Tag Archives: good clinical practice

ICH is coming to Town – European Medicines Agency (EMA)

The International Conference on Harmonization (ICH)  is involved in promoting public health, improve efficiency of new drug development and registration process among other objectives. In order to accomplish this, ICH has developed and implemented harmonized guidelines and standards, also known as ICH6.

ICH Steps

Over 50 guidelines on technical requirements on:
Quality, Safety and Efficacy
Efficacy – 14 topics/17 guidelines
Safety – 8 topics/16 guidelines
Quality – 9 topics/23 guidelines

  • Maintenance of ICH Controlled Terminology Lists
  • Medical dictionary for adverse event reporting and coding
    of clinical trial data (MedDRA)
  • Electronic Standards for the Transfer of Regulatory
    Information
  • Common Technical Document (CTD & eCTD)

The European Medicines Agency (EMA) is a decentralised body of the EU. EMA is responsible for centralised procedure and co-ordination of EU network + plays a role in stimulating innovation and research in the pharmaceutical sector.

EMA is not an FDA for Europe

EMA responsibility does not include:

  • Evaluation of all medicines in the EU
  • Research/development of medicines
  • Clinical trial approval
  • Medical devices
  • EU healthcare policies
EMA Regulatory Process

 

 

Conclusion: ICH-GCP guidelines brought forth public awareness that there was a need to control and regulate clinical trials dealing with drugs and human subjects.

ICH main goal is to provide a unified standard for the European Union (EU), Japan and the United States to facilitate the mutual acceptance of clinical data by the regulatory authorities in these jurisdictions.

Source:

Guidelines on good clinical practice (European Community and within the ICH regions)  – https://ec.europa.eu/

Presentation – ICH and EU regulatory – www.ema.europa.eu

 

Recommended Posts:

https://edcdeveloper.wordpress.com/2015/05/11/are-you-practicing-gcp/

https://edcdeveloper.wordpress.com/2011/11/17/21-cfr-part-11-cheat-sheet-for-the-edc-developer/

Fair Use Notice: Images/logos/graphics on this page contains some copyrighted material whose use has not been authorized by the copyright owners. We believe that this not-for-profit, educational, and/or criticism or commentary use on the Web constitutes a fair use of the copyrighted material (as provided for in section 107 of the US Copyright Law).

Advertisements

How to document the testing done on the edit checks?

Since the introduction of the Electronic Data Capture (EDC) in clinical trials where data is entered directly into the electronic system, it is estimated that the errors (e.g. transcription error) have been reduced by 70% [ Clinical Data Interchange Standards Consortium – Electronic Source Data Interchange 2005].

The Data Management Plan (DMP) defines the validation test to be performed to ensure data entered into the clinical database is complete, correct, allowable, valid and consistent.

Within the DMP, we find the Data Validation Plan. Some companies call it ‘DVS’ others ‘DVP’.  The Good practices for computerized systems in regulated GxP environments defines validation as a system that assures the formal assessment and reporting of quality and performance measures for all the life-cycle stages of software and system development, its implementation, qualification and acceptance, operation, modification, qualification, maintenance, and retirement.

As an {EDC} Developer or Clinical Programmer, you will be asked to:

  • Develop test scripts and execution logs for User Acceptance Testing (UAT).
  • Coordinate of UAT of eCRF build with clinical ops team members and data management and validating documents, included but not limited to: edit check document, issue logs, UAT summary report and preparation and testing of test cases.

Remember not every EDC system is alike. Some systems allow you to perform testing on the edit checks programmed; others allow you to enter test data on a separate instance than production (PROD).

Data Validation and UAT Module.png

For example, some EDC systems facilitate re-usability:

  1. There is a built-in test section for each study – where data can be entered and are stored completely separate from production data. This allows you to keep the test data for as long as needed to serve as proof of testing.
  2. The copy function allows for a library of existing checks (together with their associated CRF pages) to be copied into a new study. If there are no changes to the standard checks or pages then reference can be made back to the original set of test data in a standards study, thus reducing the study level overhead.
  3. The fact that many of the required checks (missing data, range checks, partial dates etc.) do not require the programming of an edit check at all. Each of these and many others are already there as part of the question definition itself and therefore do not need any additional testing or documentation for each study.

If you have not documented, you have not done it-FDA

The “ideal world” scenario would be to reduce the actual edit check testing by the system generating a more “human readable” format of the edit checks. The testers that way would not have to test each boundary conditions of the edit checks once the system is validated. All they would have to do is inspect the “human readable” edit checks vs the alerts and would also be easy for the clients to read and sign off.

