guidance for organizations performing in …...working document qas/15.622/rev.1 august 2015 draft...
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Working document QAS/15.622/Rev.1
August 2015
Draft document for comment
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GUIDANCE FOR ORGANIZATIONS PERFORMING IN VIVO 4
BIOEQUIVALENCE STUDIES 5
(August 2015) 6
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REVISED DRAFT FOR COMMENT 8
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© World Health Organization 2015 18
All rights reserved. 19
This draft is intended for a restricted audience only, i.e. the individuals and organizations having received this draft. The draft 20 may not be reviewed, abstracted, quoted, reproduced, transmitted, distributed, translated or adapted, in part or in whole, in 21 any form or by any means outside these individuals and organizations (including the organizations' concerned staff and 22 member organizations) without the permission of the World Health Organization. The draft should not be displayed on any 23 website. 24
Please send any request for permission to: 25
Dr Sabine Kopp, Group Lead, Medicines Quality Assurance, Technologies, Standards and Norms, Department of Essential 26 Medicines and Health Products, World Health Organization, CH-1211 Geneva 27, Switzerland. Fax: (41-22) 791 4730; 27 email: [email protected] 28
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The designations employed and the presentation of the material in this draft do not imply the expression of any opinion 30 whatsoever on the part of the World Health Organization concerning the legal status of any country, territory, city or area or 31 of its authorities, or concerning the delimitation of its frontiers or boundaries. Dotted lines on maps represent approximate 32 border lines for which there may not yet be full agreement. 33
The mention of specific companies or of certain manufacturers’ products does not imply that they are endorsed or 34 recommended by the World Health Organization in preference to others of a similar nature that are not mentioned. Errors 35 and omissions excepted, the names of proprietary products are distinguished by initial capital letters. 36 37 All reasonable precautions have been taken by the World Health Organization to verify the information contained in this 38 draft. However, the printed material is being distributed without warranty of any kind, either expressed or implied. The 39 responsibility for the interpretation and use of the material lies with the reader. In no event shall the World Health 40 Organization be liable for damages arising from its use. 41 42 This draft does not necessarily represent the decisions or the stated policy of the World Health Organization. 43
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Should you have any comments on the attached text, please send these to Dr S. Kopp, Dr S. Kopp,
Group Lead, Medicines Quality Assurance, Technologies, Standards and Norms ([email protected])
with a copy to Ms Marie Gaspard ([email protected]) by 1 October 2015.
Medicines Quality Assurance working documents will be sent out electronically only and will
also be placed on the Medicines website for comment under “Current projects”. If you do not
already receive our draft working documents please let us have your email address (to
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Working document QAS/15.622/Rev.1
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SCHEDULE FOR THE PROPOSED ADOPTION PROCESS OF DOCUMENT QAS/15.622 45
Rev.1: 46
GUIDANCE FOR ORGANIZATIONS PERFORMING IN VIVO BIOEQUIVALENCE 47
STUDIES. 48
PROPOSAL FOR REVISION 49
50
51 52
53
Presented to and discussed at the informal consultation on
inspection, GMP and risk management guidance in
medicines’ manufacturing
28–30 April 2014
Presentation of meeting recommendations to the forty-
ninth meeting of the WHO Expert Committee on
Specifications for Pharmaceutical Preparations
13–17 October 2014
Preparation of draft proposal for revision by Dr Olivier
Le Blaye, ANSM, France and Dr Stephanie Croft,
Prequalification Team (PQT)-Inspections, WHO
October 2014–April 2015
Review and discussion with inspectors and colleagues in PQT-Inspections
April–May 2015
Draft text mailed out for public consultation May 2015
Consolidation of comments received 25 June 2015
Discussion of feedback received during informal
consultation on data management, bioequivalence, GMP
and medicines’ inspection
29 June–1 July 2015
Preparation of revised working document by the authors
based on the feedback received during the public
consultation, the meeting and from the PQT-Inspections
July-August 2015
Circulation of revised working document for public
consultation
August 2015
Consolidation of comments received and review of
feedback
10 October 2015
Presentation to fiftieth meeting of the WHO Expert
Committee on Specifications for Pharmaceutical
Preparations
12–16 October 2015
Any other follow-up action as required …
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BACKGROUND 54 55
During an informal consultation held in 2014 and the forty-ninth meeting of the World Health 56
Organization (WHO) Expert Committee on Specifications for Pharmaceutical Preparations 57
discussion took place regarding the possible revision of the guidance for organizations 58
performing in vivo bioequivalence studies (WHO Technical Report Series, No. 937, Annex 59
9, 2006). 60
61
The WHO Expert Committee on Specifications for Pharmaceutical Preparations agreed that in 62
light of the new developments a draft for revision be prepared. 63
64
This guideline is being revised to take into consideration the revision for the multisource 65
guideline, as well as the creation of a new guideline on good data management. It will also be 66
