Title: INTRODUCTION TO GOOD CLINICAL PRACTICE GCP IN RESEARCH
1INTRODUCTION TO GOOD CLINICAL PRACTICE (GCP) IN
RESEARCH
- DR. GODFREY BIEMBA
- MBCHB, DTMH, DLSHTM, MSC.
- EXECUTIVE DIRECTOR, CHAZ
2Workshop Objectives
- Understand Basic Concepts of Research
- Understand the Research Logic
- Appreciate the steps in a research proposal
- Understand Basics of Clinical trials
- Understand the concept of Good Clinical Practice
- Understand Basic Principles of Research Ethics
- Appreciate the practical challenges of conducting
a clinical trial - Understand the Current Projects
- Explore and Analyze the possible challenges of
current research projects and devise an action
plan to address them
3Introduction to Basic Concepts in Research 1 The
Research logic and basic steps in the research
process
4What is Research?
- Research refers to a search for an answer(s)
- This means there should first be a clear and
valid question(s) to be answered The Research
Question - It means there should be a problem that has no
clear solutions - Once a problem has been identified, there should
be a way of finding answers. This is generally
referred to as Research Methodology.
5SELECTION OF APROBLEM REQUIRING RESEARCH
- Not every problem requires research
- Whether a problem requires research depends on
three conditions - i. There should be a perceived difference or
discrepancy between what exists and the ideal or
planned situation - ii. The reason(s) for this difference should be
unclear (so that it makes sense to develop a
research question) - iii. There should be more than one possible
answer to the question or solution to the problem.
6The Research logic and basic steps in the
research process
- Identification of the problem,
- Identification of what has been done by other
researchers to address the problem, - Identification of an existing research gap
- Study Justification why carry out the study?
- What do we hope to achieve (Objectives)?
- What information/data do we need to collect in
order to answer the question (s) or to address
the problem? - How do we collect that information?
7The Research logic and basic steps in the
research process
- How do we manage that information in order to get
valid answers to our questions/problems? How do
we know we have the answers? - What are the threats to getting valid answers to
our questions using the chosen research design
and methods? - Who will do what and when?
- What shall we need to do the study?
- How much will it cost?
- Who should know the results? How shall we let
them know?
8The Research Logic
9The Research Logic
10The Research Logic
11The Research Proposal
- A scientific document that describes the
hypothesis, aims, objectives, and methods of a
proposed research project. - For Clinical studies, this includes the protocol,
which is a detailed plan of all that will be done
from the enrollment of the study clients to the
completion of the trial.
12Basic Stages of developing a Research Proposal
- Problem identification
- Problem Analysis
- Literature review
- Definition of Variables
- Objective setting
- Determination of the research design
- Definition of data collection tools
- Plan for data analysis
- Plan for publication and dissemination of
research findings
13Characteristics of a Good Research Proposal
- Clear Statement of the Problem
- Well planned with clear objectives
- Builds on existing data, using positive and
negative findings - New data is intended to be utilized to answer
original research question.
14Research Proposal format
- Take different forms dependent on donors,
University, IRBs/IECs requirements - Generally contain
- - The Title of the Project.
- - Introduction. This normally includes the
background to the problem being addressed by the
project, and the rationale for conducting the
research. - - Goals and Objectives Main aim of the
project, hypothesis, and specific objectives.
15Research Proposal format
- Study Design and Methods or Procedures Study
design, the study population, the sample size,
sampling methods, and the procedures. - Plan for Data Analysis. It is important that
from the proposal stage the researcher indicates
how they intend to analyze their data. - Ethical Consideration.
- Work Plan Budget.
- The Research Team.
- References
16Introduction to Basic Concepts in Research 2
GCP, GMP, GLP, SOPs, Data Safety Monitoring Board.
- Hypothesis
- Null Hypothesis
- Good Clinical Practice (GCP)
- Good Manufacturing Practice (GMP)
- Good Laboratory Practice (GLP)
- Standard Operating Procedures (SOPs)
- Data Safety Monitoring Board (DSMB)
- Blinding
- Placebo
- Confounding
17Hypothesis
- What is a Hypothesis?
