Investigational products are pharmaceutical forms being tested in clinical trials. They must be manufactured and handled according to good manufacturing practices and used according to the trial protocol. The sponsor is responsible for supplying the investigational product and ensuring proper manufacturing, packaging, labeling, coding, and storage conditions. The investigator is responsible for proper receipt, inventory, storage, dispensing, return of unused product, and final accountability of the investigational product at the trial site. Monitors verify that investigational products are properly supplied, stored, dispensed, and returned. Pharmacies play an important role in ensuring investigational products are appropriately managed throughout the clinical trial.

1. Investigational Product
Management
by Clinical Trial Players
Prepared by
Dipesh Kashinath Pabrekar

2. Investigational Product
 A pharmaceutical form of an active ingredient or placebo
being tested or used as a reference in a clinical trial,
including a product with a marketing authorization
when:
• Used or assembled in a way different
from the approved form,
• Used for an unapproved indication, or
• Used to gain further information about an
approved use. ICH E6 1.33

3. Investigational Product Continue
Investigational products should be manufactured,
handled, and stored in accordance with applicable good
manufacturing practice (GMP). They should be used in
accordance with the approved protocol.

4. Management of IP During Trial
 There must be written
documentation every
time investigational
product changes its
transition.
 Investigator may
delegate some or all
duties to a pharmacist.
 100 % compliance must
be maintain during each
and every activity
related to
investigational product
Sponsor/CRO
Investigator
Subject
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5. Sponsor’s Responsibility
ICH E6 5.13 - Manufacturing, Packaging, Labeling, and
Coding Investigational Product(s):
5.13.1 - The sponsor should ensure that IP is
characterized as appropriate to the stage of development
of the product(s), is manufactured in accordance with any
applicable GMP, and is coded and labeled in a manner
that protects the blinding, if applicable.
In addition, the labeling should comply with applicable
regulatory requirement(s).

6. Sponsor’s Responsibility Continue
5.13.2 - The sponsor should determine, for the IP,
acceptable storage temperatures, storage conditions (e.g.,
protection from light), storage times, reconstitution fluids
and procedures, and devices for product infusion, if any.
The sponsor should inform all involved parties (e.g.,
monitors, investigators, pharmacists, storage managers) of
these determinations.
5.13.3 - The IP should be packaged to prevent
contamination and unacceptable deterioration during
transport and storage.
5.13.4 - In blinded trials, the coding system for the IP
should include a mechanism that permits rapid
identification of the product(s) in case of a medical
emergency, but does not permit undetectable breaks of

7. Sponsor’s Responsibility Continue…
 5.13.5 - If significant formulation changes are made in
the IP during the course of clinical development, the
results of any additional studies of the formulated
product(s) (e.g., stability, dissolution rate, bioavailability)
needed to assess whether these changes would
significantly alter the pharmacokinetic profile of the
product should be available prior to the use of the new
formulation in clinical trials.

8. Sponsor’s Responsibility Continue
ICH E6 5.14 Supplying and Handling Investigational
Product(s):
5.14.1 - The sponsor is responsible for supplying the
investigator(s)/institution(s) with the investigational
product(s).
5.14.2 - The sponsor should not supply an
investigator/institution with the investigational product(s)
until the sponsor obtains all required documentation (e.g.,
approval/favorable opinion from IRB/IEC and regulatory
authority(ies).

9. Sponsor’s Responsibility Continue
5.14.3 The sponsor should ensure that written
procedures include instructions that the
investigator/institution should follow for the handling
and storage of investigational product(s) for the trial
and documentation thereof.
The procedures should address adequate and safe
receipt, handling, storage, dispensing, retrieval of
unused product from subjects, and return of unused
investigational product(s) to the sponsor (or
alternative disposition if authorized by the sponsor
and in compliance with the applicable regulatory
requirement(s)).

10. Sponsor’s Responsibility Continue
5.14.4 The sponsor should:
(a) Ensure timely delivery of IP to the investigator(s).
(b) Maintain records that document shipment, receipt,
disposition, return, and destruction of the
investigational product(s).
(c) Maintain a system for retrieving IP and
documenting this retrieval (e.g., for deficient product
recall, reclaim after trial completion, expired product
reclaim).