revised to take into consideration the experience accumulated in the area of assessing and 67
inspecting bioequivalence (BE) studies since 2006. The areas with recurrent inspection 68
findings are being clarified and supplementary detail has been added in the area of 69
bioanalysis. It also includes an increased level of insistence on subject safety and data 70
integrity. 71
72
Based on the first working document: 73
http://www.who.int/medicines/areas/quality_safety/quality_assurance/BE-invivo-studies-guidance-74
QAS15-622_21052015.pdf?ua=1 this second version is suggested including the numerous 75
comments and feedback received from the public consultation, the PQT as well as the consultation 76
on data management, bioequivalence, GMP and medicines’ inspection held in 2015. 77
78
The PQT was started in 2001 to assure that medicinal products supplied for procurement meet WHO 79
norms and standards with respect to quality, safety and efficacy (http://www.who.int/prequal/). 80
Specifically it is a requirement that the submitted product dossier with all its necessary contents is 81
assessed and found acceptable, and that the manufacturing sites for the finished pharmaceutical 82
product (FPP), as well as the active pharmaceutical ingredient (API), are both inspected and found to 83
comply with WHO good manufacturing practices (GMP). Since products submitted to the PQT are 84
usually multisource ("generic") products, therapeutic equivalence is generally demonstrated by 85
performing a BE study, for example in a contract research organization (also known as a clinical 86
research organization) (CRO). For prequalification of such a product it is vital that, in addition to the 87
above-mentioned requirements, the CRO used by the sponsor for BE studies is compliant with 88
respect to WHO good clinical practices (GCP) and considers relevant elements from WHO good 89
laboratory practices (GLP) and good practices for quality control (QC) laboratories to ensure 90
integrity and traceability of data. In addition, if local legal provisions exist, CROs should be licensed 91
by the respective national medicines authority. Where required by national regulations, BE studies 92
should be authorized by the national regulatory authority. Those involved in the conduct and analysis 93
of BE studies with products to be submitted for prequalification therefore need to ensure that they 94
comply with the mentioned WHO norms and standards to be prepared for any inspections by WHO. 95
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100
Working document QAS/15.622/Rev.1
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Contents 101
page 102 Background 103 Introduction 3 104 1. Scope 4 105 2. Glossary 6 5 106 GENERAL SECTION 107 3. Organization and management 10 108 4. Computer systems 11 109
General 11 110 Hardware 11 111 Software 11 112 Networks 12 113 Data management 12 114
5. Quality management 13 115 6. Archive facilities 14 116 7. Premises 14 117 8. Personnel 16 118 CLINICAL SECTION 119 9. Clinical phase 17 120 10. Clinical laboratory 18 121 11. Ethics 18 122 11.1 Independent ethics committee 18 123 11.2 Informed consent 19 124 12. Monitoring 19 125 13. Investigators 20 126 14. Receiving, storage and handling of investigational drug products 20 127 15. Case report forms 23 128 16. Volunteers, recruitment methods 23 129 17. Food and fluids 24 130 18. Safety, adverse events, adverse event reporting 25 131 BIOANALYTICAL SECTION 132 19. Method development 25 133 20. Method validation 26 134 21. Sample collection, storage and handling of biological material 26 135 22. Analysis of study samples 27 136 23. Data processing and documentation 27 137 24. Good laboratory practices 28 138 PHARMACOKINETIC, STATISTICAL CALCULATIONS AND 139 REPORTING SECTION 140 25. Pharmacokinetic and statistical calculations 29 141 26. Study report 30 142 REFERENCES 30 143 Appendix 1. Examples of the list of standard operating procedures at a contract research 32 144 organization 145
146
INTRODUCTION 147 148
Multisource pharmaceutical products need to conform to the same standards of quality, 149
efficacy and safety as required of the originator's (comparator) product. Specifically, the 150
multisource product should be therapeutically equivalent and interchangeable with the 151
comparator product. Testing the BE between a product and a suitable comparator 152
Working document QAS/15.622/Rev.1
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(pharmaceutically equivalent or a pharmaceutical alternative) in a pharmacokinetic study with 153
a limited number of subjects is one way of demonstrating therapeutic equivalence without 154
having to perform a clinical trial involving many patients. In such a pharmacokinetic study 155
any statement about the safety and efficacy of the test product will be a prediction based on 156
measurement of systemic concentrations, assuming that essentially similar plasma 157
concentrations of the drug will result in essentially similar concentrations at the site of action 158
and therefore an essentially similar therapeutic outcome. The BE study thus provides indirect 159
evidence of the efficacy and safety of a multisource drug product. Often this will be the only 160
evidence that the product is safe and efficacious. It is therefore crucial that the BE study is 161
performed in an appropriate manner. Several guidance documents stress the importance of 162
onsite inspections to verify compliance with standards of GCP.i,4
163
164
1. SCOPE 165 166
The objective of this document is to provide guidance to organizations that are involved in the 167
conduct and analysis of in vivo BE studies. This guidance has been updated relative to the previous 168
version of this document. 169
170
BE studies should be performed in compliance with the general regulatory requirements and good 171
