Title: Good Clinical Practices with differences b/w Indian GCP and ICH-GCP
1Good Clinical Practices (GCP)
Dr. Ranjeet Prasad (MBA,CCRP,BDS)
2Agenda
- Evolution of GCP.
- ICH-GCP.
- Differences and Similarities between ICH-GCP ,
Indian GCP and Schedule-Y - Key Players in Clinical Research and their
checklists
3Evolution
- Nuremberg Code, 1947
- Declaration of Helsinki, 1964 ? 2001
- ICH GCP guidelines, 1996
- Ethical Guidelines for Biomedical Research in
Human Subjects (ICMR), 2000 - GCP Guidelines, CDSCO, New Delhi, 2001
4ICH-GCP-Introduction
- Good Clinical Practices (GCP) is an international
ethical scientific quality standard for
designing, conducting, recording reporting
trials that involve the participation of human
subjects. - Compliance with this standard provides public
assurance that rights, safety well being of
trial subjects are protected, consistent with the
principles that have their origin in the
declaration of Helsinki, and that the clinical
trial data are credible
5ICH GCP- Objective
- To provide a unified standard for the EU, Japan
the US to facilitate the mutual acceptance of
clinical data by regulatory authorities in these
jurisdictions - Should be followed when generating data that are
intended to be submitted to regulatory
authorities (only then??)
6ICH GCP-Section 1
- Section 1- Glossary of various terms, eg...
- Adverse drug reaction Adverse Event
- Case report form Clinical Study Report
- Coordinating Committee Contract Research
Organization - Independent Ethics Committee Institutional
Review Board - Investigator Investigators Brochure
7ICH GCP-Section 1 Cont
- Monitoring Monitoring report
- Protocol Protocol Amendment
- Serious Adverse Event
- Source data Source documents
- Sponsor Sponsor investigator
- Standard Operating Procedures
- Vulnerable subjects
8ICH GCP-Section 2
- Section 2- Principles of ICH-GCP.
- 2.1 Clinical Trials should be conducted in
accordance with the ethical principles
consistent with GCP and applicable regulatory
requirements - 2.2 Before a trial is initiated, forseeable risks
inconveniences should be weighed against
anticipated benefit for the trial subject
society.
9ICH GCP-Section 2 Cont..
- 2.3 The rights, safety, and well being of the
trial subjects are the most important
considerations should prevail over interests of
science and society - 2.4 The available nonclinical clinical
information on an investigational product should
be adequate support the proposed clinical trial. - 2.5Clinical trials should be scientifically
sound, and described in a clear, detailed
protocol.
10ICH GCP-Section 2 Cont..
- 2.6 Trial should be conducted in compliance with
the protocol that has received prior
institutional review board (IRB)/ independent
ethics committee (IEC) approval/favourable
opinion. - 2.7 The medical care and medical decisions for
subjects should be the responsibility of a
qualified physician - 2.8 Each individual involved in conducting a
trial should be qualified by education, training
experience to perform his respective task
11ICH GCP-Section 2 Cont..
- 2.9 Freely given informed consent should be
obtained from every subject prior to clinical
trial participation - 2.10 All clinical information should be recorded,
handled, and stored in a way that allows its
accurate reporting, interpretation and
verification - 2.11 The confidentiality of records that could
identify patients should be protected, respecting
the privacy and confidentiality rules in
accordance with the applicable regulatory
requirements
12ICH GCP-Section 2 Cont..
- 2.12 Investigational products should be
manufactured, handled and stored in accordance
with applicable GMP, and used in accordance with
the protocol - 2.13 Systems with procedures that assure the
quality of every aspect of the trial should be
implemented
13ICH-GCP-Section 3
- Institutional Review Boards/ Independent Ethics
Committee
14Section 3.1 IRB/IEC Responsibilities
- Should safeguard the rights, safety well being
of all trial subjects. - Should obtains following Documents Protocol
their amendments, Patient Information sheet
consent form, subject recruitment procedures
(e.g. advertisements), Investigator's Brochure
(IB), available safety information, information
about payments and compensation available to
subjects, the investigators current curriculum
vitae and/or other documentation evidencing
qualifications, and any other documents that the
IRB/IEC may need to fulfil its responsibilities
15Section 3.1 IRB/IEC Responsibilities Cont..