11. IP Lifecycle at Sponsor’s Site
Manufacturing
Of IP
• IP batch/Lot
• Amt of IP
Manufactured
• IP samples for
QA,QC, stability
analysis
• IP
rejected/destroyed
Packaging of
IP
• IP batch/Lot
• Amt of bulk IP
received
• Amt of IP packaged
samples
• IP
rejected/destroyed
• Amit of IP released
to warehouse
Warehousing
• IP batch/Lot
• Qty of kits received
• Qty of kits released
• Kits tracking by Kit
# and site #
Waste
Management
• IP return including
site # and kit #
• Qty of kits received
• Qty within kits
• Pounds of waist
destroyed
• Destruction
document

12. Investigator’s Responsibility
 CH E6 4.6.1- Responsibility for IP accountability at the
trial site(s) rests with the investigator/institution.
 ICH E6 4.6.2- Where allowed/required, the
investigator/institution may/should assign some or all of
the investigator's/institution’s duties for IP accountability
at the trial site(s) to
◦ an appropriate pharmacist
◦ or another appropriate individual
who is under the supervision of the
investigator/institution.

13. Investigator’s Responsibility Continue…
ICH E6 4.6.3 - ….should maintain records of the product's
delivery to the trial site, the inventory at the site, the use by
each subject, and the return to the sponsor or alternative
disposition of unused product(s).
These records should include dates, quantities,
batch/serial numbers, expiration dates (if applicable), and
the unique code numbers assigned to the investigational
product(s) and trial subjects.
Investigators should maintain records that document
adequately that the subjects were provided the doses
specified by the protocol and reconcile all investigational
product(s) received from the sponsor.

14. Investigator’s Responsibility Continue…
ICH E6 4.6.4 - IP should be stored as specified by the
sponsor and in accordance with applicable regulatory
requirement(s).
ICH E6 4.6.5 - ..should ensure that the IP are used only in
accordance with the approved protocol.
ICH E6 4.6.6 - …should explain the correct use of the IP to
each subject and should check, at intervals appropriate for
the trial, that each subject is following the instructions
properly.

15. IP lifecycle at Investigator’s Site
IP receipt and
Inventory
IP Storage
Dispensing and
Administration
Return of
unused IP
Alternative
disposition
Final
accountability

16. Monitor’s Responsibility
ICH E6 5.8.14 (c) - Verifying, for the investigational
product(s):
(I) That storage times and conditions are acceptable, and that
supplies are sufficient throughout the trial.
(ii) That the IP are supplied only to subjects who are eligible to
receive it and at the protocol specified dose(s).
(iii) That subjects are provided with necessary instruction on
properly using, handling, storing, and returning the IP.
(iv) That the receipt, use, and return of the IP at the trial sites
are controlled and documented adequately.
(v) That the disposition of unused IP at the trial sites complies
with applicable regulatory requirement(s) and is in accordance
with the sponsor’s authorized procedures.

17. Role of Pharmacy in Clinical Trial
To safeguard subjects, healthcare professionals and the
sponsor by ensuring IMP are appropriate for use and are
procured, handled, stored and used safely and correctly.
To ensure that IMP are managed and dispensed to
subjects in accordance with the protocol.
To ensure that all pharmacy related clinical trial
procedures comply with relevant guidelines and
regulations

18. IP/IMP Receipt
Check temperature on any monitoring devices with
delivery.
Reconcile items delivered with delivery note
Notify supplier/ sponsor of any discrepancies
Receive of appropriate IP with necessary documents i.e.
Gate Pass/ Shipment record,
• COA,
• IP Detail form,
• IP handling procedure if any
• PE Report (ANVISA), Dissolution profile (ANVISA,
DCGI), CDL testing report (Injectable)

19. Physical Verification & IP Storage
Verification of physical status of IP with its supportive
documents & protocol.
IMP should be stored as per label claim in drug store.
Temperature monitoring as per in-house SOP.
Identification of Dispensing procedure for study if any
special precautions need to be taken.

20. IP Dispensing, Accountability, Retention &
Destruction
Designated person should be trained in GCP & in-house
SOPs for IP management.
Trial specific dispensing procedures should be followed by
all staff dispensing and checking IP.
Detailed documentation of procedures of IP accountability
& IP dispensing in respective forms.
All unused IP should be returned to pharmacy and
documented on accountability log.
Retention of unused IPs after completion of study.
Destruction of IP as per in-house SOP & instructions by
sponsor.

21. THANK YOU