practices recommendations as specified in the WHO bioequivalence guideline1, GCP
2 and GLP
3 172
guidelines. It is acknowledged that GLP formally only apply to non-clinical safety studies. 173
However the WHO bioequivalence guidelines require that the validation of bioanalytical methods 174
and the analysis of BE study samples be performed following the principles of GLP. This does not 175
imply that the laboratory in charge of the bioanalytical part of the study should be monitored as part 176
of a national GLP compliance programme. 177
178
The text below lists general recommendations for organizations (including CROs and laboratories) 179
conducting BE studies and analysis of clinical trial samples. Recommendations for facilities and 180
equipment are listed in the respective paragraphs. Recommended documents, standard operating 181
procedures (SOP) and records are listed in Appendix 1, but this is not to be considered an 182
exhaustive list – others may be necessary depending on each individual CRO’s functional and 183
compliance needs. 184
185
This document provides information on: 186
187
‒ organization and management; 188
‒ study protocols; 189
‒ clinical phase of a study; 190
‒ bioanalytical phase of a study; 191
‒ pharmacokinetic and statistical analysis; 192
‒ study report; 193
‒ quality management system. 194
195
The present guideline targets organizations conducting BE studies and highlights certain important 196
aspects of the activities of such organizations. This document does not replace the above-mentioned 197
GCP or GLP guidelines, which are more complete. It is therefore not a stand-alone document. 198
199
200
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2. GLOSSARY1 201
202
The definitions given below apply to the terms used in this guidance. They may have different 203
meanings in other contexts. 204
205
adverse event. Any untoward medical occurrence in a clinical trial subject administered a 206
pharmaceutical product; it does not necessarily have a causal relationship with the treatment. 207
208
audit of a trial. A systematic examination, carried out independently of those directly 209
involved in the trial, to determine whether the conduct of a trial complies with the agreed protocol 210
and whether the data reported are consistent with the records on site, e.g. whether data reported or 211
recorded in the case-report forms are consonant with those found in hospital files and other original 212
records. 213
214
bioequivalence. Two pharmaceutical products are bioequivalent if they are 215
pharmaceutically equivalent or pharmaceutical alternatives, and their bioavailabilities, in terms of 216
rate (Cmax and tmax) and extent of absorption (area under the curve), after administration of the same 217
molar dose under the same conditions, are similar to such a degree that their effects can be expected 218
to be essentially the same. 219
220
calibration curve samples (or calibration standards).A matrix to which a known amount 221
of analyte has been added or spiked. Calibration standards are used to construct calibration curves. 222
223
case-report form. A document that is used to record data on each trial subject during the 224
course of the trial, as defined by the protocol. The data should be collected by procedures which 225
guarantee preservation, retention and retrieval of information and allow easy access for verification, 226
audit and inspection. 227
228
comparator product (or reference product). The comparator product is a pharmaceutical 229
product with which the multisource product is intended to be interchangeable in clinical practice. 230
The comparator product will normally be the innovator product for which efficacy, safety and 231
quality have been established. If the innovator product is no longer marketed in the jurisdiction, the 232
selection principle as described in Guidance on the selection of comparator pharmaceutical 233
products for equivalence assessment of interchangeable multisource (generic) products (WHO 234
Technical Report Series, No. 992, Annex 8, 2015) should be used to identify a suitable alternative 235
comparator product. 236
237
contract. A document, dated and signed by the investigator, institution and sponsor, that 238
sets out any agreements on financial matters and delegation/distribution of responsibilities. The 239
protocol may also serve as a contract when it contains such information and is signed. 240
Contracts can also be signed with other parties such as vendors supplying services to the contract 241
research organization. 242
243
contract research organization. A scientific organization (commercial, academic or other) 244
to which a sponsor may transfer some of its tasks and obligations. Any such transfer should be 245
defined in writing. 246
1 Unless otherwise stated, reproduced from Guidelines for WHO good clinical practice for trials on
pharmaceutical products. Geneva, World Health Organization. WHO Technical Report Series, No. 850, pp. 97–
137, 1995.
Working document QAS/15.622/Rev.1
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In the context of this guidance document bioequivalence studies are often contracted by the sponsor 247
to a contract research organization (CRO), which will perform some of the tasks of the sponsor, but 248
which will also perform the trial. The investigator (clinical part of the study) and the study director 249
(bioanalytical part of the study) are then employees of the CRO. 250
To facilitate reading, the term "CRO" is used throughout this document to designate any 251
organization performing the trial, even though it is acknowledged that part or all of the study may 252
be performed in-house by the sponsor itself or at a hospital. 253
254
ethics committee6.
