Académique Documents
Professionnel Documents
Culture Documents
GCP Informed Consents Case Report Forms and Source Documents Safety Reporting Study Close-out Close2
Clinical Trials
Biological Tests
Pharmacy/Chemical Development
Early Development
Pre- Clinical Trials clinical Phase 1 Phase
Full Development
Phase IIa Phase IIb
CSP
Candidate Selection Point
sPoC
Selected for Proof of Concept
DDP
Development Decision Point
FDP
Full Development Point
3CP
SDP
Submission Decision Point
IND
NDA
No standard route through which drugs are developed Some major sources of new drugs:
Synthetic compounds Discovery of a new use for an old-drug oldNatural chemical
Process:
PrePre-Clinical Research
Animal pharmacology/toxicology testing safe to proceed to human trials? (The Nuremberg Code) Approximately 2-3 yrs development 220-30 substances 20-
Is it
21 CFR 312.23 8
Clinical Trials
IND filed first 3-5 years Process:
Clinical Trials - Phase I Phase III On-going Biological tests (safety) OnOn-going formulation work On-
Subjects
Healthy volunteers or subj. w/ indications Subjects with indications Subjects with indications Subjects with indications
Scope
Length
(per phase)
2020-80
6-12 mos
II III
1-2 yrs
2-3 yrs
IV
1-5 yrs
10
Phase I
First time in human subjects Small number of healthy volunteers or severely ill patients Safety profile and dosage range Single and multi-dose studies multiPharmacokinetics / pharmacodynamics Open label, often single center Not always performed in the U.S.
11
Phase II
Safety, side effects Efficacy dose response DoubleDouble-blind, positive control or placebo, multi-center multiutilizing a limited number of subjects (100-300); often (100the first time drug is used in population for which it is intended Phase IIa proof of concept, pilot, feasibility, usually healthy volunteers Phase IIb well-controlled in target population wellFollowing completion of Phase II, meet with the FDA to pave the way for pivotal trials
21 CFR 312.47
12
Phase III
2 or 3 studies are pivotal (critical) studies To prove safety and efficacy of primary endpoints Double-blind, positive or placebo control, multiDoublemulticenter Study population resembles the intended population Support package labeling New Drug Application (NDA) Special population, concomitant medications, multiple illnesses, etc. IIIb studies post NDA-submission trial looking at NDAadditional indications PrePre-NDA meeting with the FDA near conclusion of Phase III 21 CFR 312.47
13
Can now be filed electronically 21 CFR 314.50 (a CTD = Commercial Technical Document) Review process: Target 10 months (but often longer)
14
16
Phase IV
PostPost-licensure studies to confirm the safety in large population (after NDA is filed) Phase IV commitments Possible types of studies Compared versus competition Post-marketing surveillance PostSpecial population Rare event incidences Additional long-term usage safety data longPharmacoecomonic and Quality of Life (QoL)
21 CFR 312.85
17
18
Factoid .
Over 700,000 physicians in the US, only 4% of them have participated in clinical trials since 1988.1
20
Medical Director
Project Manager
Regulatory Personnel
IRB / IEC
22
Investigative Sites
Clinical research occurs in a variety of settings Private practice Private practice with a separate research facility Clinical research facility Academic or hospital research facility Government (e.g., NIH)
ICH GCP 1.59
24
Investigator
Person responsible for the conduct of the clinical trial at a trial site If conducted by a team, the investigator is the responsible leader of the team and may be called the principal investigator (PI) (ICH GCP 1.34)
Sub -investigator
Any individual member of the clinical trial team designated and supervised by the investigator at a trial site to perform critical trial related procedures and/or to make important trialtrial-related decisions (ICH GCP 1.56)
25
26
IRB
The investigator must furnish the IRB with the following documents for review and approval: Trial Protocol Written Informed Consent Forms Written Information for Subjects (Advertisements) Information about compensation to patients Investigator Brochure Available (or additional) Safety Information Investigator s CV All amendments to study protocol
28
IRB
The IRB s possible responses: approval or favorable opinion modifications required for approval disapproval or negative opinion withdrawal or suspension of an earlier approval No subjects should be enrolled until the IRB has issued an approval (21 CFR 56.109)
29
30
Investigator Selection
FDA mandates that a sponsor shall select only investigators (21 CFR 312.53, ICH GCP 4) that:
Are qualified by training and experience as appropriate experts to investigate the drug Provide evidence of such qualifications
31
Investigator Selection
Investigator Characteristics Personnel
CRC : trained, certified, full-time? fullWork schedules
Facility
Space Equipment
IRB Patients
32
Investigator Selection
Investigator s Characteristics (general) Prior clinical research experience Experience conducting similar research trials Research interests Experience with new and marketed drugs Publications from previous research Current competing trials
33
Investigator Selection
Investigator s Characteristics (protocol(protocol-specific) Is investigator interested in the study? Does the site have the necessary patient population? (e.g. minority %, drug-nave, etc) drugIf special procedures are necessary, does this site have the capability to do this? Central vs. local IRB. What is the timetable for this study?
