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GCP Workshop: Sponsor/CRO Responsibilities
Hanaa Abdel-Maguid
TCD MENA © 2017 1
TCD MENA © 2017 2
TCD MENA © 2017 2
 GCP Definition
 Sponsor/CRO Responsibilities
 Regulatory Affairs
 Project Management
 Clinical Operations
 Biometrics
 Medical Writing
 Pharmacovigilance
 Quality Assurance
Contents
TCD MENA © 2017 3
GCP
Definition
TCD MENA © 2017 4
TCD MENA © 2017 4
 Definition
A person or an organization (commercial, academic, or other)
contracted by the sponsor to perform one or more of a sponsor's trial-
related duties and functions. ICH-GCP E6 (R2) § 1.2
 CRO Responsibilities:
 Implement systems and procedures for conduct of and assessment
of safety in clinical trials
 Conduct CTs in accordance with the applicable regulations and
guidelines
 Abide by contract signed with the sponsor
 Communicate concerns to the sponsor in a timely manner
 Maintain accurate records
Contract Research Organization (CRO)
TCD MENA © 2017 5
5
Pharmacovigilance
& Safety Reporting
Medical & Biometrics
Services
Regulatory
Affairs
CRO Responsibilities
TCD MENA © 2017
Project Management
& ClinOps
TCD MENA © 2017 6
TCD MENA © 2017 6
Regulatory
Affairs
TCD MENA © 2017 7
TCD MENA © 2017 7
 Clinical trials should be conducted in accordance with the ethical
principles that have their origin in the Declaration of Helsinki, and that
are consistent with GCP and the applicable regulatory requirement(s).
(ICH GCP E6(R2) § 2.1
 The role of RA department is to ensure compliance (in relation to
trials) Adherence to all the trial-related requirements, Good Clinical
Practice requirements, and the applicable regulatory requirements.
(ICH GCP E6(R2) § 1.15
 This compliance is maintained by performing several activities in
Consequential manner.
Regulatory Authority
TCD MENA © 2017 8
TCD MENA © 2017 8
Regulatory Affairs Activities
1- Receipt of all Study Documents
2- Study Documents Country Adaptations
3- Translation & Verification (for any document handed to
patients)
4- EC Submission & EC approval.
5- RA Submission & RA approval.
6- Concerned authorities submission and approval (in case
of biological samples exportation).
7- Investigator Budget negotiation/ Contracts Execution
8- Import License submission & approval.
9- MOH Clearance Authorization submission & approval.
10-IMP delivery to sites & Site initiation.
TCD MENA © 2017 9
TCD MENA © 2017 9
Project
Management
TCD MENA © 2017 10
TCD MENA © 2017 10
 Vendor Management and Qualification
 Translation
 Laboratories
 Radiology
 Drug Depot
 Contracting (Sponsor, investigator, Vendor)
A written, dated, and signed agreement between two or more involved parties
that sets out any arrangements on delegation and distribution of tasks and
obligations and, if appropriate, on financial matters. The protocol may serve as
the basis of a contract. ICH-GCP E6 (R2) § 1.17
Clinical Project Management
TCD MENA © 2017 11
TCD MENA © 2017 11
 Project Oversight:
 Ensure the interim and final project deliverables meet the sponsor’s
time, quality, and cost expectations;
 Provide leadership, co-ordination and management of the project
team through start up, conduct, tracking, quality and regulatory
compliance and close-out activities;
 Complete and monitor actual hours and expenses versus budget
 Review and approve costs and ensure timely invoicing.