You can leverage the EDC systems audit trail under certain conditions. First of all – the system you are testing with must be validated in itself. Some EDC products are only ‘validated’ once a study is built on top of them – they are effectively further developed as part of a study implementation process – in this situation, I would doubt you could safely use the audit trail.

Secondly, you need to come up with a mechanism whereby you can assure that each edit check has been specifically tested – traceability.

Finally, you need to secure the test evidence. The test data inside the EDC tool must be retained for as long as the archive as part of the evidence of testing.

The worst methods in my view are paper / screenshot based. They take too long, and are largely non-reusable. My past experience has been creating test cases using MS Word then performing each step as per test case and take a screenshot, where indicated. Then attached to the final documentation and validation summary. This obviously a manual and tedious process. Some companies create test cases using HPQC or similar tool. This is a bit more automated and traceable yet, it is still prone for errors. It is better than documenting using MS Word or Excel but it is still a manual process.

Re-usability is what it is all about, but, you need to ensure you have methods for assuring the test evidence produced for edit checks you are reusing is usable as part of the re-use exercise.

Edit Check Design, Development and Testing is the largest part of any typical EDC implementation. Applying methods to maximize quality and minimize time spent is one of the areas I have spent considerable time on over the last couple of years.

For additional tips on writing effective edit checks please go here -Effective edit checks eCRFs.

To hire me for services, you may contact me via Contact Me OR Join me on LinkedIn

Source images: provided courtesy of Google images.

-FAIR USE-
“Copyright Disclaimer Under Section 107 of the Copyright Act 1976, allowance is made for “fair use” for purposes such as criticism, comment, news reporting, teaching, scholarship, and research. Fair use is a use permitted by copyright statute that might otherwise be infringing. Non-profit, educational or personal use tips the balance in favor of fair use.”

Are you Practicing GCP?

You probably heard news or stories such as Misconduct Delayed Drug Approval or Duke Settles Negligence Suit.

The Good Clinical Practice (GCP) is an international ethical and scientific quality standard for designing, conducting, recording and reporting trials that involve the participation of human subjects. Compliance with this standard provides public assurance 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.

The first is to ensure the protection of the patient. The subject’s consent should have been obtained before any study procedure were performed. Each subject is monitor to ensure accuracy and completeness of the data generated.  If an SAE occurred, the monitor will confirm that the SAE has been reported promptly and completely.

The objective of the ICH GCP Guideline is to provide a unified standard practice for the United States, Japan and the European Union (EU) to facilitate the mutual acceptance of clinical data by the regulatory authorities in these jurisdictions.

So what are the essential documents during the conduct of a clinical trial?

1- Investigator Brochure documents relevant and current scientific information around the investigation product (IP) has been provided to the investigator.

2- Signed Protocol (including Amendments) and Case Report Forms (CRF) document investigator and sponsor agreements.

3- Informed Consent Form documents the information given to trial subjects.

4- Financial Aspects of the trial documents the financial agreement between the investigator/institution and the sponsor / research for the trial.

5- Signed agreement between involved parties. For example, sponsor and CRO.

6- Institutional Review Board (IRB) / Ethics committee (IEC) documents the trial has been subject to IRB/IEC review and given approval opinion. For example this includes but not limited to protocol and any amendments, CRF (if applicable), informed consent form, subject compensation.

7- Regulatory authority(ies) approval/notification of protocol documents approval/notification by the regulatory authority compliance with the applicable regulatory requirements(s).

8- Curriculum Vitae and/or other relevant document evidencing qualifications of investigator and sub-investigator as document eligibility to conduct trial and/or provide medical supervision of subjects.

9- Normal value(s)/range(s) for medical / laboratory technical procedures documents normal values of the tests.

10- Sample of label(s) attached to investigational product containers document compliance with applicable labeling regulations and appropriateness of instructions to the subjects.

11- Decoding procedures for blinded trials documents how, in case of an emergency, identify of blinded investigational product without breaking the blind for remaining subject’s treatment.

12- Master randomization list documents method for randomization of trial population.

13- Pre-trial monitoring report documents the site is suitable for the trial.

Note: Any or all documents listed in this guidelines may be subject to, and should be available for audit by the sponsor’s auditor and inspection by the regulatory authority(ies). Any revision to any of the above documents should be added to the files during the trial as evidence.