An independent body (a review board or a committee, institutional, 255
regional or national), constituted of medical professionals and non-medical members, whose 256
responsibility is to verify that the safety, integrity and human rights of the subjects participating in 257
a particular trial are protected and to consider the general ethics of the trial, thereby providing 258
public reassurance. Ethics committees should be constituted and operated so that their tasks can be 259
executed free from bias and from any influence of those who are conducting the trial. 260
261
final report. A comprehensive description of the trial after its completion including a 262
description of experimental methods (including statistical methods) and materials, a presentation 263
and evaluation of the results, statistical analysis and a critical, ethical, statistical and clinical 264
appraisal. 265
266
good clinical practice. A standard for clinical studies which encompasses the design, 267
conduct, monitoring, termination, audit, analysis, reporting and documentation of the studies and 268
which ensures that the studies are scientifically and ethically sound and that the clinical properties 269
of the pharmaceutical product (diagnostic, therapeutic or prophylactic) under investigation are 270
properly documented. 271
272
good laboratory practice. A quality system concerned with the organizational process and 273
the conditions under which non-clinical health and environmental safety studies are planned, 274
performed, monitored, recorded, archived and reported. 275
276
informed consent. A subject’s voluntary confirmation of willingness to participate in a 277
particular trial and the documentation thereof. This consent should be sought only after all 278
appropriate information has been given about the trial including an explanation of its status as 279
research, its objectives, potential benefits, risks and inconveniences, alternative treatment that may 280
be available, and of the subject’s rights and responsibilities in accordance with the current revision 281
of the Declaration of Helsinki. 282
283
inspection. An officially-conducted examination (i.e. review of the conduct of the trial, 284
including quality assurance, personnel involved, any delegation of authority and audit) by relevant 285
authorities at the site of investigation and/or at the site of the sponsor in order to verify adherence to 286
good clinical practices and good laboratory practices as set out in this document. 287
288
internal standard. Test compound(s) (e.g. a structurally similar analogue or stable isotope 289
labelled compound) added to calibration standards, quality control samples and study samples at a 290
known and constant concentration to correct for experimental variability during sample preparation 291
and analysis. 292
293
investigational labelling. Labelling developed specifically for products involved in a 294
clinical trial. 295
296
Working document QAS/15.622/Rev.1
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investigational product (or study product). Any pharmaceutical product (see definition) 297
or placebo being tested or used as a reference in a clinical trial. 298
299
investigator. A person responsible for the trial and for the rights, health and welfare of the 300
subjects in the trial. The investigator should have qualifications and competence in accordance with 301
local laws and regulations as evidenced by an up-to-date curriculum vitae and other credentials. 302
Decisions relating to, and the provision of, medical or dental care must always be the responsibility 303
of a clinically competent person legally allowed to practise medicine or dentistry. 304
305
lower limit of quantification. The lower limit of quantification of an individual analytical 306
procedure is the lowest amount of analyte in a sample which can be quantitatively determined with 307
pre-defined precision and accuracy. 308
309
monitor. A person appointed by, and responsible to, the sponsor or contract research 310
organization for the monitoring and reporting of progress of the trial and for verification of data. 311
312
pharmaceutical product. Any substance or combination of substances which has a 313
therapeutic, prophylactic or diagnostic use, or is intended to modify physiological functions, and is 314
presented in a dosage form suitable for administration to humans. 315
316
principal investigator. The investigator serving as coordinator for certain kinds of clinical 317
trials, e.g. multicentre trials. 318
Note: "principle investigator" also has a specific, but different meaning in good laboratory 319
parctices, practically seldom used in bioequivalence studies. To avoid any misunderstanding, the 320
words "principal investigator" will only be used in this guidance document with their good clinical 321
practices meaning. 322
323
protocol. A document which states the background, rationale and objectives of the trial and 324
describes its design, methodology and organization, including statistical considerations, and the 325
conditions under which it is to be performed and managed. The protocol should be dated and 326
signed by the investigator, the institution involved and the sponsor. It can also function as a 327
contract. 328
329
quality assurance relating to clinical trials. Systems and quality control procedures that 330
are established to ensure that the trial is performed and the data are generated in compliance with 331
good clinical practices and good laboratory practices. These include procedures to be followed 332
which apply to ethical and professional conduct, standard operating procedures, reporting, and 333
professional qualifications or skills of personnel. 334
335
quality control samples. A spiked sample used to monitor the performance of a 336
bioanalytical method and to assess the integrity and validity of the results of the unknown samples 337
analysed in an individual batch. 338
339
raw data. All records or certified copies of original observations, clinical findings or other 340
activities in a clinical trial necessary for the reconstruction and evaluation of the trial. Such material 341
includes laboratory notes, memoranda, calculations and documents, as well as all records of data 342
