Title: The Education and Compliance Office for Human Subject Research ECOHSR
1The Education and Compliance Office for Human
Subject Research (ECO-HSR)
- Guidelines to Good Research Practices
- http//www.rcco.pitt.edu/educ/
2Organizational Chart for the Research Conduct
Compliance Office (RCCO)
3ECO Staff
- Kelly Dornin-Koss, MPPM, RN, CCRC
- Patricia Erb, RN, BSN, CIP
- Cindy Kern, RN, CCRC
- Nancy Nagel, RN, BSN, CCRC
http//graphicfreebies.com/fall2.html
4- Mission Statement
-
- To provide education to individuals involved in
clinical research at the University of Pittsburgh
and to strive for research excellence and
integrity throughout the University.
5- The ECO has performed nearly 300 audits to date
- The ECO has reviewed over 3,600 research records
for the presence of consent forms
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7Good Research Practices Taken From
-
- The Reference Manual for Use of Human Subjects in
Research (http//www.irb.pitt.edu/) -
- The Federal Policy Regulations (CFR 45 Part 46
http//www.hhs.gov/ohrp/humansubjects/guidance/45c
fr46.htm ) -
- The FDA Regulations (CFR 21 Parts 50, 56 and 312
) http//www.accessdata.fda.gov/scripts/cdrh/cfdoc
s/cfcfr/cfrsearch.cfm and - The International Conference of Harmonization -
Good Clinical Practices http//www.fda.gov/cder/gu
idance/959fnl.pdf . - Observed practices in the research community
8- Patricia Erb, RN, BSN, CIP
9PROTOCOL ADHERENCE AND OVERSIGHT
- Get ready
- Get set
- Go
- Done, at last
10GET READY
- RPF modules and training
- E
- A
- D
- Y
11GET READY
- RPF modules, training
- Equipment, facilities, supplies
- A
- D
- Y
12GET READY
- RPF modules, training
- Equipment, facilities, supplies
- Approvals
- D
- Y
13GET READY
- RPF modules, training
- Equipment, facilities, supplies
- Approvals
- DSMP-who, what, when
- Y
14GET READY
- RPF modules
- Equipment
- Approvals
- DSMP
- Yes, its in the mail-samples shipped and/or
stored
15GET SET
- Standard Operating Procedures (SOPs)
- E
- T
16GET SET
- SOPs
- Education explain protocol and consent form,
equipment - T
17GET SET
- SOPs
- Education
- Trial records data collection forms (CRFs),
record storage, confidentiality, randomization
plan
18Good Oversight
- Ensure study is conducted per protocol
- Submit mods before implementing changes
- Maintain approvals
- Report AEs and unanticipated problems
- Maintain records, consent forms
- Ensure proper storage of samples
- Staff meetings
- DSMP meetings
- Communications with sponsor
19DONE
20DONE
- Documentation
- Out with drugs, devices
- N
- E
21DONE
- Documentation
- Out with drugs, devices
- Notify IRB, sponsor
- E
22DONE
- Documentation
- Out with drugs, devices
- Notify IRB, sponsor
- Extended storage
23- Nancy Nagel, RN, BSN, CCRC
24INFORMED CONSENT PROCESS
- C Communicate
- O
- N
- S
- E
- N
- T
25Communicate
- Informed Consent Document
- Vs.
- Informed Consent Process
26Communicate
- Who introduces the study?
- Who explains details of study?
- Who answers questions?
27Communicate
- The individuals implementing the informed consent
process must be authorized to do so as outlined
in the protocol. - If someone other than the investigator is
delegated to conduct the process, it must be
explained in the protocol and approved by the
IRB. - (See IRB Reference Manual, Chapter 8)
28Communicate (Continued)
- Be Creative..
- Visual aids - pill bottlesdevicesmodels
- Charts
- Diagrams
- Drawings
- Stack of questionnaires
- Anything to draw them in and make them listen
- Create a dialogue.not a monologue
29Communicate
- Evaluate
- Make some effort to evaluate the subjects
comprehension. For example - Ask them to describe the purpose of the study
- Ask them to repeat some of the risks
- Ask them how long their participation will last
- Ask them who they would call with a problem
30INFORMED CONSENT PROCESS
- C Communicate
- O Obtain consent
- N
- S
- E
- N
- T
31Obtain Consent
- Be sure you are using the most current version of
the consent document - Check the approval date
- Check the renewal date
- Written consent must be provided by the subject
prior to ANY research activity
32INFORMED CONSENT PROCESS
- C Communicate
- O Obtain consent
- N Narrative note
- S
- E
- N
- T
33Narrative Note
- FDA requires documentation of informed consent
process. - Recommended for ALL studies as
- Good Clinical Practice and as backup
documentation if consent is LOST. -
34Narrative Note
- The consent form doesnt provide specifics of
the consent discussion or interaction. - Develop your own system.