Clinical Project Management
TCD MENA © 2017 12
TCD MENA © 2017 12
Monitoring Plan
Communication Plan
Risk Management Plan
Safety Plan
CRF completion
guidelines
Data Management Plan
Clinical Project Plans
TCD MENA © 2017 13
TCD MENA © 2017 13
Clinical
Operations
Management
TCD MENA © 2017 14
TCD MENA © 2017 14
Clinical Ops. Activities
• Site Selection
(FQ)
• Pre-Study Visit
(PSVs)
Start Up
• Study Site
Initiation
• Clinical
Monitoring
• Monitoring
Report
Study
Conduct
• Close Out Visits
Study
Closure
TCD MENA © 2017 15
TCD MENA © 2017 15
Clinical Monitoring
 Monitor's Responsibilities
The monitor(s) in accordance with the sponsor’s requirements should
ensure that the trial is conducted and documented properly by carrying
out the necessary activities when relevant and necessary to the trial
and the trial site: ICH-GCP E6 (R2) § 5.18.4
TCD MENA © 2017 16
IRB/IEC
APPROVAL
OPINION
SUBJECT
ENROLLMENT
MONITORING VISITS
During the monitoring visits, the
Monitor will verify:
COMPLIANCE
with GCP and
PROTOCOL
IP DISPENSING
&
ACCOUNTABILITY
ADVERSE
EVENT
REPORTING
CRF
COMPLETION
vs SOURCE
DOCUMENTS
S F
T I
U L
D E
Y
STUDY
INITIATION
that the Investigator maintains the
essential documents (ICH/GCP § 5.18.4)
S F
T I
U L
D E
Y
Clinical Monitoring
TCD MENA © 2017 17
TCD MENA © 2017 17
CRF
CRF
CRF DRF
code breaking material
OTHER
MATERIALS INVESTIGATOR’s
FILE ARCHIVE
to ensure that :
all SAEs have been
reported to the
Sponsor
all CRFs have been
verified against
source documents
all queries have been
resolved by the
Investigator
all unused drugs
have been returned to
the Sopnsor for
destruction, and all
decoding envelopes
have been retrieved
all unused
materials
have been
retrieved
from the
study site
all essential documents
have been maintained by
the Investigator
all arrangements for
archiving have been made
by the Investigator
CLOSURE VISIT TASKS
18TCD MENA © 2017
TCD MENA © 2017 18
19
Biometrics &
Medical Writing
TCD MENA © 2017
TCD MENA © 2017 19
TCD MENA © 2017 19
Biometrics & Medical Writing Process
Protocol
writing
CRF Design
Informed
Consent
Development
Statistical
Analysis Plan
Edit Checks
Development
Database
Design
Data
Management
Plan
Data
Validation
Process
Query
Management
Data
Cleaning
Database
Lock
Medical
Coding
Statistical
Analysis
Report
Clinical
Study Report
Manuscript
TCD MENA © 2017 20
TCD MENA © 2017 20
Biometrics & Medical Writing
 Informed Consent
A Process by which a subject voluntarily confirms his or her willingness
to participate in a particular trial, after having been informed of all
aspects of the trial that are relevant to the subject’s decision to
participate. Informed consent is documented by means of a written,
signed and dated informed consent form. ICH GCP E6(R2) § 1.28
TCD MENA © 2017 21
TCD MENA © 2017 21
Medical Writing
 Protocol
A clinical trial protocol is a document that describes the objective(s),
design, methodology, statistical considerations, and organization of a
trial. Detail on the background of and rationale for the trial is usually
included in the protocol, although this information could be provided in
other protocol referenced documents., use the term protocol to refer to
the protocol and protocol amendment(s). ICH GCP E6 (R2) §1.44
TCD MENA © 2017 22
TCD MENA © 2017 22
Medical Writing
 Clinical Study Reports (CSR)
A written description of a trial/study of any therapeutic, prophylactic, or
diagnostic agent conducted in human subjects, in which the clinical and
statistical description, presentations, and analyses are fully integrated
into a single report. ICH GCP E6 (R2) § 1.13
 Manuscripts
A final document in the clinical trial that is written according to specific
guidelines for publication purpose.
TCD MENA © 2017 23
TCD MENA © 2017 23
Biostatistics
 Statistical Analysis Plan (SAP):
A document that contains a more technical and detailed elaboration of
the principal features of the analysis described in the protocol, and
includes detailed procedures for executing the statistical analysis of the
primary and secondary variables and other data.
 Statistical Analysis Report (SAR)
A report that contains the statistical analysis of the primary and
secondary variables and other data according to the study protocol.
TCD MENA © 2017 24
TCD MENA © 2017 24
Data Management
 Case Report Form Design (CRF)
A printed, optical, or electronic document designed to record all of the
protocol required information to be reported to the sponsor on each trial
subject. ICH GCP E6 (R2) §1.11
 Database Design
An electronic form designed according to the approved CRF for storing
data from a clinical trial in an organized format.
TCD MENA © 2017 25
TCD MENA © 2017 25
Data Management
 Data Management Plan Development
A document to facilitate forward planning of all data management activities,
provide technical information and act as a reference document for auditors
or retrospective retrieval of data.