from automated instruments or exact, verified copies, e.g. in the form of photocopies or 343
microfiches. Raw data can also include photographic negatives, microfilm, magnetic media (e.g. 344
computer diskettes) and optical media (CD-ROMs). 345
346
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serious adverse event. An event that is associated with death, admission to hospital, 347
prolongation of a hospital stay, persistent or significant disability or incapacity, or is otherwise life-348
threatening in connection with a clinical trial. 349
350
sponsor. An individual, a company, an institution or an organization which takes 351
responsibility for the initiation, management and/or financing of a clinical trial. When an 352
investigator initiates and takes full responsibility for a trial, the investigator then also assumes the 353
role of the sponsor. 354
355
standard operating procedures. Standard, detailed, written instructions for the 356
management of clinical trials. They provide a general framework enabling the efficient 357
implementation and performance of all the functions and activities for a particular trial as described 358
in this document. 359
360
study director. According to the Organisation for Economic Co-operation and 361
Development principles of good laboratory practice: the individual responsible for the overall 362
conduct of the nonclinical health and environmental safety study. In a bioequivalence study the 363
individual responsible for the conduct of the bioanalytical part of the study. 364
365
study product. see investigational product 366
367
test product. Any pharmaceutical product (see definition) or placebo being tested against 368
the reference in a clinical trial. 369
In a bioequivalence study the multisource product being tested against the comparator product. 370
371
trial subject. An individual who participates in a clinical trial, either as a recipient of the 372
pharmaceutical product under investigation or as a control. The individual may be: 373
‒ a healthy person who volunteers to participate in a trial; 374
‒ a person with a condition unrelated to the use of the investigational product; 375
‒ a person (usually a patient) whose condition is relevant to the use of the investigational 376
product. 377
378
upper limit of quantification. The upper limit of quantification of an individual analytical 379
procedure is the highest amount of analyte in a sample which can be quantitatively determined with 380
predefined precision and accuracy. 381
382
validation. Action of proving and documenting, in accordance with the principles of good 383
clinical practices and good laboratory practices, that any procedure, process, equipment (including 384
the software or hardware used), material, activity or system actually and consistently leads to the 385
expected results. 386
387
verification of data. The procedures carried out to ensure that the data contained in the 388
final report match original observations. These procedures may apply to raw data, data in case-389
report forms (in hard copy or electronic form), computer printouts and statistical analysis and 390
tables. 391
392
393
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GENERAL SECTION 394
395
3. ORGANIZATION AND MANAGEMENT 396 397
Note: the acronym “CRO” is used throughout this document to refer not only to a contract 398
research organization (CRO), but also to any organization involved in the conduct or analysis of in 399
vivo BE studies. 400
401
3.1 Where national requirements exist as to the legal status of a CRO these have to be complied 402
with. This also applies to the research unit which is a subsidiary of the manufacturer. 403
404
3.2 The CRO should have an organization chart reflecting key positions and the names of 405
responsible persons. The organization chart should be dated, authorized and kept up to date. 406
407
3.3 There should be job descriptions for all personnel, including a description of their 408
responsibilities. All job descriptions should be acknowledged and signed off by the staff member to 409
whom it applies. 410
411
3.4 There should be a list of signatures of authorized personnel participating in each study. 412
413
3.5 For the bioanalytical part of the trial, the principles of GLP clearly establish the 414
responsibilities of the test facility management. The CRO management should be aware that as the 415
investigator is an employee of the CRO, some of the responsibilities usually assigned to the 416
investigator would in a similar way reside with the CRO management. At a minimum, the CRO 417
management should: 418
‒ ensure that the principles of GCP and GLP, as appropriate, are complied with in the 419
CRO; 420
‒ ensure that a sufficient number of qualified personnel, appropriate facilities, 421
equipment and materials are available for the timely and proper conduct of the 422
study; 423
‒ ensure the maintenance of a record of the qualifications, training, experience and job 424
description for each professional and technical individual; 425
‒ ensure that personnel clearly understand the functions they are to perform and, 426
where necessary, provide training for these functions; 427
‒ ensure that appropriate and technically valid SOPs are established and followed, and 428
approve all original and revised SOPs. Ensure the maintenance of a historical file of 429
all SOPs; 430
‒ ensure that there is a quality assurance (QA) programme with designated personnel 431
and assure that the QA responsibility is being performed in accordance with the 432
principles of GLP and GCP, as appropriate; 433
‒ ensure that an individual is identified as responsible for the management of the 434
archive(s), and ensure that the documents transferred to the archives are kept under 435
adequate conditions for the appropriate duration; 436
‒ ensure that supplies meet requirements appropriate to their use in a study; 437
‒ establish procedures to ensure that computerized systems are suitable for their 438
intended purpose, and are validated, operated and maintained in accordance with the 439
principles of GCP and GLP, as appropriate. 440
441
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4. COMPUTER SYSTEMS 442 443