- Example Form Included
- (Original concept developed by I. Macio of Magee
Womens Hospital. Generic form developed by N.
Nagel)
35IRB ____________ PI ________Subject ID
__________
Signature and Date of Investigator/Co-Investigator
(or IRB approved delegate) who administered the
consent process and completed this
form.Signature ______________ Date
______________ Time____________
36Narrative Note
- Include
- Who was present for the discussion
- All risks were presented
- All questions were answered
- Subject appears to understand
- Agrees to participate by signing
- Sign date time (especially if research
procedures will be performed on the same day
37INFORMED CONSENT PROCESS
- C Communicate
- O Obtain consent
- N Narrative note
- S Signatures
- E
- N
- T
38Signatures
- Subject
- (or Legally authorized representative)
- Person obtaining consent
- If the study involves a drug, device or
surgical - procedure..
- must be a listed investigator
- listed on first page of consent
- MUST be an M.D.
- (Exceptions See Reference Manual,
Chapter 8)
39Signatures
- If the study does NOT involve a drug, device
or surgical procedure, and is considered to be
MINIMAL RISK, members of the research team may be
delegated the task of educating the subject and
obtaining consent. - INCLUDE A DESCRIPTION IN PROTOCOL
40Signatures
- Retention of consent document..
- Principal investigator must retain ORIGINAL
- Copy in medical records if hospitalized
- Copy to subject
41INFORMED CONSENT PROCESS
- C Communicate
- O Obtain consent
- N Narrative note
- S Signatures
- E Emergency Contact
- N
- T
42Emergency Contact
- If a research study involves risk of physical
harm (or emotional distress leading to physical
harm, i.e., suicide), subjects must know what to
do and whom to contact. 24 hrs./7 days/wk. - Include contact information on first page of
consent - Subject should reach someone on the research team
within two phone calls
43INFORMED CONSENT PROCESS
- C Communicate
- O Obtain consent
- N Narrative note
- S Signatures
- E Emergency Contact
- N Notify IRB
- T
44Notify IRB
- If you discover any problems..
- No consent
- Lost or missing consent
- Incorrect consent
- DOCUMENT ALL FINDINGS AND CIRCUMSTANCES
- Call the IRB for guidance
45INFORMED CONSENT PROCESS
- C Communicate
- O Obtain consent
- N Narrative note
- S Signatures
- E Emergency Contact
- N Notify IRB
- T Trust
46Trust
- Develop a relationship with your subjects so that
they trust you - You can trust them to be compliant with study
conduct - The IRB trusts that you will implement the
consent process and conduct the study as outlined
in your protocol and consent document
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50STUDY DOCUMENTATION
51Source Documents
- The International Conference on Harmonization
(ICH), the Code of Federal Regulations and Good
Clinical Practice require the following - Written, informed consent by all subjects prior
to the implementation of any study-related
procedures and - Accurate, complete and appropriate clinical
research documentation
52Source Documents
- Data collection tools should be developed and
completed to address all study activities.
53Source Documents
- The data collection tools should include
- Eligibility criteria presence of inclusion
criteria and absence of exclusion criteria - Screening
- Study procedures
- Drug/device dispensing
- Follow-up procedures
- Any and all contacts with the study participant
54Source Documents
- Supportive documentation should also be included
in the research subjects file, e.g. - Psychological assessment tools
- Bloodwork results
- X-ray, CT, MRI reports
- Electrocardiograms
- SCID (Structured Clinical Interview for DSM-IV)
testing
55- Source documents
- Tell the entire story
- U
- D
- Y
56Tell the entire story
- Narrative notes should also be generated to
document - How the subject tolerated the study procedures
- Any telephone calls or contacts with the subjects
- Missed visits or protocol deviations
- Adverse events or unanticipated problems
57- Study documents
- Tell the entire story
- Understand
- D
- Y
58Understand
- All subject-specific source documents should be
labeled with subject ID and date and should be
signed by the person completing the document - Separate research records should be maintained
- Never use white-out on study documents
59- Source documents
- Tell the entire story
- Understand
- Document
- Y
60Document
- DOCUMENT
- DOCUMENT
- DOCUMENT
61- Study documents
- Tell the entire story
- Understand
- Document
- Yield
62Yield
- Yield the best possible study results by
maintaining accurate and complete study
documentation.