After completion of a trial, some other documents such as completed subject identification code list, audit certificate, clinical study report and final trial close-out monitoring report shall be available to document completion of the trial.

Research and practice may be carried on together when research is designed to evaluate the safety and efficacy of a therapy. Basic Ethical principles refers to those general judgements that serve as a basic justification for the many particular ethical evaluation of human actions. Respect for persons where persons are treated in an ethical manner not only by respecting their decisions and protecting them from harm, but also by making efforts to secure their well being.

Do not harm – hippocratic maxim

 Who ought to receive the benefits of research and bear its burdens?

An injustice occurs when some benefit to which a person is entitled to or when ought to be treated equally. This principle applies to the rights, safety and well-being of the trial subjects with most considerations and should prevail over interests of science and society.

Conducting clinical trials, in accordance with this principles of good clinical practice (GCP), makes it possible to test the effectiveness and safety of medicines, hence, it is important the understand the principles established in the guidelines.

Source:

http://www.ich.org/home.html and http://www.the-scientist.com/

Anayansi is an EDC Developer Consultant and clinical programmer for the Pharmaceutical and Biotech industry with more than 13 years of experience.

Available for short-term contracts or ad-hoc requests. See my specialties section (Oracle, SQL Server, EDC Inform, EDC Rave, OpenClinica, SAS and other CDM tools)

Fair Use Notice: This blog/article/video contains some copyrighted material whose use has not been authorized by the copyright owners. We believe that this not-for-profit, educational, and/or criticism or commentary use on the Web constitutes a fair use of the copyrighted material (as provided for in section 107 of the US Copyright Law).

If you wish to use this copyrighted material for purposes that go beyond fair use, you must obtain permission from the copyright owner. Fair Use notwithstanding we will immediately comply with any copyright owner who wants their material removed or modified, wants us to link to their website or wants us to add their photo.

Disclaimer: The EDC Developer blog is “one man’s opinion”. Anything that is said on the report is either opinion, criticism, information or commentary. If making any type of investment or legal decision it would be wise to contact or consult a professional before making that decision.

Disclaimer: The legal entity on this blog is registered as Doing Business As (DBA) – Trade Name – Fictitious Name – Assumed Name as “GAMBOA”.

Good Documentation Practice (GDP) for the EDC / SAS Developer

When writing programming codes for either validating the software or for validation checks, we often have to write comments to explain why we did something.

Since the FDA regulates computerized systems used in clinical trials under the authority of Title 21 the Code of Federal Regulations Part 11 (21 CFR Part 11) – see my other article about 21 CFR Part 11 here, we need to make sure our codes and programs are documented. As you have heard before, if it is not documented, it never happened. Nevertheless, there is no mandatory regulatory agency mandating to have to do this.

GDP is an expected practice”

So how much documentation is needed? We could get into endless discussions of when we should comment, what we should comment, and how much we should comment. I have had plenty of discussions about comments with people with various opinions on the subject.

Here’s a good documentation practice for a SAS code:

The program header was written to validate Clintrial (Oracle).

  • Program name, version, programmer and purpose.
  • Modifications
  • Risk Assessments

The second section contains information about the

  • quality testing, user testing
  • Macros, global variables and any other code that is reusable.

The document must tell the entire story about your program and must be readable by internal or external staff. Two other important things to remember, your program must be accurate “error free” and each section of your program must be traceable, such as who updated it, what and why.

Most companies have SOPs that requires you to record certain information. But do we understand what it is we are recording? or when it was recorded?

Standardized Documentation is KEY”

Do you have a preference? Tell me about it in the comments!

To hire me for services, you may contact me via Contact Me OR Join me on LinkedIn

Anayansi Gamboa has an extensive background in clinical data management as well as experience with different EDC systems including Oracle InForm, InForm Architect, Central Designer, CIS, Clintrial, Medidata Rave, Central Coding, OpenClinica Open Source and Oracle Clinical.

Fault Lines – Outsourced: Clinical trials overseas

This video shows why good clinical practice is very important in the pharmaceutical industry.

FAIR USE-
“Copyright Disclaimer Under Section 107 of the Copyright Act 1976, allowance is made for “fair use” for purposes such as criticism, comment, news reporting, teaching, scholarship, and research. Fair use is a use permitted by copyright statute that might otherwise be infringing. Non-profit, educational or personal use tips the balance in favor of fair use.”