(agathe guillot - gcp inspector, 14 july 2014) mhra view of responsible sponsorship
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(Agathe Guillot - GCP Inspector, 14 July 2014)
MHRA view of responsible Sponsorship
Content• Sponsor• Basis for Oversight• Investigator Oversight:
o Contracting/delegatingo Plans for oversighto Evidence of oversighto Retention of evidence
• Common findings• MHRA Expectations
Sponsor• An individual, a company, institution or organisation that takes
responsibility for the initiation, management, and/or financing of a clinical trial (Reg 3(1) of SI 2004/1031)
• Established in the EEA (or legal representative in EEA)
• Types of sponsor seen in the UK:o Commercial pharmaceutical companies,o Research councils,o Medical charities,o and Other non-commercial bodies (Trusts & Universities)
Oversight
• Watchful and responsible care• Supervision • Watchful management• Management of the performance or operation of a
person/group
Basis for oversightSponsor Responsibilities:
Global: Guidance ICH GCP E6 5.2.1, 5.2.2 and 5.2.4
EU: Directive 2005/28/EC article 7, EU Regulation 536/2014 Chapt 8
UK: Reg.3(12) of SI2006/1928
Quality Systems:
Global : Guidance ICH GCP E6 2.13, 5.1.1 and 5.2.1
EU: Directive 2005/28/EC article 2(4)
UK: Reg.28(2) of SI2006/1928, Schedule 1 part 2 (4) & (9)
Basis for oversight
Trial Master File:
Global : Guidance ICH GCP E6 2.10, 5.5.3, 5.5.4, 5.5.6,
5.5.11 and 8.1
EU: Directive 2005/28/EC articles 5 and 16 to 20
UK: Reg.31A of SI2006/1928, Schedule 1 part 2 (9)
Sponsor Oversight Summary
Trials
• Complexity of trials:o New technology, more specialised/niche vendorso More vendors within the trial to provide necessary expertiseo Involvement of CTUso Outsourced work (specialised labs, image analysis, CRF)
Co-sponsorship
• Reg.3(2) of SI2004/1031 – joint responsibility• No reference to contract information in the TMFs, as contracts are not
at a trial level • No evidence in the TMF of what aspects of the delegated “function” was
undertaken by each party • Although all staff were on the delegation log, it was not apparent from
any trial documents who were sponsor or co-sponsor staff especially if they have an honorary contract
• Training logs were incomplete, as these were split between the sponsor and co-sponsor, so not everything was available.
Delegation
Delegation
• Sponsor can delegate a task or role, but not the responsibility under the legislation
(Reg.3(12) of SI2006/1928)
• The sponsor/vendor relationship (delegation of whole departmental functions)o CTUs (Data management/statistics/project management)
Delegation Expectations
• Delegation of tasks must be in writing• Sufficiently detailed: who does what• Routinely reviewed throughout the trial lifecycle• Regular well-defined communication (documented
Reg.31A(4) of SI2006/1928)• Escalation process• Assessment program
Delegated Parties
• Examples include:o Investigatorso Clinical Trials Units (CTU)o Third parties e.g. laboratories
Common Issues
Sponsor and delegated parties (DP):• Sponsor or DP not undertaking their responsibilities• DP undertaking activities not formally delegated• Inadequate detail of the activities delegated • Partnership agreement for function not considered formal
delegation, so no clarity in trial documents that activities performed by vendor
• Responsibility of reporting of SUSARs to CA not clear
Oversight
Mechanisms for oversight• Monitoring (on site or remote) and audits• Review of monitoring reports & co-monitoring visits• Minuted meetings with study team • Review of progress reports (e.g.ASR/APR/Organisation Report)• Spot checks (processes and trial documents)• Documentation to support key decision making• Plan for review of vendors performance • Defined process for escalation and resolution of issues
Expectations
• Formal procedures for addressing oversight• Proactive & ‘up front’ determination of the levels of oversight
needed for a trial/project • Justified rationale for levels of oversight• Flexible oversight plans to permit changes
Risk assessment and oversight mitigation plan
Expectations
Then:• Documentation of what has been performed• Contemporaneous evidence of compliance • Retained in the TMF
Issues• Documentation to reconstruct appropriate oversight• No evidence of TMF issues addressed/closed when raised
by sponsor• No evidence of sponsor review of status reports• Informal meetings so not documented: attendance and
decisions unclear
Retention of documentation
• Oversight documentation: contemporaneously retained
• TMF = o individual to the organisation (index)o story of the trialo all documentation produced during the trial (what
happened and compliance with SOPs)
MHRA Expectations
• Follow current Regulations• Procedures in place and being followed• Follow protocol, follow randomisation procedure• Mechanism for non-compliances – appropriate
management of issues• Staff appropriately trained • Oversight of contracting or outsourcing
Contracting
Contracting
TMF/Documentation
Expectations
• Formal process: vendors identification and assessment • Mechanisms for assessment depending on GCP criticality• Assessment and decision documented• Retention – where/how is this referenced if not in the TMF
Common IssuesSponsors• No/inadequate assessment• Commitment prior to any
issues being resolved• Not considered trial data, so
not in TMF or referenced• No awareness of third party
outsourcing
Vendors• Unable to deliver to a
required standard
(e.g. laboratory being unable to comply with GCP)
Issues for sponsors to be aware of• Pressure on study team:
o timeo funding
• Academic qualifications:o CI, rotating registrars conducting different parts of the trial,
pressure to write up publication
Sponsorship responsibility
• Awareness of what is to be done• Clear who/what responsibility• Appropriate mechanisms to ensure oversight • Use of tools to manage risk:
o sponsor audits, visibility to trial team, presence of sponsor on project team/copied into minutes
• Management of data, close out and publication:o no review on outputs from trial, no process for publication
review despite claims of compliance
Summary
• Basis for sponsor oversight • Delegations and our expectations• Oversight and the various mechanisms that can be used• Contracting and our expectations • Sponsor responsibilities
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Questions ?
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