- should conduct continuing review of each ongoing
trial at intervals appropriate to the degree of
risk to human subjects, but at least once per
year. - Review Protocol/ ICD/ recruitment procedures/
IB/payments - Continuing review for Ongoing Progress/Adverse
events
16Section 3.2 IRB/IEC Composition
- At least 5 members
- At least one non scientific member
- At least one independent member
- Maintain list of members and qualifications
- Only independent members to vote
- Quorum to be present
17Section 3.3 Procedures
- The IRB/IEC should establish, document in
writing, and follow its procedures, which should
include - Composition
- Meeting Scheduling conduct
- Specify that trial starts only after IRB review
- Specify regarding changes in protocol
- Specify prompt reporting of adverse events
18Section 3.4 Records
- The IRB/IEC should retain all relevant records
(e.g., written procedures, membership lists,
lists of occupations/affiliations of members,
submitted documents, minutes of meetings, and
correspondence) for a period of at least 3 years
after completion of the trial and make them
available upon request from the regulatory
authority(ies). - The IRB/IEC may be asked by investigators,
sponsors or regulatory authorities to provide its
written procedures and membership lists.
19ICH-GCP Section 4
20Section 4.1Investigator qualifications
Agreements
- Qualified (documented) by education, training
experience to assume responsibility for proper
trial conduct - Should be familiar with the appropriate use of
the investigational product, IB, and other
information provided by sponsor - Should be aware of, should comply with, GCP and
the applicable regulatory requirements - Should permit monitoring, auditing and inspection
- Delegation of duties to appropriately qualified
persons
21Section 4.2 Adequate Resources
- Potential for recruitment
- Sufficient time for trial conduct and completion
- Staff, facilities
- Ensure training to staff
22Section 4.3 Medical care of trial subjects
- Qualified physician investigator/sub investigator
for the trial, should be responsible for all
trial related medical decisions - Adequate medical care during and after trail
participation - Make reasonable efforts ascertaining for
premature withdrawal from trial
23Section 4.4 Communication with IRB
- Written dated approval for trial protocol, ICD,
recruitment procedures etc prior to trial
initiation - Should provide latest copies of IB to IRB
- Should provide all relevant documents for review
during trial
24Section 4.5 Compliance with Protocol
- Should conduct trial in accordance with the
protocol version agreed documented by the
sponsor, IRB and regulatory authority - No changes allowed in the protocol except in case
of immediate hazard to the patient which should
be submitted to all immediately
25Section 4.6 Investigational Product
- Responsible for accountability at site
- May be assigned to pharmacist/individual
- Stored as specified by sponsor or regulatory
authority - Used only in accordance with the protocol
26Section 4.7 Randomization Procedures and
unblinding
- Should follow the trials randomization procedure
- Any premature unblinding to be explained to
sponsor
27Section 4.8 Informed Consent
- Comply with regulatory requirement, GCP and
ethical principles - Documented Communication of revised ICD to IRB
and patient - No influence or coercion to participate
- Subject or their legal representative should be
fully informed in their own language - Non technical language
28Section 4.8 Informed Consent cont..
- Ample time for consent and opportunity for
questions - Impartial witness for illiterate patients
- Subject should receive a copy of the signed and
dated ICD/ amendment
29Section 4.9 Records and reports
- Should ensure accuracy, completeness, legibility
and timeliness of data to sponsor in CRF - Correction in CRF should be signed, dated
- Maintain trial related documents
- Financial agreements in place
- Access to records by monitor, regulatory agency
or auditors - Progress reports to IRB
30Section 4.10 Progress reports
- The investigator should submit written summaries
of the trial status to the IRB/IEC annually, or
more frequently, if requested by the IRB/IEC. - The investigator should promptly provide written
reports to the sponsor, the IRB/IEC (see 3.3.8)
and, where applicable, the institution on any
changes significantly affecting the conduct of
the trial, and/or increasing the risk to subjects
31Section 4.11Safety Reporting
- SAE should be reported immediately to sponsor,
and timely as required to IRB/regulatory agency - 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/IEC with any
additional requested information (e.g., autopsy
reports and terminal medical reports).