- A hypothesis is an "educated guess". It can be an
educated guess about what nature is going to do,
or about why nature does what it does. - What makes a statement a scientific hypothesis,
rather than just an interesting speculation? A
scientific hypothesis must meet 2 requirements - It must be testable
- It must be falsifiable
- Must be testable
- Science proceeds by making observations of nature
(experiments). If a hypothesis does not generate
any observational tests, there is nothing that a
scientist can do with it. Arguing back-and-forth
about what should happen, or what ought to
happen, is not the way science makes progress.
18Hypothesis
- Consider this hypothesis
- Hypothesis A
- "Our universe is surrounded by another, larger
universe, with which we can have absolutely no
contact." - This statement may or may not be true, but it is
not a scientific hypothesis. By its very nature
it is not testable. There are no observations
that a scientist could make to tell whether or
not the hypothesis is correct. Ideas such as
Hypothesis A are interesting to think about, but
science has nothing to say about them. Hypothesis
A is a speculation, not a hypothesis.
19Hypothesis
- Hypothesis B
- "There are other inhabited planets in the
universe." - This hypothesis is testable, but it is not a
scientific hypothesis. Here's why. Hypothesis B
may be either correct or wrong. If it is correct,
there are several ways that its correctness can
be proven, including - A space probe sent from earth to explore the
universe sends back the news that it has
discovered an inhabited planet. (This news is
later confirmed by other space probes.) - Radio telescopes on earth begin to receive
signals from somewhere in the Andromeda Galaxy
that appear to be reruns of the "I Love Telek"
show. - Knock, Knock. "Greetings, earthling! I am Telek
from the planet Zoron in the Andromeda Galaxy. I
have just landed in your backyard. Take me to
your leader."
20Hypothesis
- So, if Hypothesis B is true, there are
observations that scientists could make that
would prove its correctness. But, the hypothesis
may be wrong. (Most hypotheses are...) If
Hypothesis B is wrong, there is no test that will
prove it. If one of our space probes never finds
an inhabited planet, it doesn't mean that one
doesn't exist. If we never receive signals from
space, or Telek never lands in your back yard,
that does not prove that the hypothesis is wrong,
either. Hypothesis B is not falsifiable.
21Hypothesis
- What about this
- Hypothesis C "Any two objects dropped from the
same height above the surface of the earth will
hit the ground at the same time, as long as air
resistance is not a factor." - Hypothesis C is a scientific hypothesis because
- It is testable - pick 2 objects, and drop them.
Of course, you may have to provide a vacuum for
them to fall in, in order to remove air
resistance from consideration. - It is falsifiable - If anyone finds 2 objects
that don't hit the ground at the same time and
can show that it is not due to air resistance,
then she has proven the hypothesis wrong. This
hypothesis "sticks its neck out" for every test.
In theory and in practice, if Hypothesis C were
wrong, it would be very easy and straightforward
to show it.
22Null Hypothesis
- In statistics a null hypothesis is a hypothesis
set up to be nullified or refuted in order to
support an alternative hypothesis. When used, the
null hypothesis is presumed true until
statistical evidence in the form of a hypothesis
test indicates otherwise. The use of the null
hypothesis is controversial - The null hypothesis is generally that which is
presumed to be true initially. Hence, we reject
only when we are quite sure that it is false,
often 90, 95, or 99 confident that the data do
not support it.
23GCP1 What is GCP?
- An international ethical and scientific quality
standard for designing, conducting, recording,
monitoring, auditing, analyzing, and reporting of
clinical trials that involve the participation of
human subjects. - Compliance with this standard provides public
assurance that the data and reported results are
credible and accurate, and that the rights,
safety and well-being of trial subjects are
protected, consistent with the principles that
have their origin in the Declaration of Helsinki.
24THE PRINCIPLES OF GCP
- Clinical trials should be conducted in accordance
with the ethical principles and consistent with
GCP. - A trial should be conducted only if the benefits
outweighs risks to both the subjects and society - The rights, safety, and well-being of the trial
subjects should prevail over interests of science
and society.
25THE PRINCIPLES OF ICH GCP
- Clinical trials should be scientifically sound,
and described in a clear, detailed protocol. - A trial should be conducted in compliance with
the protocol that has been approved by the
IRB/IEC. - The medical care given to, and medical decisions
made on behalf of, subjects should always be the
responsibility of a qualified physician or, when
appropriate, of a qualified dentist.
26THE PRINCIPLES OF ICH GCP
- Each individual involved in conducting a trial
should be qualified by education, training, and
experience to perform his or her respective
task(s). - Freely given informed consent should be obtained
from every subject prior to clinical trial
participation.