Note: this section highlights only some of the requirements for computer systems that are specific 444
to BE studies. Organizations involved in BE studies should ensure that the relevant principles of the 445
following guidelines are appropriately followed: 446
‒ GAMP 5: A risk-based approach to compliant GxP computerized systems4; 447
‒ Good Practices for Computerised Systems in Regulated “GXP” Environments, PIC/S 448
Guidance, Pharmaceutical Inspection Convention Pharmaceutical Inspection Co-operation 449
Scheme, PI 011-3, 25 September 20078; 450
‒ US FDA Code of Federal Regulations Part 119; 451
‒ EU guidelines to Good Manufacturing Practice and Medicinal Products for Human and 452
Veterinary Use Annex 11, Computerised systems10
; 453
‒ WHO Good data management practices guidelines7– [Note from the Secretariat: full 454
reference will be added once finalized]. 455 456 General 457
458
4.1 Computer systems should be qualified and validated (hardware, software, networks, data 459
storage systems and interfaces4,7,8,9,10
). Qualification is the planning, carrying out and recording of 460
tests on equipment and systems which form part of the validated process, to demonstrate that it will 461
perform as intended. 462
463
Hardware 464
465
4.2 There should be a sufficient number of computers to enable personnel to perform data entry 466
and data handling, required calculations and compiling of reports. 467
468
4.3 Computers should have sufficient capacity and memory for the intended use. 469
470
4.4 There should be access control to the trial-related information entered and stored in 471
computers. The method of access control should be specified (e.g. password protection) and a list 472
of people who have access to the database should be maintained. Secure and unique, individual-473
specific identifiers and passwords, should be used. 474
475
Software 476
477
4.5 The software programs used to perform key steps detailed in this guideline should be 478
suitable and validated for the intended use. Whether standard, off-the-shelf software is purchased or 479
whether bespoke software is developed, developer, vendor and/or service provider qualification 480
and/or validation certificates may be provided but it is the user’s responsibility to ensure that the 481
software is validated for its intended use. 482
483
4.6 As software, computer systems and related equipment can be technically complex, the user 484
should ensure that formal qualification and validation was carried out by the developer and that it 485
was developed in a controlled manner in accordance with a system of quality assurance. 486
487
4.7 Performance qualification should take account of the specific user’s requirements, of 488
regulatory/guideline requirements for BE studies, of the operating environment in which it will be 489
used, and of how it will be used by an organization’s staff in the context of a study. Quality risk 490
analysis should be applied when deciding which components need to be validated. All phases of 491
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their life cycle should be considered. For example, when a CRO decommissions the software in use 492
for high-performance liquid chromatography (HPLC) and mass spectrometric (MS) analysis (e.g. 493
HPLC-MS/MS), it should ensure that the data collected by the system using this software remains 494
fully readable. This could be done, for instance, by having the old software installed on a 495
workstation for inspection/verification purposes only. 496
497
4.8 There should be SOPs in place for usage of each software program that is used to perform 498
key steps of a BE study. 499
500
4.9 There should be a system in place for the implementation of regular updates to key software 501
programs (e.g. such as those used for control and data processing of chromatographic and mass 502
spectrometry systems) whenever required, following an appropriate risk assessment on the potential 503
impact that it could have on current data and on qualification/validation status. 504
505
4.10 Software programs used, frequency of virus testing, storage of data and the making and 506
archiving and keeping of back-ups should be specified in writing. 507
508
4.11 The programs used should be able to provide the required quality and management 509
information, reliably and accurately. Necessary programs for data management include word 510
processing, data entry, databases, graphics, pharmacokinetics and statistical programs. Self-511
designed software programs must be suitable and validated for their intended use. 512
513
4.12 Since data for BE studies is often transferred electronically between organizations 514
involved in the studies, there should be a verification that the software used between each 515
organization is compatible prior to commencing key study-related tasks. 516
517
4.13 These requirements apply to all systems used in clinical BE studies, e.g. subject database, 518
electronic case report forms, electrocardiogram (ECG) recording software, HPLC-MS/MS 519
software, software used for pharmacokinetic analysis, for statistical analysis, etc. 520
521
Networks 522
523
4.14 Networks, including the full client/server architecture and interfaces such as laboratory 524
information management systems, when used, should be appropriately designed, qualified, 525
managed and controlled. 526
527
4.15 Access to each component of the system by the different users at any given organization 528
involved in the studies, should be appropriately defined, controlled and documented. 529
530
4.16 There should be a documented inventory of all computerized systems on the network, with 531
a clear identification of those which are GxP regulated. Any changes to the network, including the 532
temporary addition or removal of systems from the network, should be documented. 533
534
Data management 535
536
4.17 Data entry includes transfer of the data from case report forms (CRF) and analytical data to 537
the computerized system for pharmacokinetic and statistical analysis and reporting. 538
539
4.18 Data entry procedures should be designed to prevent errors. The data entry process should 540
be specified in the SOP. 541
Working document QAS/15.622/Rev.1
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542