32Section 4.12 Premature termination of trial
- If the trial is prematurely terminated or
suspended for any - reason , Investigator
- Should inform subjects
- Should assure therapy and follow up
- Should inform regulatory authorities
- Should inform sponsor/IRB with explanation
33Section 4.13 Final Report
- Upon completion, should inform institution, IRB,
and regulatory authorities with a summary of the
trials outcome
34ICH-GCP Section 5
35Sponsor
- An individual, company, institution, or
organization which takes responsibility for the
initiation, management, and/or financing of a
clinical trial
36Section 5.1 Quality Assurance Quality Control
- Implementing maintaining QA and QC systems with
written SOPs to ensure GCP compliance - Securing agreements from all sites for
monitoring, auditing, and inspections - QC of data handling
- Payment agreements
37Section 5.2 CRO
- A person or an organization (commercial,
academic, or other) - contracted by the sponsor to perform one or more
of a sponsors - trial related duties and functions
- Sponsor may transfer all or some duties to CRO
- Ultimate responsibility for quality lies with the
sponsor - Document of all duty delegation required
38Sponsor Responsibilities
- Designate Medical Expertise who will be readily
available to advise on trial related medical
questions or problems. (Section 5.3) - Trial design (Section.5.4), Trial management,
Data handling and Record Keeping (Section 5.5)
and Investigator selection (Section 5.6),
Allocation of Responsibilities (Section 5.7) - Compensation to Subjects and Investigators
(Section 5.8), Financing (Section 5.9) - Submission to regulatory authorities (Section
5.10) - Confirmation of review by IRBs (Section5.11)
39Sponsor ResponsibilitiesCont.
- Information on investigational product (Section
5.12) - Manufacturing, labeling, packaging coding of
product (Section 5.13) - Supplying and Handling Investigational Product(s)
(Section 5.14) and Record Assess (Section 5.15) - Safety Evaluation (Section 5.16) and Adverse Drug
Reaction Reporting (Section 5.17) - Monitoring (Section 5.18)
40Monitoring
- The act of overseeing the progress of a clinical
trial, and of ensuring that it is conducted,
recorded, and reported in accordance with the
protocol, SOPs, GCP, and the applicable
regulatory requirements
41Sponsor ResponsibilitiesCont.
- Audit (Section 5.19)
- Noncompliance (Section 5.20)
- Premature Termination or Suspension of a Trial
(Section5.21) - Multicentre Trials (Section 5.22)
42ICH-GCP Section 6
- CLINICAL TRIAL PROTOCOL
- AND
- PROTOCOL AMENDMENT(S)
43Protocol
- Document describing all aspects of the study
- Well designed and thoroughly considered
- Well structured
- Complete
44Protocol- Relevant components
- General Information (Section 6.1)
- Background Information (Section 6.2)
- Trial Objectives and Purpose (Section 6.3)
- Trial Design (Section 6.4)
- Selection and Withdrawal of Subjects (Section
6.5) - Treatment of Subjects (Section 6.6)
- Assessment of Efficacy (Section 6.7)
- Assessment of safety (Section 6.8)
45Protocol- Relevant componentsCont
- Statistics (Section 6.9)
- Direct Access to Source Data/Documents (Section
6.10) - Quality Control and Quality Assurance (section
6.11) - Ethics (section 6.12)
- Data handling management (Section 6.13)
- Financing and Insurance (Section 6.14)
- Publication Policy (Section 6.15)
- Supplements (Section 6.16)
46Sec 6.1 Protocol- General Information
- Protocol Title, identifying number date.
Amendment number - Contact names, addresses
- Name and title of Authorized signatory
- Contact medical expert
- Contact investigator(s)
- Institution(s), Laboratories, department contact
47Sec. 6.2Protocol- Objective Justification
- Aims objectives, phase of study
- Name description of Inv product
- Summary of non clinical clinical studies
- Summary of risks benefits
- Description of route of administration, dosage
- Statement of GCP compliance
48Sec 6.4 Protocol- Trial Design
- Primary secondary endpoints
- Randomized/comparator/blinded/open, placebo
controlled - Blinding technique(double blind/single blind)
- Randomization(method procedure)
- Diagram of design, procedure stages
- Medications permitted not permitted during
study - Description of study treatments, dose, route
during study conduct - Packing/labeling description
- Duration of subject participation sequence of
all study periods, including follow up
49Sec 6.4 Protocol- Trial DesignCont.