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64Regulatory Binder/Files
- Reference
- E
- G
- U
- L
- A
- T
- O
- R
- Y
65Reference
- You should be able to easily reference all
vital study information.
66Reference
- Reference
- Explain
- G
- U
- L
- A
- T
- O
- R
- Y
67Explain
- It is acceptable to establish a central
departmental file for documentation that
pertains to all studies conducted within that
department. A cross-reference note should be
placed in the specific study regulatory file
noting the location of these documents.
68Explain
- For example, the central file may contain
- Investigator-staff
- CVs
- Licenses
- Certificates
- Staff training records
69- Reference
- Explain
- Groundwork
- U
- L
- A
- T
- O
- R
- Y
70Groundwork
- Before the study starts, organize all of the
study documentation in a binder or file.
71SITE PERSONNEL SIGNATURES DELEGATED
RESPONSIBILITIES Investigator ___________________
_______ Project _________________________ Study
Site __________________________ Sponsor
________________________
72- Reference
- Explain
- Groundwork
- Unimportant
- L
- A
- T
- O
- R
- Y
73Unimportant
- No matter how unimportant a study document seems
to you, dont discard it. - E.g., shipping or mailing labels
74- Reference
- Explain
- Groundwork
- Unimportant
- Laboratory
- A
- T
- O
- R
- Y
75Laboratory
- If applicable, laboratory certifications and
ranges of normal laboratory values should be
maintained in the regulatory files.
76- Reference
- Explain
- Groundwork
- Unimportant
- Laboratory
- Adverse Event Reports
- T
- O
- R
- Y
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78Adverse Event Reports
- All adverse event reports should be sent to
the appropriate agencies and copies should be
maintained in the regulatory files.
79- Reference
- Explain
- Groundwork
- Unimportant
- Laboratory
- Adverse Event Reports
- Telephone conversations, emails
- O
- R
- Y
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81Telephone conversations, emails
- Document all telephone conversations with the
sponsor or regulatory agency. These should be
maintained in the regulatory files and should
include - Date and time
- Who initiated the call
- Topic of discussion
- Resolution
82TELEPHONE COMMUNICATIONS LOG Investigator
__________________________ Project
___________________________ Study Site
_________________________ Sponsor
___________________________
- Record chronologically all contacts with sponsor
- Sign and date each entry
83Telephone conversations, emails
- Also, print and file all relevant e-mail
correspondence regarding the study in the
regulatory files.
84- Reference
- Explain
- Groundwork
- Unimportant
- Laboratory
- Adverse Event
- Telephone conversations, emails
- Organization
- R
- Y
85Organization
- It is best to organize the regulatory files in
chronological order. This will make it easier
for you to locate information when you need it.
86- Reference
- Explain
- Groundwork
- Unimportant
- Laboratory
- Adverse Event Reports
- Telephone conversations, emails
- Organization
- Reproach
- Y
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88Reproach
- If you keep your regulatory files organized you
will be above reproach.
89- Reference
- Explain
- Groundwork
- Unimportant
- Laboratory
- Adverse Event Reports
- Telephone conversations, emails
- Organization
- Reproach
- Your work
90Your work
- Your study files reflect your work. Let them
speak highly of you.
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92Test Article Accountability
93Tell
- The Investigational Drug Service must be
notified of all research protocols wherein the
research involves the administration of an
investigational new drug or an approved drug.
94- Send the following items to the Investigational
Drug Service - The research protocol
- The informed consent document
- The Investigators Brochure
- Fiscal review
- UPMC IDS Questions - 647- 4958
- Magee Pharmacy Questions 641-6626
- Shirley Podnar
95 96Elaborate
- The principal investigator/coordinator should
maintain an inventory log for the test article.
This responsibility may be performed by IDS.
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98 99Sign
- There should be a signed physicians order for
every test article dispensed.
100- Tell
- Elaborate
- Sign
- Thorough
101Thorough
- The investigator should ensure that periodic
inventories of the test article are performed.
Each test article must be accounted for and any
discrepancies reconciled.
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104References
- MB Ott, GL Yingling. Guide to Good Clinical
Practice. Thomas Publishing Group, Washington,
DC, 2000. - International Conference on Harmonisation
Guidelines http//www.ifpma.org/ich5.html - FDA regulations 21 CFR 312.62, 600.12, 812.14
- Deborrah Norris. Clinical Research Coordinator
Handbook. Plexus Publishing - Photos from Webshots.com, Allposters.com,
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