34
Investigator Selection
Sponsor s Tour of Facility / Site visit
Drug Storage OnOn-site Laboratory Exam Rooms and Storage area CRFs, lab kits, and other study supplies Special Equipment ECG, Freezer, lab equipment, defibrillator and rescue meds Place for CRA to monitor Desk, phone, access to copier, CRFs, source docs, etc. Sample of source documents
35
36
Study Documents
Protocol and Signed Protocol Signature Page Approved Informed Consent Signed Form FDA 1572 Investigator Brochure Case Report Form (CRF) Clinical Trial Agreements and Budget IRB Approvals and membership roster Curriculum Vitae of Investigator(s) and Copy of Medical License Lab Normal Ranges and Certifications Financial Disclosure Forms
37
Study Documents
Informed Consent Form Informed consent is a process A joint effort by the sponsor and the investigator Must be approved by the IRB and the sponsor, and accepted by the investigator
38
Study Documents
Form FDA 1572 The regulatory document which, when signed by the investigator, commits him/her to follow the regulatory requirements under penalty of law.
39
Study Documents
Investigator Brochure (IB) Provides Information on the drug s
Pharmacology, Toxicology Adverse experience profile
Study Documents
Source Documents First place where information is recorded, either on paper or computer All entries must be signed and dated Include any deviations from the study protocol or procedures Record of explanations for unexpected occurrences
41
Study Documents
Case Report Forms (CRFs) Used to record data on all subjects Monitored to verify that trial records and data are valid, accurate, complete, and up to date Provide data for analysis and reporting after the trial is completed Often electronic (eCRF s)
42
Study Documents
Clinic charts, doctors notes, nursing notes, pharmacy notes, original laboratory results, and patient diaries for each study subject must be available for review by the sponsor and the FDA Records of all study events and patient visits need to be maintained All source documents must be available during routine monitoring visits
43
Investigator s Meeting
Review protocol and procedures Get better acquainted with the sponsor and other investigators Answer outstanding questions Generate enthusiasm for the trial and for recruitment Identify potential problems May serve as the initiation visit
44
Investigator s Meeting
Study Coordinators and sub-investigators should subalso attend the meeting or hold a separate discussion of their own Sponsor participants include the medical expert, biostatistician, CRAs, and CRO personnel
45
46
Drug Accountability
Study Medication
Cannot be shipped until the sponsor obtains all required documentation (e.g. IRB approval, CV s, etc). Must be verified upon receipt Must be stored ICH 5.14, 21 CFR 312.61, 21 CFR 312.57 in a secured cabinet preferably in a secured room/area per investigator s brochure, protocol, or package insert A current log must be maintained. Verified by CRA during visits. ICH 5.18.14
48
Subject Recruitment
Investigator s patient population Referrals from other physicians and clinics Direct advertisement, which must be approved by the IRB
49
Informed Consent
Must be obtained before subjects participate in any clinical trial procedure (21 CFR 50), and must be dated. Should be written at the 7th grade reading level Must explain medical terms Should be provided in patient s native language Should not make it appear that rights have been waived by the participant or liability released by the investigator, sponsor or institution Consent is a process
50
Informed Consent
Eight basic elements of informed consent 50.25) (21 CFR
Trial involves research, purpose of the research A description of any reasonably foreseeable risks or discomforts A description of any benefits to the subject which may reasonable be expected from the research A disclosure of appropriate alternative procedures or treatment that may be available to the subject A statement describing the extent to which confidentiality of records identifying the subject will be maintained An explanation as to whether any compensation and whether any medical treatments are available if injury occurs An explanation of whom to contact for answers to questions about the research and research subjects rights A statement that participation is voluntary
51
Protocol Adherence
Research studies must be conducted as detailed in the study protocol Amendments to the protocol are conveyed to the PI in writing; the PI must sign and return signature page to sponsor Amendment or any change requires IRB approval
52
53
54
Sponsor Monitoring
Types of Monitoring visits PrePre-study or evaluation ( screening visit ) Initiation InterimInterim-monitoring Audit CloseClose-out
55
Sponsor Monitoring
Purpose To verify
protection of rights and well-being of subjects wellreported trial data is accurate, complete, and verifiable trial is in compliance with:
Protocol and amendments Regulatory requirements Enrollment Drug supply
ICH GCP 5.18.1
56
Safety Reporting
A Federal regulation: an investigator shall promptly report to the sponsor any adverse effect that may reasonably be regarded as caused by, or probably caused by, the drug. If the adverse effect is alarming, the investigator shall report the adverse effect immediately. (21 CFR 312.64)
57
Safety Reporting
Investigator should report SAEs to sponsor and to IRB within 24 hours
Serious does not mean severe, which describes intensity Follow up required with subject, sponsor and IRB
ICH GCP 4.11.1 58
59
CloseClose-Out Visit
A study close-out visit closeis required
at study completion decision to terminate the study short of completion Drop-out of a site Drop-
60
Objectives of the Close-Out Visit CloseVerify that the investigator s study files are complete Ensure that regulatory requirements for retention of records are understood Review final reporting requirements with the investigator Ensure all data is complete Ensure that all supplies are returned, destroyed or placed in compassionate use
61
Drug Accountability
A final reconciliation of all study drug Drug dispensing logs will be verified against a physical inventory All drug on-site at the close-out onclosevisit will either be disposed of at the visit or shipped back to the sponsor
62
Record Retention
Essential documents should be retained until at least 2 years. CFR 312.62
(Novartis requires 15 years)
It is the responsibility of the sponsor to inform the investigator/institution as to when these documents no longer need to be retained.
ICH GCP 4.9.5
If an investigator leaves an institution, he/she must transfer responsibilities for record retention to another physician and notify the sponsor in writing.
63
64
Questions?
Contact Info: Catherine D. Freiman, PhD Catherine.freiman@novartis.com 734-424734-424-3783
65