27THE PRINCIPLES OF ICH GCP
- All clinical trial information should be
recorded, handled, and stored in a way that
allows its accurate reporting,interpretation and
verification. - The confidentiality of records that could
identify subjects should be protected, respecting
the privacy and confidentiality rules in
accordance with the applicable regulatory
requirement(s).
28THE PRINCIPLES OF ICH GCP
- Investigational products should be manufactured,
handled, and stored in accordance with applicable
good manufacturing practice (GMP). They should - be used in accordance with the approved
protocol. - Systems with procedures that assure the quality
of every aspect of the trial should be
implemented.
29Good Laboratory Practice
- Good Laboratory Practice (GLP) embodies a set of
principles that provides a framework within which
laboratory studies are planned, performed,
monitored, recorded, reported and archived. These
studies are undertaken to generate data by which
the hazards and risks to users, consumers and
third parties, including the environment, can be
assessed for pharmaceuticals, agrochemicals,
cosmetics, food and feed additives and
contaminants, novel foods and biocides. GLP helps
assure regulatory authorities that the data
submitted are a true reflection of the results
obtained during the study and can therefore be
relied upon when making risk/safety assessments.
30Good Manufacturing Practice
- Good Manufacturing Practice means the part of the
quality assurance which ensures that medicinal
products are consistently produced and controlled
to the quality standards appropriate to their
intended use. - Good Manufacturing Practice is an international
set of guidelines by which drugs and medical
devices are manufactured. - A recommendation for "Good Manufacturing
Practice", first issued in by the World Health
Organization (WHO) in 1968, that ensures that the
products are manufactured and tested invariably
in compliance with the prescribed quality
standards
31Standard Operating Procedures (SOPs)
- Detailed, written instructions to achieve
uniformity of the performance of a specific
function.
32GCP2 Designing, Conducting and Monitoring
Clinical Trials under GCP
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34COHORT STUDT DESIGN
35Case Control Study
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37THE CLINICAL TRIAL
38Clinical Trials
- Carefully designed scientific studies aimed at
finding out the safety and efficacy of a
particular drug or intervention. - They answer the following questions regarding a
drug or an intervention Is the drug safe? Does
it work? Is it safe when used over a long period
of time? Does it work in many people over a long
period of time? Are there any long term side
effects?
39PHASES OF A CLINICAL TRIAL
40PRE-CLINICAL STUDIES
- In vitro testslaboratory experiments to find out
if a new drug works on human cells in test tubes.
- Animal studies These are meant to ascertain
efficacy and safety of the drug or intervention
in living creatures.
41CLINICAL STUDIES
- Phase1 Safety trials.
- Phase 2 The dose that has been found to be safe
in phase1 is given to a larger number of
participants over a longer period of time to see
if the drug really works and see if there are
long term side-effects.
42CLINICAL STUDIES
- Phase 3 The trial drug is given to a much larger
group of participants usually in many research
centers (multi-center trials) over many months or
even years to see if the drug remains useful or
has any side effects that only show after long
term use. - Phase 4 Post-marketing trials. These trials
could as well be called surveillance studies
because they are meant to monitor side-effects or
problems that may show up after several years of
use.
43Types of Clinical trials.
- Randomized controlled trial divides participants
randomly into two test groups using computer
generated random numbers - Double-blind controlled trialensures that
neither the participants nor the researchers know
who has received which treatment - Randomized double-blind controlled studywhich
combines both control measures. - Randomized open label placebo controlled
cross-over trial
44Conducting Clinical Trials
- Screening
- Enrollment
- Patient management and Monitoring
- Data management/recording
- Discharge
- Follow-up
45Screening
- Inclusion and Exclusion Criteria
46Enrollment Procedure
- Assess for admission to study (See Inclusion
Criteria). - Do a general physical exam including
Temperature, Pulse, BCS, assess Pallor, Jaundice,
Petechiae. - Do lab investigations
- Get Informed Consent from Parent or Guardian if
patient qualifies for study. - Enroll the patient and give study Identification
Number (SIN) - Do all Admission Routine as per Flow-sheet or
CRF.
47Revision Slide GCP
- A Quality and Ethical Standard that guides the
conduct of Clinical Trials from the design stage
to the Publication of results.