 Data Validation Process
A process to ensures that the data are complete, valid and consistent.
 Query Management
A process of raising queries for incomplete, invalid of inconsistent data for
investigators resolutions and update the database accordingly.
TCD MENA © 2017 26
TCD MENA © 2017 26
Data Management
 Medical Coding
A process coding the Adverse events and concomitant medications
according to Medical dictionaries (MedDRA, WHO Drug)
 Data Cleaning
A process that grants that all the data have been entered, queries have
been raised by the Data management and resolved by the investigator in
order to proceed with database lock and start the Statistical Analysis
process.
TCD MENA © 2017 27
TCD MENA © 2017 27
PV/Safety Reporting
TCD MENA © 2017 28
TCD MENA © 2017 28
Pharmacovigilance &Safety Monitoring
 Safety Monitor is responsible for immediate and follow-up reporting of
any SAEs to sponsor/ RA according to the safety reporting timelines
 The immediate reports should be followed promptly by details, written
reports.
 The immediate and follow-up reports should identify subjects by unique
code numbers assigned to the trial subjects rather than by the subjects’
name, personal identification numbers, and/or addresses. ICH GCP E6
(R2) § 4.11
TCD MENA © 2017 29
TCD MENA © 2017 29
Pharmacovigilance &Safety Monitoring
 Adverse events and/or laboratory abnormalities identified in the protocol
as critical to safety evaluations should be reported to the sponsor
according to the reporting requirements and within the time periods
specified by the sponsor in the protocol.
 For reported deaths, the investigator should supply the sponsor and the
IRB/EC with any additional requested information.
 The investigator should also comply with the applicable regulatory
requirements related to the reporting of unexpected serious adverse
drug reactions to the regulatory authority(ies) and the IRB/EC
ICH GCP E6 (R2) § 4.11
TCD MENA © 2017 30
TCD MENA © 2017 31
Quality Assurance
• Staff Training
• Systems, procedures and working
practices
• Compliance ICH GCP, SA GCP, FDA
…etc.
• Internal project-specific and system
audits
Internal
Functions
• Contracted trial site, laboratory &
other vendors
• QA/training services (e.g. site
training, GCP training)
External
Functions
THANK YOU
WWW.TCD-GLOBAL.COM
TCD MENA © 2017 32

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Sponsor/CRO Responsibilities-GCP Workshop 27 FEB 2017

  • 1. GCP Workshop: Sponsor/CRO Responsibilities Hanaa Abdel-Maguid TCD MENA © 2017 1
  • 2. TCD MENA © 2017 2 TCD MENA © 2017 2  GCP Definition  Sponsor/CRO Responsibilities  Regulatory Affairs  Project Management  Clinical Operations  Biometrics  Medical Writing  Pharmacovigilance  Quality Assurance Contents
  • 3. TCD MENA © 2017 3 GCP Definition
  • 4. TCD MENA © 2017 4 TCD MENA © 2017 4  Definition A person or an organization (commercial, academic, or other) contracted by the sponsor to perform one or more of a sponsor's trial- related duties and functions. ICH-GCP E6 (R2) § 1.2  CRO Responsibilities:  Implement systems and procedures for conduct of and assessment of safety in clinical trials  Conduct CTs in accordance with the applicable regulations and guidelines  Abide by contract signed with the sponsor  Communicate concerns to the sponsor in a timely manner  Maintain accurate records Contract Research Organization (CRO)
  • 5. TCD MENA © 2017 5 5 Pharmacovigilance & Safety Reporting Medical & Biometrics Services Regulatory Affairs CRO Responsibilities TCD MENA © 2017 Project Management & ClinOps
  • 6. TCD MENA © 2017 6 TCD MENA © 2017 6 Regulatory Affairs
  • 7. TCD MENA © 2017 7 TCD MENA © 2017 7  Clinical trials should be conducted in accordance with the ethical principles that have their origin in the Declaration of Helsinki, and that are consistent with GCP and the applicable regulatory requirement(s). (ICH GCP E6(R2) § 2.1  The role of RA department is to ensure compliance (in relation to trials) Adherence to all the trial-related requirements, Good Clinical Practice requirements, and the applicable regulatory requirements. (ICH GCP E6(R2) § 1.15  This compliance is maintained by performing several activities in Consequential manner. Regulatory Authority
  • 8. TCD MENA © 2017 8 TCD MENA © 2017 8 Regulatory Affairs Activities 1- Receipt of all Study Documents 2- Study Documents Country Adaptations 3- Translation & Verification (for any document handed to patients) 4- EC Submission & EC approval. 5- RA Submission & RA approval. 6- Concerned authorities submission and approval (in case of biological samples exportation). 7- Investigator Budget negotiation/ Contracts Execution 8- Import License submission & approval. 9- MOH Clearance Authorization submission & approval. 10-IMP delivery to sites & Site initiation.
