Quality Assurance :  Audit & Inspection Prashanth Babu. M Principal Consultant
Topics to be discussed Why do we need quality assurance ? Who should be involved in the QA process ? Audit & Inspection How to prepare for an audit ?
Quality Assurance is mentioned  in ICH-GCP   Chapter 5 : Sponsor  Section 5.1 Quality assurance & quality control ‘ The sponsor is  responsible  for implementing & maintaining quality assurance & quality control systems with  written SOPs  to ensure that trials are  conducted  &  data are generated , documented (recorded)  in compliance with  protocol ,  GCP  &  applicable regulatory requirement(s) ICH GCP 1997
Quality Assurance is responsibility  of sponsor   ‘ The sponsor is responsible for  securing agreement  from  all involved parties  to ensure  direct access  to all  trial related sites ,  source data/ documents  &  reports  for the purpose of  monitoring  &  auditing  by the sponsor &  inspection  by domestic & foreign regulatory authorities’ ICH GCP 1997
Who should be involved in QA process Quality of the study Investigators/ team  Sponsor Ethics Committee Institution Health Authority Monitor/ study operation team Biometrics team Patients  QA team
The Quality Assurance Procedure ?   Audit  The i ndependent,   systematic  action to ensure the quality of study, data generated, is accurate, reliable, patient’s safety and right is protected and followed  GCP,  SOPs   &  applicable regulations  in the country  ICH-GCP 1997
Inspection   The act by a  regulatory authority(ies)  of conducting an official review of  documents ,  facilities ,  records  and  any other resources  that are deemed by the authority(ies) to be related to the clinical trial and that may be located  at the site of the   trial ,   at the sponsor’s   and/ or CRO’s facilities  or at other establishments deemed appropriate by the regulatory authority(ies) ICH-GCP 1997
Why do the authority inspect ? Support regulatory authority decision Base upon   Safety Validity of data Regulatory compliance Subject’s right protection Law enforcement When the data from the trial will be used for authority approval
How to Prepare for Audit
What are the areas concerned by auditor Patient’s safety  Has the study approved  Did patient agree to join the study Does the investigator follow protocol Does the investigator report the adverse event (on time)  Does Ethics Committee be informed on safety Does the patient be informed on new information Study credibility  Does the patient exist  How can we ensure that the procedure is followed Human, machine variation   We have to document all the activity  Does the facilities meet the standard How can we ensure the equipment work properly
Preparation for Audit Should start from the beginning of the study Ensure that we have the documents to prove that study has been conducted properly According to ICH-GCP, Local regulation, Institution SOP All party understand the protocol, procedure Any concern raised by any party should be documented Aware of the chronology of the event, version of documents
Essential Documents (1) Study protocol,  patient information sheet,   informed consent,   questionnaire,   investigator brochure  etc. Version, date submitted, approved, implemented Safety report : AE, SAE, SUSAR Submitted to EC, FDA Agreements : clinical, financial Study personnel : CV, authorised letter, sample of signature Enrollment log Correspondence
Essential Documents (II) Case record form : CRF Signed & dated informed consent  Completeness of CRF Investigator signed & dated in the assigned pages Accuracy of data compared with source data Black ball point pen  Logical date according to protocol ! Source data has to be available
Essential Documents (III) Source data Patient note (OPD card) : should document the information required by the protocol (monitor can prepare the check list page & attach to the OPD card) Other documents : lab test, ECG, X-rays, CT scan,  Translator is required in case local language is not English (FDA inspection might ask for an  independent translator)
Essential Documents (IV) Standardisation, maintenance of equipment Document to prove that all procedure is followed Logistics, accountability of the test kits, study medication Temperature controlled required Study personnel who operate the machine Well trained; training record, CV Sample handling procedure  Tissue block, blood, serum, etc
Major Mistakes Misconduct of the study   Study not being approved Major protocol violation Patient safety : SAE Fraud data Cause loss of reputation of investigator/ institute Loss of reputation of sponsor Withdrawal, termination of product license
Problems/ Mistakes Things to be remembered Problems/ mistakes are common things Auditor’s job is to find mistake ! Don’t arrange or make up, he/she will find anyway Too good to be true when everything is perfect   As long as the mistake is minor & acceptable
What needs to be done to prevent mistake Understands the principle of GCP Patient safety Data validity Proactive approach Foresee the problems might happen Good communication with monitor Inform monitor if there is anything unclear Positive attitude Mistake does happen, nothing to hide
Summary   QA is the key responsibility of sponsor QA involved all parties in the clinical study QA should be started from the beginning of the study (planning process) QA should be placed in every step of the study Standard should be defined & comply to GCP/ regulation QA can not be achieved without the cooperation of all parties
  Thank you for your attention Any questions ????????????

Quality Assurance : Audit And Inspection

  • 1.