- Proposed date of initiation of study
- Discontinuation criteria for subjects
- Instructions on suspending or terminating the
study - Procedures for monitoring compliance
50Sec 6.5 Selection and Withdrawal of Subjects
- Inclusion/ Exclusion criteria
- Specifications of the subjects to be included
(age, gender, ethnic groups, prognostic factors,
diagnostic criteria) - Specify exclusion criteria
- Subject withdrawal criteria procedures
51Sec 6.7 Protocol-Assessment of Efficacy
- Specifications of efficacy parameters
- Descriptions of how these are measured and
recorded - Time periodicity of recording
- Description of special analysis/ tests (PK,
clinical, lab, radiology) - Specifications of safety parameters
- Procedures for eliciting reports of and reporting
ADR - Time method of recording
- Type, duration of follow up after adverse events)
52Sec 6.9 Protocol- Statistics
- Description of statistical methods employed
- Timing of interim analysis, if any
- Details of enrollment plan
- Significance level, power
- Procedures for reporting any deviations from the
original statistical plan - Selection of subjects to be included in final
analysis
53Sec 6.10 Direct Access to Source Data/Documents
- The sponsor should ensure that it is specified in
the protocol or other written agreement that the
investigator(s)/institution(s) will permit
trial-related monitoring, audits, IRB/IEC review,
and regulatory inspection(s), providing direct
access to source data/documents
54Sec 6.11 Protocol- QC QA
- Steps procedures for monitoring study
- Instructions for protocol deviations
- Allocation of duties responsibilities within
research teams - Quality control of methods evaluation procedures
55Sec 6.12Protocol- Ethical considerations
- Description of how patients/volunteers would be
informed
56Sec 6.13 Protocol-Data Handling and Record
Keeping
- Procedures for handling processing records of
effects and adverse events - Handling of Products
- Safe handling and storage measures
- System to be followed for labelling
- Labeling specifications
57Sec. 6.14 Protocol- Finance insurance
- Budget, financial aspects
- Sources of economic support
- Subject payments
- Reimbursement to team members
- Insurance details of study subjects
58ICH-GCP Section 7
59Section 7 Investigator Brochure-Introduction
- Compilation of the clinical and nonclinical data
on the investigational product that are relevant
to the study of the products in human subjects
60Sec 7 Investigator Brochure Contents
- Introduction
- Definition
- Purpose
- Information form
- Edition
- Type extent
- Review revise
- Up-date
- General consideration
- Contents of the IB
- Conclusion
-
61ICH-GCP Section 8
- ESSENTIAL DOCUMENTS FOR THE CONDUCT OF A
CLINICAL TRIAL
62Sec 8 Essential Documents -Introduction
- Essential Documents are those documents which
individually and collectively permit evaluation
of the conduct of a trial and the quality of the
data produced. - These documents serve to demonstrate the
compliance of the investigator, sponsor and
monitor with the standards of Good Clinical
Practice and with all applicable regulatory
requirements
63Essential Documents to be Kept before Trial
Commences
- Investigators Brochure
- Signed protocols, amendments (if any) and sample
CRF - Information given to the trial subjects
- Informed Consent
- Applicable translations of informed consent (if
any) - Any other written information
- Advertisements for subject recruitment
- Subject compensation
- Financial aspects of the trial
- Compensation document for trial-related injury
- Signed agreements of all involved parties
- Investigator and sponsor
- Investigator and CRO (if any)
- Investigator/institution and regulatory
authorities (if any) - Approval letter from the IRB
- IRB Composition
- Authorization or notification from the regulatory
agencies (where required)
64Essential Documents to be Kept before Trial
Commences
- CV of investigator and sub-investigators
evidencing qualifications - Normal values of labs /technical procedures
