Title: Audience Question
1Audience Question
Replace content of Slide 25
- Study Coordinators and research assistants
change over time, so if you have an IND and
ongoing study, are you supposed to inform the FDA
that your study coordinator is a different
person or if you have a new research assistant?
2Review Warning Letter (WL) Cases
Place between slides 37 and 38
- Instructions
- Click Stop Button under video window
- Read all 3 Warning Letters (Click each name)
- Mitchell Creinin
- Michael Gruber
- Alkis Togias
- Match statements in WLs with SMALL PRINT issues
- e.g. failed to retainrecords R (Retain
records) - Restart video by clicking under video
window
3Speaker Dr Mitchell Creinin, what were the
SMALL PRINT issues for him?
- Audience Discussion
- Maintain Records (M)
- Adhere to Protocol (A)
- Inform Subjects (I)
- Notify IRB (N)
- Report Adverse Events (P)
Replace content of slide 38
4Speaker Dr. Michael Gruber, what were the
problems with his study?
- Audience Discussion
- Maintain Records (M)
- Lack of source data
- Supervise (S)
- Investigator as team leader in charge of study
- Adhere to Protocol (A)
- Retain Records (R)
Replace content of slide 40
5Speaker Dr. Togias, what were the 2 most
significant issues?
- Audience Discussion
- He did not file an IND.
- Drug crossed state lines and was administered
without FDA approval of IND. - A normal healthy volunteer died.
Replace content of slide 42
6Speaker Other findings with Dr. Togias?
- Audience Discussion
- Adhere to Protocol (A)
- Inadequate protocol
- Change protocol on a whim
- Notify IRB (N)
- Report Adverse Events (P)
- Learn IB (L)
- No animal data
- Maintain and Retain Records (M) (R)
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7Read OHRP Determination Letters
Place between slides 48 and 49
- Instructions
- Click Stop Button under video window
- Click each date for letter
- Jul 19, 2001 (MPA Suspension)
- Jul 23, 2001 (MPA Reinstatement)
- Oct 03, 2001 (1st Monthly Report)
- Aug 23, 2002 (Followup inspection)
- Restart video by clicking under video
window
8Speaker Who can tell me what OHRP stands for?
- Audience Answer
- Office of Human Research Protection
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9Review Determination LetterCase 1 John Hopkins
University
Place between slides 58 and 59
- Instructions
- Click Stop Button under video window
- Click Date for letter
- Dec 14, 2001 (Dr. Rolley E. Johnson)
- Restart video by clicking under video
window
10Speaker introduces Case 1
Replace Slides 60 and 61
11Review Determination LetterCase 2 Thomas
Jefferson University
Place between slides 61 and 62
- Instructions
- Click Stop Button under video window
- Click Date for letter
- Dec 11, 2001 (Dr. David W. Andrews)
- Restart video by clicking under video
window
12Speaker introduces Case 2
Replace Slides 63 and 64
13Review Determination Letter Case 3
Massachusetts General Hospital
Place between slides 65 and 66
- Instructions
- Click Stop Button under video window
- Click Date for letter
- Apr 03, 2002 (Dr. John Growden)
- Restart video by clicking under video
window
14Speaker introduces Case 3
Replace Slides 67 and 68
15Review Determination LetterCase 4 John Hopkins
University
Place between slides 68 and 69
- Instructions
- Click Stop Button under video window
- Click Date for letter
- Aug 19, 2002 (Dr. Mark Farfel)
- Restart video by clicking under video
window
16Speaker introduces Case 4
Replace Slide 70
17Summary Determination Letters
Include as Slide 73
- Not always determinations of non-compliance.
- Of interest in terms of current OHRP
interpretations -- recognizing that you are
getting only one side of the story - Actions/corrective actions taken by the
institutions although the institution may
require actions by the investigator.
18Summary Warning Letter (WL) versus Determination
Letter (DL)
Include as Slide 74
- Source
- WL FDA
- DL OHRP
- Target Audience
- WL e.g., Investigators, IRBs, not Institution
level - DL Institution, not Investigator, IRB levels
- Cause
- WL FDA Inspection noting serious compliance
problems - DL Various reports including institution self
reports - Issuance and Inspections
- WL Always issued post FDA site inspection
- DL Usually issued pre OHRP site inspection, if
any