  • 9. TCD MENA © 2017 9 TCD MENA © 2017 9 Project Management
  • 10. TCD MENA © 2017 10 TCD MENA © 2017 10  Vendor Management and Qualification  Translation  Laboratories  Radiology  Drug Depot  Contracting (Sponsor, investigator, Vendor) A written, dated, and signed agreement between two or more involved parties that sets out any arrangements on delegation and distribution of tasks and obligations and, if appropriate, on financial matters. The protocol may serve as the basis of a contract. ICH-GCP E6 (R2) § 1.17 Clinical Project Management
  • 11. TCD MENA © 2017 11 TCD MENA © 2017 11  Project Oversight:  Ensure the interim and final project deliverables meet the sponsor’s time, quality, and cost expectations;  Provide leadership, co-ordination and management of the project team through start up, conduct, tracking, quality and regulatory compliance and close-out activities;  Complete and monitor actual hours and expenses versus budget  Review and approve costs and ensure timely invoicing. Clinical Project Management
  • 12. TCD MENA © 2017 12 TCD MENA © 2017 12 Monitoring Plan Communication Plan Risk Management Plan Safety Plan CRF completion guidelines Data Management Plan Clinical Project Plans
  • 13. TCD MENA © 2017 13 TCD MENA © 2017 13 Clinical Operations Management
  • 14. TCD MENA © 2017 14 TCD MENA © 2017 14 Clinical Ops. Activities • Site Selection (FQ) • Pre-Study Visit (PSVs) Start Up • Study Site Initiation • Clinical Monitoring • Monitoring Report Study Conduct • Close Out Visits Study Closure
  • 15. TCD MENA © 2017 15 TCD MENA © 2017 15 Clinical Monitoring  Monitor's Responsibilities The monitor(s) in accordance with the sponsor’s requirements should ensure that the trial is conducted and documented properly by carrying out the necessary activities when relevant and necessary to the trial and the trial site: ICH-GCP E6 (R2) § 5.18.4
  • 16. TCD MENA © 2017 16 IRB/IEC APPROVAL OPINION SUBJECT ENROLLMENT MONITORING VISITS During the monitoring visits, the Monitor will verify: COMPLIANCE with GCP and PROTOCOL IP DISPENSING & ACCOUNTABILITY ADVERSE EVENT REPORTING CRF COMPLETION vs SOURCE DOCUMENTS S F T I U L D E Y STUDY INITIATION that the Investigator maintains the essential documents (ICH/GCP § 5.18.4) S F T I U L D E Y Clinical Monitoring TCD MENA © 2017 17
  • 17. TCD MENA © 2017 17 CRF CRF CRF DRF code breaking material OTHER MATERIALS INVESTIGATOR’s FILE ARCHIVE to ensure that : all SAEs have been reported to the Sponsor all CRFs have been verified against source documents all queries have been resolved by the Investigator all unused drugs have been returned to the Sopnsor for destruction, and all decoding envelopes have been retrieved all unused materials have been retrieved from the study site all essential documents have been maintained by the Investigator all arrangements for archiving have been made by the Investigator CLOSURE VISIT TASKS 18TCD MENA © 2017
  • 18. TCD MENA © 2017 18 19 Biometrics & Medical Writing TCD MENA © 2017
  • 19. TCD MENA © 2017 19 TCD MENA © 2017 19 Biometrics & Medical Writing Process Protocol writing CRF Design Informed Consent Development Statistical Analysis Plan Edit Checks Development Database Design Data Management Plan Data Validation Process Query Management Data Cleaning Database Lock Medical Coding Statistical Analysis Report Clinical Study Report Manuscript
  • 20. TCD MENA © 2017 20 TCD MENA © 2017 20 Biometrics & Medical Writing  Informed Consent A Process by which a subject voluntarily confirms his or her willingness to participate in a particular trial, after having been informed of all aspects of the trial that are relevant to the subject’s decision to participate. Informed consent is documented by means of a written, signed and dated informed consent form. ICH GCP E6(R2) § 1.28
  • 21. TCD MENA © 2017 21 TCD MENA © 2017 21 Medical Writing  Protocol A clinical trial protocol is a document that describes the objective(s), design, methodology, statistical considerations, and organization of a trial. Detail on the background of and rationale for the trial is usually included in the protocol, although this information could be provided in other protocol referenced documents., use the term protocol to refer to the protocol and protocol amendment(s). ICH GCP E6 (R2) §1.44
  • 22. TCD MENA © 2017 22 TCD MENA © 2017 22 Medical Writing  Clinical Study Reports (CSR) A written description of a trial/study of any therapeutic, prophylactic, or diagnostic agent conducted in human subjects, in which the clinical and statistical description, presentations, and analyses are fully integrated into a single report. ICH GCP E6 (R2) § 1.13  Manuscripts A final document in the clinical trial that is written according to specific guidelines for publication purpose.