included in the protocol - Medical/laboratory and technical procedures of
tests - Certification
- Accreditation
- Established Quality control (QC assessments)
- Other validations
- Sample labels attached to investigational product
containers - Instructions for handling investigational
products and trial-related materials (sometimes
this information is included in the
investigators brochure) - Shipping records of investigational products and
trial-related materials - Certificates of analysis of investigational
products shipped - Decoding procedures for blinded trials
- Master randomization list
- Pretrial monitoring report
- Trail initiation monitoring report
65Essential Documents to be Kept During the Trial
- Investigators brochure updates
- Any revisions to
- Protocol, amendments and CRF
- Informed consent form
- Written information provided to subjects/LAR
- Advertisement
- Dated, IRB approved documents of
- Protocol amendments
- Revisions of informed consent, information to
subjects/LAR - Advertisements and any other documents given
- Continuing review of trial
- Dated Regulatory approved documents of
- Authorizations and notifications
- Protocol amendments and other documents
66Essential Documents to be Kept During the Trial
- Curriculum Vitae of new investigators and
sub-investigators - Updates to normal value(s) range(s) for medical
lab technical procedure(s), test(s) included in
the protocol - Updates on medical/laboratory/technical procedure
tests - Certificates
- Accreditation
- Established quality control/external quality
assessment - Other validations
- Documentation of investigational products and
trial-related materials shipment - Certificate(s) of analysis for new batches of
investigational products - Monitoring visit reports
- Relevant communications other than site visits
(Letters, meeting notes and notes of telephone
calls) - Signed informed consent forms
- Source documents
- Signed, dated and completed CRF
- Documentation of CRF Corrections
67Essential Documents to be Kept During the Trial
- Notification by the originating investigator to
sponsor of serious adverse evens and related
reports - Notification by investigator (if applicable) to
regulatory authorities and IRB of unexpected
serious adverse reactions and of other safety
information - Notification by sponsor to investigators of
safety information - Subject screening log
- Subject identification code list
- Subject enrolling log
- Investigational product(s) accountability at the
sire - Signature sheet
- Record of retained body fluids/tissue samples (if
any)
68Essential Documents to be Kept After Completion
or Termination of the Trial
- Investigational product(s) accountability at sire
- Documentation of investigational product(s)
destruction - Completed subject identification code list (to
permit identification of all subjects enrolled in
the trial in case of follow up is required this
information should be kept in a confidential
manner and for agreed period of time) - Audit certificate (if required)
- Final trial close-out monitoring report
- Treatment allocation and decoding documentation
returned to sponsor to document any decoding that
may have occurred - Final report by investigator to IRB where
required - Final report by investigator to regulatory
authorities where applicable to document
completion of the trial - Clinical study report to document results and
interpretation
69Differences and similarities between ICH-GCP and
Indian GCP
70Indian GCP Dec 2001
- Expert Committee set up by Central Drugs Standard
Control Organization (CDSCO) in consultation with
clinical expert has formulated this GCP guideline - Drug Technical Advisory Board (DTAB), the
highest technical body under DC, Act, has
endorsed adoption of this GCP guideline for
streamlining the clinical studies in India - These guidelines have been evolved with
consideration of WHO, ICH, USFDA and European GCP
guidelines as well as the Ethical Guidelines for
Biomedical research on Human Subjects issued by
the Indian Council of Medical Research.