4.19 Double entry of the data should be performed. Data validation methodology (proof-reading, 543
double data entry, electronic logical control) should be specified in writing. 544
545
4.20 Changes made to data entered in the database should be made by authorized persons only. 546
Changes should be specified and documented. 547
548
4.21 Electronic data should be backed up at regular intervals. The reliability and 549
completeness of these back-ups should be verified – data should not be selected but 550
comprehensively backed up. 551
552
4.22 All of the raw electronic data must be kept. This includes: 553
– all meta data associated to a computerized system and the equipment that is associated to it 554
(which includes the audit trails for integration, for projects and for the entire instrument); 555
– validation data and meta data in the form of their source electronic files. 556
PDF copies are not sufficient on their own, unless it can be demonstrated that these are the 557
raw data and that no alteration was possible after they were generated. 558
559
4.23 All electronic records obtained from HPLC and MS analysis (e.g. HPLC-MS/MS) are 560
required to be retained, maintained and backed-up. It should be ensured that back-up data are 561
exact and complete and that they are secure from alteration, inadvertent erasures or loss shall 562
be maintained. The printed paper copy of the chromatogram would not be considered a “true, 563
exact and complete copy” of the entire electronic raw data used to create that chromatogram. 564
Printed chromatograms do not generally include, for example, the sample sequence, 565
instrument method, processing method, integration settings or the full audit trail, of which all 566
were used to create the chromatogram or are associated with its validity. Therefore there 567
should be a higher emphasis on conservation of electronic data than paper data, as paper data 568
is usually not considered the true source data, except in the case of paper logbooks where the 569
original record was handwritten, for instance. 570
571
4.24 If data is transformed during processing steps (such as in the example of re-integration 572
of chromatographic data), it should always be possible to compare the original data with the 573
processed data. 574 575 5. QUALITY MANAGEMENT 576 577
5.1 The CRO should have appropriate QA and QC systems with written SOPs to ensure that 578
trials are conducted and data are generated, documented and reported in compliance with the 579
protocol, GCP, GLP and the applicable regulatory requirements. 580
581
5.2 QA personnel should be independent of the work they are quality assuring, including: 582
‒ conducting or monitoring of the trial; 583
‒ conducting bioanalysis; 584
‒ performing reporting and pharmacokinetic and statistical analyses. 585
As a consequence, QA personnel should not be directly involved in trial-related activities, and an 586
in-process audit by QA personnel does not replace oversight by another person when required. 587
588
5.3 The QA unit should be responsible for: 589
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‒ verifying all activities undertaken during the study; 590
‒ ensuring that the quality management systems, are followed, reviewed and updated; 591
‒ determining that the protocol and SOPs are made available to study personnel and are being 592
followed; 593
‒ checking all the study data for reliability and traceability; 594
‒ planning and performing self-inspections (internal audits) at regular and defined intervals in 595
accordance with an SOP, and following up on any corrective action as required, to 596
determine if all studies are conducted in accordance with GCP and GLP; 597
‒ ensuring that contract facilities adhere to GCP and, if applicable, to GLP. This would 598
include auditing of such facilities, and following up on any corrective action as required; 599
‒ verifying that the trial report accurately and completely reflects the data of the study and the 600
methods and procedures followed; 601
‒ promptly reporting audit findings in writing to management, to the investigator and to the 602
study director, as applicable. 603
604
5.4 The CRO should allow the sponsor to monitor the studies and to perform audits of the 605
clinical and analytical study and sites and should provide suitable office space for these activities.. 606
607
5.5 Both retrospective and in-process (e.g. in bioanalysis, as the samples and standards 608
are being prepared and tested) QA verifications should be performed. 609
610
5.6 The quality management system should include root cause analysis, tracking for trends 611
and ensuring all aspects of data integrity. 612
613
6. ARCHIVE FACILITIES 614 615
Note: The CRO should have sufficient and appropriately secure storage space, which should be 616
fire proof, humidity-controlled and pest-controlled, for archiving of trial-related 617
documentation and product samples. Archives should be protected from flooding. 618
619
6.1 An SOP should be in place for archiving. 620
621
6.2 Access to archive storage areas should be controlled and restricted to authorized personnel. 622
623
6.3 Records should be maintained of document access and return. 624
625
6.4 The length of period for which study documentation including raw data is kept in the 626
archive should be defined in the SOP and may vary depending on country requirements. This 627
duration should be specified in the contract between the sponsor and the CRO, which should 628
include provisions for financing of the archival. 629
630
6.5 All data, including both paper and electronic, should be easy to retrieve and traceable. 631
632
7. PREMISES 633 634
7.1 The facilities should be maintained clean and should have adequate conditions of lighting, 635
ventilation and, if required, environmental control. Floor, walls and working benches surfaces 636
should facilitate the cleaning and decontamination. 637
638
Working document QAS/15.622/Rev.1
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7.2 Clinical trials must be carried out under conditions which ensure adequate safety for the 639
subjects. The site selected should be appropriate to the potential risk involved. 640
641
