactions – Updated annually, esp. AEs and SAEs – Simple, easy to understand 32
  • 33. GAME 2 WHEN YOU ARE IN A RELATIONSHIP WITH RESEARCH
  • 34. GAME 2: When you are in a relationship with research • Three groups: – (Judge): IRB – (Millionaire): Sponsor – (Expert): Investigator • Summary of a study protocol
  • 35. GAME 2: When you are in a relationship with research IRB • Who are you? • What documents do you request? • What questions do you have? Sponsor • What documents do you provide? • What do you need to prepare? Investigator • What do you need to do? 35
  • 36. GAME 2: When you are in a relationship with research Source documents • Look at the given CRF. • What kinds of source documents are required? 36
  • 38. INFORMED CONSENT 1. A PROCESS 2. A subject VOLUNTARILY confirms the willingness to participate 3. After having been INFORMED 4. Documented by a WRITTEN, SIGNED and DATED informed consent form.
  • 39. Why to obtain informed consent? • Evidence for respect for research participants • Historical examples: – Henrietta Lacks – HeLa immortal cell line – Thalidomide – from miscarriage prevention to birth defects – GlaxoSmithKline – 2004-2012: vaccine experiments on poor children, orphanage children and soldiers 39
  • 40. What needs to be done? 1. Inform potential candidates about the study – “This is a research” – Study procedure, investigational products (up-to-date) – Risks/benefits, compensation/reimbursement, confidentiality – Contact information 2. Spend time for questions 3. Ask for agreement 4. Sign and date in 2 copies of informed consent form (ICF) 5. Provide a copy of ICF 40
  • 41. Special situations • Children – Legal representative – Assent form (age 12-<18) • Illiterate subjects – Thumbprint – Independent witness • Subjects with cognitive impairment/coma – Legal representative 41
  • 42. What is called “RESPECT”? • No coercion – “You’ll receive more of my cares if you join the study” ~ “You’ll receive less of my cares if you don’t join the study” – “We’ll give you very much money if you join the study” • No concealing – Risks and adverse events – Future use of samples • Voluntary participation = voluntary withdrawal 42
  • 43. Sample of an ICF 43
  • 44. Sample of an ICF 44
  • 45. Sample of an ICF 45
  • 46. Sample of an ICF 46
  • 47. Sample of an ICF 47
  • 48. GAME 2: When you are in a relationship with research • An investigator is to obtain informed consent • IRB and sponsor: Is the process properly performed? 48
  • 49. PART 5 ADVERSE EVENTS
  • 50. ADVERSE EVENTS Any signs / symptoms / diseases / abnormal lab tests • New • Worsening During the study
  • 51. Severe vs. serious • Serious: – Death – Life-threatening – Hospitalization (initial / prolonged) – Disability – significant / persistent – Congenital anomaly – Emergency intervention required • Severe: depending on the scale to each individual condition 51
  • 52. Severe vs. serious • Severe but not serious: – Severe headache (VAS 10) – Generalized rash, but not with respiratory failure or shock • Serious but not severe: – Mild chest pain but requires hospitalization 52
  • 53. Expected vs. unexpected • Expected: documented • Unexpected adverse events: – Assess relativeness to investigational product: • Definite • Likely • Possible • Probable • Unlikely – Reporting: sponsor, IRB, other study sites, research participants 53
  • 55. When to monitor? • Pre-implementation monitoring • Implementation monitoring: – Regulatory documents – Study procedures – CRFs – ICFs – AEs, SAEs – Data entry • Post-implementation monitoring 55
  • 56. Why to monitor? • Research participants: – Informed consent – Risks/harms of study procedures – Sample collection, transfer and storage • Data quality – Data collection – Data entry • Confidentiality: data storage, data transfer … • Logistics 56
  • 57. Monitoring vs. Auditing vs. Inspection Monitoring Auditing Inspection Who? Monitor: sponsor, CRO Auditor: sponsor, IRB Inspector: regulatory agencies What? Participants, study procedures Study procedures, monitoring Suspected problems Frequency Optional Once throughout the study Depending Report to Sponsor Sponsor, IRB Regulatory agencies Friendly Serious Punishment 57
  • 58. GAME 2: When you are in a relationship with research Situation 1 A patient comes to you on day 3 for follow-up. She doesn’t have any significant health problems, and just wants to come early. 58
  • 59. GAME 2: When you are in a relationship with research Situation 2 Look at this CRF and find out errors in the CRF. 59
  • 60. GAME 2: When you are in a relationship with research Situation 3 The research nurse takes 10 mL of blood and separates into 2 tubes. He sends one tube to one research lab unit for the study lab tests, and the other tube to another lab unit for another study which investigates only on blood specimens. 60
  • 61. GAME 2: When you are in a relationship with research Situation 4 The pharmacy assistance reveals to the evaluation investigator that the current patient is in the placebo group. 61
  • 62. GAME 2: When you are in a relationship with research Situation 5 A new research nurse doesn’t remember the exact follow-up duration and makes an appointment with a new patient earlier than the follow-up days in the protocol. The patient comes back earlier and is examined. The follow-up CRF is filled in and a blood sample is taken. 62
  • 63. GAME 2: When you are in a relationship with research Situation 6 Look at this ICF and find out errors in the ICF. 63
  • 64. THE END Thank you for listening!