48Laboratory Procedures
- The Procedures
- Timing
- Quality control
- Communication with Clinical staff
- Storage of specimens for transportation
- Labeling Name, Age, Sex, Date, Time, Study No.
49Discharge Procedure
- Do all discharge orders as per flow-sheet
- Make sure you have all your contact persons full
name and residential address - Inform the parent or guardian who they should see
on review, when and where. - Give name of all alternative persons for the
parent/guardian to see if at time of review a
specific officer is not there, - Deal with all possible transport issues
necessary, - Find out if the address given is permanent or
they are just visiting.
50Follow up Procedure
- Ensure that the flow-sheet has all necessary
information for follow-up including landmarks to
find the village - Have a direction map on the discharge/follow up
form - Field officer to be there at discharge time to
appraise himself with the directions and names of
contact persons - Have good register of all discharged patients
- Liase well with Clinical monitors
- Create a computer data base with a prop-up
facility to remind you of due and
overdue(24hours) follow-ups. - All defaulting patients must be followed up
promptly.
51Data and Safety Monitoring
- Includes Clinical care of the patient
- Ensures the safety and wellbeing of the patient
- Data Safety Monitoring Board
- The Flow-sheet Follow the flow-sheet
-
52Data Safety Monitoring Board
- A group of independent researchers who review the
data while a clinical trial is going on, to
determine if one drug is markedly safer or more
effective than another. - Oversees and monitors clinical trials to ensure
participant safety and data validity and
integrity.
53Data Management
- Data Collection-tools, e.g. Flow-sheets, CRFs
- Data entry and storage-data bases, spreadsheets
and manual storage (filing). - Data Analysis-data must be entered on data bases
or spreadsheets in analysable form - - Different computer packages for data analysis,
e.g. Systat/Stata/Epi-info/SPSS - Publication and dissemination- Abstracts,
Publication into peer reviewed Scientific
Journals.
54Introduction to Data Processing and Data Analysis
55Data Processing and Analysis
- Data Processing
- Collection
- Recording
- Data entry/Data security
- Quality controls(including plan for handling of
missing data)Data cleaning, checking for
completeness and internal consistency - Analysis
56Planning for Data Analysis
- You MUST PLAN for Data Analysis at the DESIGN
STAGE - To ensure collection of NECESSARY Data
- To reduce collection of UN-NECESSARY Data
- Aim to Answer the main research question link
your analysis to your main and specific objectives
57Basic Steps in Quantitative Data Analysis
- 1.0 Clean your data
- Check for errors
- 2.0 Basic Descriptive analyses
- basic description of the data.
- summary statisticsFrequency tables, Proportions,
Mean, Range, Mode, etc. - graphical presentations
- Bar charts, Histograms, etc.
58Basic Steps in Data Analysis
- 3.0 Analyse Associations
- Crude Univariate analyses
- Classical methods are used for univariate
analysis to give an initial idea of the
relationship between the outcome and explanatory
variables within the dataset. - Estimate the magnitude of the difference in
outcome between exposure groupsestimate risk
ratio - Determine if the observed difference could be
explained by Chance(Significance testing)
59Is the observed difference true or just due to
chance?
- Start with the Null hypothesis that theres no
difference between the groups - Test the Null hypothesis with an appropriate
test Chi, Z-test, Fischers exact test(t-test),
etc.
60INTRODUCTION TO RESEARCH ETHICS
- -DR. GODFREY BIEMBA-
- MBCHB, DTMH, DLSHTM, M.SC Executive Director,
CHAZ, Chair-NHRAC, member UNZA REC
61AIMS OF THE SESSION
- Understand Basic Principles of Ethics
- Understand the importance of protecting the
rights of study subjects by means of the process
of informed consent - Understand how to complete the forms for
submission to Research Ethics Committee
62RESEARCH ETHICS
- What is Ethics?
- Morality
- Right or Wrong
- What is Morality?
- Right (good) and wrong (bad) in human actions,
conduct and behaviour. - What is Ethos?
- a professional code of conduct relevant to a
particular occupation - Ethical code or standard
63RESEARCH ETHICS
- Ethics and morality may be descriptive by
observing the way human beings behave or
normative by trying to figure out the right
course of action to take in a particular
circumstance. - Abuses in health research in the past led to the
development of the current international ethical
guidelines in biomedical research. - Example Tuskegee Syphilis Study (1932-1972)
Poor African American men were deceived and
observed for untreated syphilis.
