APEC GCP Inspection Workshop May 29, 2008

Transcription

1 Common Investigator Deficiencies Jean Toth-Allen, Ph.D. APEC GCP Inspection Workshop May 29, 2008 Most Common CI Deficiencies Failure to follow the investigational plan Protocol deviations Inadequate recordkeeping Inadequate accountability for the investigational product Inadequate subject protection including informed consent issues 1

2 CI Deficiencies CDER Inspections - FY % 40% 24% 31% 27% 35% 30% 25% 20% Protocol Record *Based on Letter Date 10% 10% 11% 6% Drug Acct Consent 8% 3% AEs 15% 10% 5% 0% Foreign n = 104* Domestic n = 244* Foreign Domestic 2/28/08 CDER CI Deficiencies FY % 40% 30% 20% 10% Protocol Records Consent Drug Acct AEs 0% N =

3 Device CI Deficiencies Fiscal Years Failure to follow investigational plan/regs Protocol deviations Inadequate subject protection/ic Inadequate device accountability Lack of FDA &/or IRB approval 46% 47% 44% 44% 51% 54% 8% 26% 40% 20% 38% 16% 19% 21% 28% 21% 21% 24% 17% 21% 27% 26% 18% 14% 9% 11% 5% 8% 13% 13% 50% 44% 9% 22% 29% 20% 7% 15% 10% 7% FDA and TURBO Computerized system for recording observations (FDA Form 483) and preparing establishment inspection reports (EIRs) Initiated in early 2000s Presently used for most GCP inspections 3

4 TURBO: Purposes -1- To aid the investigator in preparing and electronically storing FDA 483s and EIRs To improve the quality of the FDA 483 by linking citations to underlying regulations and statutes To streamline and enhance uniformity, appearance, and fitness for use of the EIR TURBO: Purposes -2- To allow on-line access to inspectional findings from throughout FDA To streamline FDA s process for making 483s and EIRs publicly available To allow for easier capture and analysis of data on specific types of violations 4

5 Restricting Inspection Drugs Failure to permit an authorized officer or employee of FDA to [have access to] [copy] [verify] records or reports. Specifically, *** Devices Authorized FDA employees were not permitted to enter and inspect an establishment where records of results from use of devices are kept. Specifically, *** Authorized FDA employees were not permitted to [inspect] [copy] all records relating to an investigation. Specifically, *** CI Agreement Drugs An investigation was not conducted in accordance with the [signed statement of investigator] [investigational plan]. Specifically*** Broad use for non-compliance with/deviation from general investigational plan which includes the study protocol 5

6 CI Agreement Devices An investigation was not conducted according to the [signed agreement] [investigational plan] [applicable FDA regulations]. Specifically, *** CI Oversight Drugs A study drug was [administered to subjects] [provided to persons] not under the investigator's personal supervision or under the supervision of a subinvestigator responsible to the investigator. Specifically, *** Devices An investigational device was used for subjects not under the supervision of an authorized investigator. Specifically, *** 6

7 IEC Approval Drugs Failure to assure that an IRB [complying with applicable regulatory requirements] was responsible for the initial and continuing review and approval of a clinical study. Specifically, *** Devices Subjects were allowed to participate in an investigation prior to obtaining [IRB] [FDA] approval to conduct the investigation. Specifically, *** Progress Reports Drugs Not all investigational progress reports were furnished to the drug study sponsor. Specifically, *** Devices Progress reports on the investigation were not submitted [at the required intervals] [at least yearly] to the [sponsor] [monitor] [reviewing IRB]. Specifically, *** 7

8 Informed Consent - Drugs Failure to obtain informed consent in accordance with 21 CFR Part 50 from each human subject prior to [drug administration] [conducting study-related tests]. Specifically*** 21 CFR Part 50 FDA s regulation regarding informed consent Informed Consent - Devices Written informed consent of potential subjects to participate in an investigation was obtained prior to obtaining [IRB] [FDA] approval to conduct the investigation. Specifically, *** Records documenting that informed consent was obtained for each subject prior to participation in the study are not all [accurate] [complete] [current]. Specifically, *** 8

9 Safety Reports - Drugs Failure to report [promptly] to the sponsor adverse effects that may reasonably be regarded as caused by, or probably caused by, an investigational drug. Specifically, *** Safety Reports - Devices A complete and accurate report of an unanticipated adverse device effect was not prepared and submitted [within 10 working days after first learning of the effect] to [the sponsor] [the reviewing IRB]. Specifically, *** 9

10 Case Histories Drugs Failure to prepare or maintain [adequate] [accurate] case histories with respect to [observations and data pertinent to the investigation] [informed consent]. Specifically, *** Devices Records of each subject's [case history] [exposure to the investigational device] are not all [accurate] [complete] [current]. Specifically, *** Investigational Product Control Drugs Investigational drug disposition records are not adequate with respect to [dates] [quantity] [use by subjects]. Specifically, *** Unused supplies of an investigational drug were not [returned to the sponsor] [disposed of in accordance with sponsor instructions]. Specifically, *** 10

11 Investigational Product Control Devices Devices under investigation were not properly controlled. Specifically, *** An investigational device was supplied to a person not authorized to receive it. Specifically, *** Records of [receipt] [use] [disposal] of a device that relate to the [type and quantity] [dates of receipt] [batch number or code mark] of the device are not all [accurate] [complete] [current]. Specifically, *** The remaining supply of investigational devices was not disposed of as the sponsor directed upon [completion] [termination] of a clinical investigation or part thereof. Specifically, *** Labeling Drugs Investigational drug (label) (labeling) [bears a statement that is false or misleading] [represents that the investigational drug is safe or effective for the purposes for which it is being investigated.] Specifically, *** 11

12 Record Retention - Drugs Investigational records were not retained for a period of two years following [approval of a drug's marketing application] [discontinuance of the investigation and notification of FDA]. Specifically, *** Record Retention - Devices Required records were not all maintained [during the investigation] [for a period of two years after the date on which an investigation was terminated or completed] [for a period of two years after the date that the records were no longer required for purposes of supporting a premarket approval application or a notice of completion of a product development protocol]. Specifically, *** 12

13 Labeling Devices The labeling for an investigational device bears a statement that is [false] [misleading]. Specifically, *** The labeling for an investigational device misrepresents that the device is [safe] [effective] for the purposes for which it is being investigated. Specifically, *** Other Drugs Representations were made in a promotional context that the investigational drug is [safe] [effective] for the purposes for which it is under investigation. Specifically, *** The investigational new drug was [commercially distributed] [test marketed]. Specifically, *** Charges were made for the investigational drug without the prior written approval of FDA. Specifically, *** 13

14 Other Devices An investigational device was [promoted] [test marketed] prior to FDA approval/clearance. Specifically, *** An investigational device was commercialized by charging the [subjects] [investigators] a price larger than that necessary to recover costs of manufacture, research, development, and handling. Specifically, *** 14

15 Disclaimer : The information within this presentation is based on the presenter's expertise and experience, and represents the views of the presenter for the purposes of a training workshop.