The Duty for Sponor Oversight in Clinical Trials: Practical Guide: 2nd Edition Clinical Data Review
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About this ebook
Doris Breiner
Doris Breiner, MSc Consultant Clinical Research works since 2005 in the field of clinical research. In the meantime the focus was set on the quality aspects to ensure robust and reliable data to ensure the alignment with the regulatory requirements with regards to the data integrity.
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The Duty for Sponor Oversight in Clinical Trials - Doris Breiner
The Duty for Sponor Oversight in Clinical Trials
The Duty for Sponor Oversight in Clinical Trials
Preamble
Table of Content
1. Introduction
2. Underlying Rationale and Assumptions to the Approach
3. Definition of the Clinical Data Review
4. Clinical Data Review Details
5. Risk Score Calculation
6. Safety Management and Reporting Review as well as Clinical Data Coding Review (ICH-GCP 5.16, 5.17)
7. Quality Control
8. Sponsor Oversight Plan – Cross References
9. Conclusion
References
List of Tables
Abbreviations
Copyright
The Duty for Sponor Oversight in Clinical Trials
Preamble: The first edition of the practical guide related to the topic „ The Duty for Sponsor Oversight in Clinical Research outlined the underlying requirements as well as possible approaches to implement it efficiently in small and mid-sized companies. This was based on a master's thesis released in April 2019. The next edition will focus on the „ Clinical Data Review
which includes all aspects to be considered, for example, the outcome of the overall monitoring oversight activities. Furthermore, to describe and show examples of a standardized score assignment to ensure a unique process of the assessment. In addition to that, the derived value could be considered and taken into account for the overall Good Clinical Practice (GCP) clinical trial compliance, concerning the „Clinical Data Review. As shown in the first edition the aim was to connect the activities with the corresponding items of the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH-GCP) related to this topic. However, the existing guidances outline the requirements on what is expected to be submitted to the authorities for further judgement. The kind of approach is more or less as presented and discussed in the 1st edition up to the responsible sponsor. That means the underlying rationale for the presented approach refers to the requirements, discussions around the definition and content of the „Clinical Data Review
interpretation by experts and quality assurance of any kind of business, even the information technology (IT). Finally, the defined goal was to enhance with that procedure the quality of the data set required for AMNOG and/or fast-track approval. Also, any changes related to the topic as such induced e.g. by new EU-Trials Regulation 536/2014 which became effective in 2022 are considered. Also, any outcome of further discussions over time with regard to the 1st edition „The Duty for Sponsor Oversight in Clinical Trials" are summarised briefly below.
Outcome of further discussions over the time, with regard to the content of the 1st edition summarized briefly.
General aspect: Additional information for the relevant factors related to the so-called „Data Integrity: technical equipement, used systems assessed as „Fit for purpose
, complexicity of the established processes, human ressource (responsible leadership, understanding, implementation)
The ALCOA Principle: in overall in the 1st edition the meaning behind that principle was pointed out. For consisteny purposes the acronym „ ALCO+Principles" (attributable, legible,contemporaneous, original or true copy, accurate) should always be mentioned.
Thank you for the discussions to the topic as such already started in 2017/2018 and as always any comments and crtitics are welcome to ensure the data sets presented to the public and authorities are realibale, acurate, and properly processed to ensure the ALCO + Principles and the data intergrity in the clinical research.
Berlin, 20-Dec-2022 Doris Breiner, MSc
Table of Content
1. Introduction
2. Underlying Rationale and Assumptions to the Approach
3. Definition of the Clinical Data Review
4. Clinical Data Review Details
5. Risk Score Calculation
6. Clinical Data and Coding Review
7. Quality Control
8. Sponsor Oversight Plan – Cross References
9. Conclusion
References
List of Tables
Abbreviations
1. Introduction
Access to the marketing authorization of new pharmaceutical or biotechnology compounds requires specified data. Also, the proper clinical data documentation from the phase 1 study onwards is mandatory. This 2nd edition of the practical guide does not focus on and does not include the requirements for the study of drug manufacturing or so-called Good Manufacturing Practice
(GMP), nor the requirements for the AMNOG in detail, as those are very specific. However, the quality aspects concerning the clinical data may contribute providing