Title: Informed ConsentInternational
1Informed Consent/International
- Melody Lin, Ph.D.
- Deputy Director, OHRP
- Director, OIA
- Beijing, China
- March 2003
2Objectives (1)
3Objectives (2)
- Process and Form
- Documentation and Waiver
- Research with Records and Specimens
4Why Have Informed Consent?
- Show respect to human subjects (HS)
- Mandated by regulations
- Protect HS
- Insure that HS understand risk-benefit associated
with participation - Provide HS all information needed for decision
making about participation
5Is It Just Signing the Form?
- No
- Involves
- Provide information
- Ensure understanding via question and
answer - Obtain voluntary agreement
6Who Ensures Compliance With Regulations?
- FDA 21CFR 50
- OHRP 45 CFR 26
- Study Centers IRB
7Basic Elements (1)
- Research, why, what, how long
- Risks or discomforts
- Potential benefits
- Aware of other alternatives
- Confidentiality protection
8Basic Elements (2)
- If subjects at risk of physical harm
- Care if injured, whom to contact
- Contact for questions, problems
- Can withdraw without penalty
9Additional Elements
- Additional where appropriate
- Possible unknown risks
- Involuntary termination
- Additional costs
- Consequences of withdrawal
- Inform of new findings
- Number of subjects
10Consent Must Be
- Individual
- Voluntary
- Informed
- Effective
- Continuous
11Subject Recruitment
- Recruitment ads, telephone scripts
- Often the first step in informed consent
- Must be reviewed by the IRB
12Consent Process and Form
- Consent is a PROCESS in which
- investigator discloses all relevant information
- potential subject has opportunity to ask
questions - investigator answers questions
- repeat the above..
- The consent form is a permanent record of
- information conveyed
- subjects willingness to participate
13Consent Process Must
- Give subject enough time to consider the decision
- Minimize possibility of coercion or undue
influence
45 CFR 46.116, 21 CFR 50.20
14Consent Form Must
- Be understandable to subject or representative
- NOT
- waive subjects rights
- release investigator, sponsor, institution from
liability
45 CFR 46.116, 21 CFR 50.20
15Documentation
- Use written form approved by IRB
- Form must be signed and dated by subject or
legally authorized representative - Give copy to subject/ representative
- Two types of forms permissible
45 CFR 46.117, 21 CFR 50.27
16Criteria for Waiving or Altering Informed Consent
- No more than minimal risk to subjects
- Waiver will not adversely affect the rights and
welfare of subjects - Research could not practicably be done without
the waiver or alteration - When appropriate, subjects will be given
additional pertinent information after
participation
45 CFR 46.116(d), but not FDA
17Criteria for Waiving Written Documentation of
Consent (45 CFR 46.117, 21 CFR 56.109)
- If consent form would be the only record linking
subjects to research, and the principal risk is
breach of confidentiality (HHS only) - If research has no more than minimal risk and
involves only procedures for which written
consent is not normally required outside research
(HHS and FDA)
18Do Retrospective Medical Record Reviews Require
- ...IRB APPROVAL?
- Yes, if they are done for research
- ...INFORMED CONSENT of research subject?
- Not always, if the IRB agrees that waiver is
appropriate
19Storage of Specimens for Future Research
- Why?
- Where?
- For how long?
- Who has access?
- With or without identifiers?
- Re-contact?
- What if clinically relevant information is found?
20OHRP Website
- http//ohrp.osophs.dhhs.gov/