64International Ethical Guidelines
- Declaration of Helsinki (1964/1975/1983/1989/1996/
2000, on biomedical research involving human
subjects) - International Ethical Guidelines for Biomedical
Research Involving Human Subjects (CIOMS
WHO1993) - World Health Organization Good Clinical Practice
Guideline (WHO GCP 1995) - International Conference on Harmonization Good
Clinical Practice Guideline (ICH GCP 1996) - Ethics Considerations in HIV Preventive Vaccine
Research (UNAIDS 2000).
65FUNDAMENTAL CONSIDERATIONS IN RESEARCH
- Scientific design,
- Care of the research participants,
- Ethics and scientific standards,
- The communities in which the research takes
place.
66Principles of Biomedical Ethics
- Autonomy
- Individuals should be treated as autonomous
agents. - Participation in a research project should be
voluntary and with adequate information no undue
coercion. - Beneficence/Non-Maleficence
- Do not harm
- Maximize possible benefits and minimize
possible harm. - Justice An injustice occurs when some benefit to
which a person is entitled is denied without good
reason or when some burden is imposed unduly.
67Ethical Guidelines
- Physicians duty to protect the life, health,
privacy, and dignity of the human subject. - Medical research involving human subjects must
conform to generally accepted scientific ethical
principles. - The research protocol should always contain a
statement of the ethical considerations involved
and should indicate that there is compliance with
international ethical guidelines. - The subjects must be volunteers and informed
participants in the research project.
68What makes Clinical Research Ethical?
- Social or Scientific Value
- Scientific Validity
- Fair Subject Selection
- Favourable risk-benefit ratio
- Independent review
- Informed Consent
- Respect for potential and enrolled subjects
69UNZA ETHICAL GUIDELNES
- Submit proposal to Secretary of Research and
Ethics Committee - Submission should include
- - 20 copies of application form,
- 4 copies of full protocol,
- Any questionnaires in four copies
- Informed consent in four copies
- 4 copies of Principal Investigators CV
- 4 copies of approval from appropriate research
committee or Research Technical Committee - 4 copies of External Ethical Approval Letter
70The Informed Consent Process
- Dr. Godfrey Biemba
- MBCHB, DTMH, DLSHTM, MSC
- Executive Director, CHAZ
71Informed Consent
- Respect for persons requires that subjects, to
the degree that they are capable, be given the
opportunity to choose what shall or shall not
happen to them. - Consent Form must contain at least three
elements - a) Information
- b) Understanding/Comprehension
- c) Voluntariness
72Informed ConsentInformation
- - This means full disclosure of information,
unless such disclosure impairs the validity of
the research. This is only justified if, there
are no undisclosed risks that are more than
minimum and there are plans to debrief the
subjects when appropriate. - - Includes that it is a research project, the
procedures, risks, benefits, alternative
procedures, a statement offering the subject the
opportunity to ask questions(including name and
address of the person to ask questions) and to
withdraw at any time from the research without
compromising present or future care.
73Informed Consent
- Comprehension - The manner and context in which
information is presented is as important as the
information itself. - - Avoid technical jargon, use local language
translation - Voluntariness - Requires conditions free of
coercion and undue influence.
74The Informed Consent Process
- It is a Process, not a one time event
- Involves four stages
- Verbal Discussion - Doctor has preliminary
discussions with patient to explain diagnosis,
prognosis and treatment options, both standard
and investigational. - Information sheet and Consent Forms - The patient
is given (explained) an information sheet which
contains comprehensive details of study treatment
including rationale for study, possible benefits
as well as adverse effects sub-divided into
likely, less likely and remote possibilities. - Discussion - The trial is again explained to the
patient and the patient encouraged to ask
questions. - On going dialogue The Doctor and
patient/guardian engage in an ongoing dialogue - Based on four basic principles Do good, Do No
Harm, Autonomy, Justice.
75The Informed Consent Process-Adequate disclosure
and maintenance of Consent-
- What constitutes adequate disclosure of
information? How much information is considered
"adequate"? - reasonable physician standard what would a
typical physician say about this intervention? - reasonable patient standard what would the
average patient need to know in order to be an
informed participant in the decision? - subjective standard 1 what would this patient
need to know and understand in order to make an
informed decision? - subjective standard 2what would this patient and
relatives need to know and understand in order to
maintain their informed decision?