    Quality Assurance : Audit & Inspection Prashanth Babu. M Principal Consultant
  • 2.
    Topics to bediscussed Why do we need quality assurance ? Who should be involved in the QA process ? Audit & Inspection How to prepare for an audit ?
  • 3.
    Quality Assurance ismentioned in ICH-GCP Chapter 5 : Sponsor Section 5.1 Quality assurance & quality control ‘ The sponsor is responsible for implementing & maintaining quality assurance & quality control systems with written SOPs to ensure that trials are conducted & data are generated , documented (recorded) in compliance with protocol , GCP & applicable regulatory requirement(s) ICH GCP 1997
  • 4.
    Quality Assurance isresponsibility of sponsor ‘ The sponsor is responsible for securing agreement from all involved parties to ensure direct access to all trial related sites , source data/ documents & reports for the purpose of monitoring & auditing by the sponsor & inspection by domestic & foreign regulatory authorities’ ICH GCP 1997
  • 5.
    Who should beinvolved in QA process Quality of the study Investigators/ team Sponsor Ethics Committee Institution Health Authority Monitor/ study operation team Biometrics team Patients QA team
  • 6.
    The Quality AssuranceProcedure ? Audit The i ndependent, systematic action to ensure the quality of study, data generated, is accurate, reliable, patient’s safety and right is protected and followed GCP, SOPs & applicable regulations in the country ICH-GCP 1997
  • 7.
    Inspection The act by a regulatory authority(ies) of conducting an official review of documents , facilities , records and any other resources that are deemed by the authority(ies) to be related to the clinical trial and that may be located at the site of the trial , at the sponsor’s and/ or CRO’s facilities or at other establishments deemed appropriate by the regulatory authority(ies) ICH-GCP 1997
  • 8.
    Why do theauthority inspect ? Support regulatory authority decision Base upon Safety Validity of data Regulatory compliance Subject’s right protection Law enforcement When the data from the trial will be used for authority approval
  • 9.
    How to Preparefor Audit
  • 10.
    What are theareas concerned by auditor Patient’s safety Has the study approved Did patient agree to join the study Does the investigator follow protocol Does the investigator report the adverse event (on time) Does Ethics Committee be informed on safety Does the patient be informed on new information Study credibility Does the patient exist How can we ensure that the procedure is followed Human, machine variation We have to document all the activity Does the facilities meet the standard How can we ensure the equipment work properly
  • 11.
    Preparation for AuditShould start from the beginning of the study Ensure that we have the documents to prove that study has been conducted properly According to ICH-GCP, Local regulation, Institution SOP All party understand the protocol, procedure Any concern raised by any party should be documented Aware of the chronology of the event, version of documents
  • 12.
    Essential Documents (1)Study protocol, patient information sheet, informed consent, questionnaire, investigator brochure etc. Version, date submitted, approved, implemented Safety report : AE, SAE, SUSAR Submitted to EC, FDA Agreements : clinical, financial Study personnel : CV, authorised letter, sample of signature Enrollment log Correspondence
  • 13.
    Essential Documents (II)Case record form : CRF Signed & dated informed consent Completeness of CRF Investigator signed & dated in the assigned pages Accuracy of data compared with source data Black ball point pen Logical date according to protocol ! Source data has to be available
  • 14.
    Essential Documents (III)Source data Patient note (OPD card) : should document the information required by the protocol (monitor can prepare the check list page & attach to the OPD card) Other documents : lab test, ECG, X-rays, CT scan, Translator is required in case local language is not English (FDA inspection might ask for an independent translator)
  • 15.
    Essential Documents (IV)Standardisation, maintenance of equipment Document to prove that all procedure is followed Logistics, accountability of the test kits, study medication Temperature controlled required Study personnel who operate the machine Well trained; training record, CV Sample handling procedure Tissue block, blood, serum, etc
  • 16.
    Major Mistakes Misconductof the study Study not being approved Major protocol violation Patient safety : SAE Fraud data Cause loss of reputation of investigator/ institute Loss of reputation of sponsor Withdrawal, termination of product license
  • 17.
    Problems/ Mistakes Thingsto be remembered Problems/ mistakes are common things Auditor’s job is to find mistake ! Don’t arrange or make up, he/she will find anyway Too good to be true when everything is perfect As long as the mistake is minor & acceptable
  • 18.
    What needs tobe done to prevent mistake Understands the principle of GCP Patient safety Data validity Proactive approach Foresee the problems might happen Good communication with monitor Inform monitor if there is anything unclear Positive attitude Mistake does happen, nothing to hide
  • 19.
    Summary QA is the key responsibility of sponsor QA involved all parties in the clinical study QA should be started from the beginning of the study (planning process) QA should be placed in every step of the study Standard should be defined & comply to GCP/ regulation QA can not be achieved without the cooperation of all parties
  • 20.
    Thankyou for your attention Any questions ????????????