70
71STRUCTURE
- Definitions
- Pre-requisites
- Responsibilities
- Records Data
- Quality Assurance
- Statistics
- Special Concerns
- Appendices
- Glossary
- Principles
- IRB/IEC
- Investigator
- Sponsor
- Protocol
- Investigators Brochure
- Essential Documents
71
72GCP - A Shared Responsibility
Sponsor Investigator Regulatory
Authority Ethics Committee
72
73GCP IMPLEMENTATION
Attitude
Want to
Performance
Skills
Knowledge
How to
73
What to Why to
74Schedule Y DRUGS AND COSMETICS (IIND AMENDMENT)
RULES, 2005 NOTIFICATION the 20th January, 2005
- Amendment to Drugs and Cosmetics Act, 1940
- Enacted by Parliament in the Fifty-sixth year of
Republic of India - Published in the Gazette of India Part-II,
section 3, sub-section (i) vide G.S.R. 32(E),
dated 20th January, 2005
74
75Schedule Y
- Regulation and guidelines for permission to
import and / or manufacture of new drugs for sale
or to undertake clinical trials - It has outlined extensive study criteria in line
with the globally accepted formats such as ICH
and US FDA guidelines - REFER TO RULES 122A, 122B, 122D, 122DA, 122DAA
and 122E
75
76122-A Application for permission to import new
drug 122-B Application for approval to
manufacture new drug 122-D Permission to
import or manufacture FDC 122-DA Permission to
conduct clinical trials for New Drug /
Investigational New Drug 122-DAA Clinical
trial 122-ENew drug
76
77List of Appendices For Schedule Y
78 Appendix I-A Data required to be submitted by an
applicant for grant of permission to import
/or manufacture a new drug already approved in
the country.
Appendix I Data to be submitted along with the
application to conduct clinical trials / import
/ manufacture of new drugs for marketing in the
country.
Appendix II Structure, contents format for
clinical study reports
Appendix II Structure, contents format for
clinical study reports
Appendix III Animal toxicology (non-clinical
toxicity studies)
Appendix III Animal toxicology (non-clinical
toxicity studies)
Appendix V Informed Consent
Appendix IV Animal pharmacology
Appendix VII Undertaking by the Investigator
Appendix VI Fixed Dose Combinations (Fdcs)
Appendix IX Stability Testing Of New Drugs
Appendix VIII Ethics Committee
Appendix X Contents Of The Proposed Protocol For
Conducting Clinical Trials
Appendix XI Data Elements For Reporting Serious
Adverse Events Occurring In A Clinical Trial.
78
79INFORMED CONSENT PROCESS
79
80ESSENTIAL ITEMS FOR INFORMED CONSENT
81ETHICS COMMITTEE COMPOSITION
82DRUG LABEL
83DOCUMENT RETENTION
84POWERS OF IEC
85STANDARD OPERATING PROCEDURES
86INVESTIGATORS QUALIFICATION
87Key Players in Clinical Research and their
checklists
88Players in Clinical Research
- Investigators
- Sponsors
- Regulatory agency
- Ethics Committee
89Investigators checklist - 1
- Interest, expertise, time and facilities
- Interaction with sponsor
- Protocol, CRF, PIS and ICF
- Financial grant
- Publication policy
- Interaction with ethics committee
- Presentation and defense of protocol
- Compliance with conditions of approval
90Investigators checklist - 2
- Implementation
- Organizing, briefing and supervising the team
- Facilitating informed consent process
- Completing and signing CRFs
- Reporting SAE
- Interacting with monitor
- Reviewing and approving final report
- Archiving source documents
- Preparing for audit and/or inspection
91Sponsors checklist - 1
- Scientific, regulatory and ethical basis of the
protocol, PIS and ICF - Investigators qualifications, training and
experience - Regulatory and ethical approvals
- Publication policy
- Quality of trial supplies
- Initiation, monitoring and audit
92Sponsors checklist - 2
- Data management and analysis
- Drafting of study report
- Preparation for inspection
- Archives of source documents
93Regulators checklist
- Periodic review of current regulations from
scientific and ethical angles - Advance consultation to sponsors on protocols
- Efficacy and safety criteria
- Comparator product
- Advisory panels for review of applications and
decision making - Inspection of investigational centers
94Ethics Committees checklist - 1
- Need for trial
- Scientific aspects of protocol with ethical
implications - Participants
- Number
- Healthy volunteers or patients
- Vulnerable persons
95Ethics Committees checklist - 2
- Treatment
- Withdrawal of current treatment
- Assignment of placebo
- Dosage and route
- Assessment of response
- Nature and frequency
- Invasive or non-invasive
- Total blood drawn
96Ethics Committees checklist - 3
- Ethical aspects of protocol
- Information and consent form
- Content and language
- Risks and benefits
- Compensation or other payments
- Insurance for study-related injury
- Treatment after study
- Regulatory approval
97Happy Reading