  • 23. TCD MENA © 2017 23 TCD MENA © 2017 23 Biostatistics  Statistical Analysis Plan (SAP): A document that contains a more technical and detailed elaboration of the principal features of the analysis described in the protocol, and includes detailed procedures for executing the statistical analysis of the primary and secondary variables and other data.  Statistical Analysis Report (SAR) A report that contains the statistical analysis of the primary and secondary variables and other data according to the study protocol.
  • 24. TCD MENA © 2017 24 TCD MENA © 2017 24 Data Management  Case Report Form Design (CRF) A printed, optical, or electronic document designed to record all of the protocol required information to be reported to the sponsor on each trial subject. ICH GCP E6 (R2) §1.11  Database Design An electronic form designed according to the approved CRF for storing data from a clinical trial in an organized format.
  • 25. TCD MENA © 2017 25 TCD MENA © 2017 25 Data Management  Data Management Plan Development A document to facilitate forward planning of all data management activities, provide technical information and act as a reference document for auditors or retrospective retrieval of data.  Data Validation Process A process to ensures that the data are complete, valid and consistent.  Query Management A process of raising queries for incomplete, invalid of inconsistent data for investigators resolutions and update the database accordingly.
  • 26. TCD MENA © 2017 26 TCD MENA © 2017 26 Data Management  Medical Coding A process coding the Adverse events and concomitant medications according to Medical dictionaries (MedDRA, WHO Drug)  Data Cleaning A process that grants that all the data have been entered, queries have been raised by the Data management and resolved by the investigator in order to proceed with database lock and start the Statistical Analysis process.
  • 27. TCD MENA © 2017 27 TCD MENA © 2017 27 PV/Safety Reporting
  • 28. TCD MENA © 2017 28 TCD MENA © 2017 28 Pharmacovigilance &Safety Monitoring  Safety Monitor is responsible for immediate and follow-up reporting of any SAEs to sponsor/ RA according to the safety reporting timelines  The immediate reports should be followed promptly by details, written reports.  The immediate and follow-up reports should identify subjects by unique code numbers assigned to the trial subjects rather than by the subjects’ name, personal identification numbers, and/or addresses. ICH GCP E6 (R2) § 4.11
  • 29. TCD MENA © 2017 29 TCD MENA © 2017 29 Pharmacovigilance &Safety Monitoring  Adverse events and/or laboratory abnormalities identified in the protocol as critical to safety evaluations should be reported to the sponsor according to the reporting requirements and within the time periods specified by the sponsor in the protocol.  For reported deaths, the investigator should supply the sponsor and the IRB/EC with any additional requested information.  The investigator should also comply with the applicable regulatory requirements related to the reporting of unexpected serious adverse drug reactions to the regulatory authority(ies) and the IRB/EC ICH GCP E6 (R2) § 4.11
  • 30. TCD MENA © 2017 30
  • 31. TCD MENA © 2017 31 Quality Assurance • Staff Training • Systems, procedures and working practices • Compliance ICH GCP, SA GCP, FDA …etc. • Internal project-specific and system audits Internal Functions • Contracted trial site, laboratory & other vendors • QA/training services (e.g. site training, GCP training) External Functions