76The Informed Consent Process-Maintaining the
Informed Consent-
- Barriers to refusal and maintenance of consent
- Communication barriers
- Misperceptions
- Misconceptions
- Concerns over the protocol and the implications
- Poor motivation
77The Informed Consent Process-Maintaining the
Informed Consent-
- Communication Develop a communication strategy
(Mapping strategy) - Identify main issues at each stage of the
research - Develop appropriate messages to address the
issues - Develop strategies/ways of communication to
address the issues - Maintain effective communication
- Motivation
- Identify motivating and de-motivating factors
- Address de-motivating factors
- Put in place motivators
- Misconceptions and Misperceptions
- These arise from ineffective communication
- They also arise from inherent cultural beliefs a
thorough understanding of these beliefs is part
of the answer to addressing them. - Effective Counseling is vital in addressing
these this requires full and continuous DIALOGUE
78Compliance with GCP
- Is the design scientifically and ethically sound?
- Is the Study Protocol Clinically, ethically and
scientifically sound? - Is there an Informed Consent Process following
international ethical standards? - Is there an efficacy and safety monitoring system
in place - Is there a quality assurance system in place at
all levels of the study process (screening,
enrollment, data collection/recording, patient
monitoring, data entry)? - Is there evidence that the trial drug has been
produced under GMP?
79Current Project COARTEM STUDY
- Study Purpose To obtain efficacy, safety,
tolerability and pharmacokinetic data of Coartem
dispersible tablet formulation for oral
suspension in infants and children equal or less
than 12 years with body weight/gt5kg and lt35kg
suffering from acute uncomplicated P. falciparum
malaria in order to gain regulatory approval for
to make Coartem paediatric formulation available
for clinical use in Africa.
80Current Project COARTEM STUDY
- Primary Objective
- To confirm the efficacy of Coartem paediatric
formulationby testing the hypothesis that
Coartem 6-dose regimen paediatric formulation is
non-inferior to the presently used Coartem 6-dose
regimen of crushed conventional tablet
formulation on the 28-day Polymerase Chain
Reaction (PCR)-corrected parasitological cure
rate.
81Current Project COARTEM STUDY
- Secondary Objectives
- To compare 7-day parasitological cure rate, 14
day PCR correlated parasitological cure rates
between the two treatment groups - To compare time to parasite, fever, and
gametocyte clearance between the two treatment
groups - To compare the safety and tolerability profile of
the two treament groups on Adverse Events,
general laboratory, vital signs and ECG
measurements - Exploratory Objectives
- To explore the incidence of early treatment
failures with the paediatric formulation
82Current Project COARTEM STUDY
- Design Randomized, investigator-blinded,
multicentre, parallel group study to compare
efficacy, safety and tolerability of Coartem
dispersible tablet formulation vs. Coartem 6 dose
crushed tablet in the treatment of acute
uncomplicated P. Falciparum malaria in infants
and children. - Group1 /gt5kg - lt15kg
- Group2 15kg - lt25kg
- Group3 25 kg - lt35kg
83COARTEM STUDY Study Size and Interim Analysis
- Initially 160 patients will be enrolled
- Interim Analysis will be performed by DSMB for
perceived futility for efficacy as the new
formulation has never been tested in humans - No more patients to be enrolled till completion
of interim analysis and recommendation by DSMB to
continue or otherwise
84Protection of Human Subjects,Data and Safety
Monitoring
- Informed Consent will be obtained
- Serious Adverse Events (SAEs) experienced within
4-weeks of study must be reported to Norvatis
within 24hours or occurrence - Site Monitoring
- Data management and Quality Control system in
place - Data from CRFs entered on databse by expert
research organization using a proven SOPs - Entered data checked for errors by data
management staff - DSMB in place
85Does the Coartem Study Comply with GCP?
- Is the design scientifically and ethically sound?
- Is the Study Protocol Clinically, ethically and
scientifically sound? - Is there an Informed Consent Process following
international ethical standards? - Is there an efficacy and safety monitoring system
in place - Is there a quality assurance system in place at
all levels of the study process (screening,
enrollment, data collection/recording, patient
monitoring, data entry)? - Is there evidence that the trial drug has been
produced under GMP?