7.3 The CRO should have sufficient space to accommodate the personnel and activities required 642
to perform the studies. The trial site must have adequate facilities, including laboratories, and 643
equipment. The facilities used for the clinical phase of the study, including areas listed in paragraph 644
9.6 should be well organized in order to carry out the activities in logical order. 645
646
7.4 The entry to the facility should be restricted and controlled. There should be alarm systems 647
to detect the exit of subjects from clinical facilities or the doors should be locked (however, doors 648
should be locked only if emergency evacuation can still be ensured). Any entry and exit to the 649
facility should be recorded. 650
651
7.5 Sites involved in clinical activities should include a pharmacy where investigational 652
products should be stored under appropriate conditions with entry and exit restricted by access 653
control. Appropriate entry/exit records of each visit to the pharmacy should be maintained. 654
655
7.6 Utilities such as water, air, gas and electricity should be adequate, stable and uninterrupted. 656
657
7.7 There should be access to telephone, email and facsimile facilities to ensure proper 658
communication. The CRO should have the necessary office equipment (printer, copy machine) to 659
perform the required activities. 660
661
7.8 Laboratory premises should be designed to suit the operations to be carried out in them. 662
Sufficient space should be given to avoid mix ups, contamination and cross-contamination. There 663
should be adequate suitable storage space for samples, standards, solvents, reagents and records. 664
665
7.9 Laboratory premises should be designed to provide adequate protection to all employees 666
and visitors, including inspectors or auditors, by ensuring their safety while handling or working in 667
the presence of chemicals and biological samples. Improper working conditions can negatively 668
impact on the quality of the work performed and of the data generated. 669
670
The following general rules for safe working in accordance with national regulations and SOPs 671
normally include the following requirements: 672
(a) safety data sheets should be available to staff before testing is carried out; staff working in 673
the laboratory should be familiar with and knowledgeable of the material safety data sheets for 674
the chemicals and solvents that they are handling; 675
(b) smoking, eating and drinking in the laboratory should be prohibited; 676
(c) staff should be familiar with the use of fire-fighting equipment, including fire extinguishers, 677
fire blankets and gas masks; 678
(d) staff should wear laboratory coats or other protective clothing, including eye protection; 679
(e) special care should be taken, as appropriate, in handling, for example, highly potent, 680
infectious or volatile substances; 681
(f) highly toxic and/or genotoxic samples should be handled in a specially designed facility to 682
avoid the risk of contamination; 683
(g) all containers of chemicals should be fully labelled and include prominent warnings (e.g. 684
“poison”, “flammable”, “radioactive”) whenever appropriate; 685
(h) adequate insulation and spark-proofing should be provided for electrical wiring and 686
equipment, including refrigerators; 687
Working document QAS/15.622/Rev.1
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(i) rules on safe handling of cylinders of compressed gases should be observed and staff should 688
be familiar with the relevant colour identification codes; 689
(j) staff should be aware of the need to avoid working alone in the laboratory; 690
(k) first-aid materials should be provided and staff instructed in first-aid techniques, emergency 691
care and the use of antidotes: 692
(l) containers containing volatile organic solvents, such as mobile phases or liquid/liquid 693
extraction solvents, should be closed with an appropriate seal; 694
(m) volatile organic chemicals should be handled under certified fume-hoods or air extractors 695
and safety and eye showers should be available in the laboratory. 696
697
7.10 Premises should have suitable systems in place to dispose of waste, to treat fumes and to 698
protect the environment in conformance to local or national regulation. 699
700
8. PERSONNEL 701 702
8.1 There should be a sufficient number of qualified and appropriately trained medical, 703
paramedical, technical and clerical staff to support the trial and to be able to respond effectively to 704
all reasonably foreseeable emergencies. The number of members of staff required depends on the 705
number and complexity of the trials performed by the CRO. At all stages during the trial, including 706
at night, there should be a sufficient number of appropriately qualified and trained personnel to 707
ensure that the rights, safety and well-being of the subjects are maintained, and to take care of the 708
subjects in emergency situations. 709
710
8.2 The delegation of significant trial-related duties should be documented in writing. 711
712
8.3 Contract workers may be employed to perform certain activities. All contract workers 713
having access to the clinical or bioanalytical areas or performing trial-related activities should be 714
provided with adequate information, training and job descriptions. Their contracts should be signed 715
before the performance of work. 716
717
8.4 Current curriculum vitae and training records should be kept for full-time and contract 718
workers. 719
720
8.5 The personnel responsible for the planning and conduct of the study should have 721
appropriate qualifications and sufficient knowledge and experience in the relevant field. They 722
should receive the study-specific information and training required for the performance of their 723
work. 724
725
8.6 Records for training and assessment of knowledge of GCP, GLP and any other relevant area 726
or technique should be maintained. 727
728
8.7 There should be adequate measures in place to protect personnel from accidental 729
contamination (e.g. from accidental needle pricks) while obtaining blood samples from subjects or 730
while handling the samples that are derived from blood products (e.g. plasma and its extracts) or 731
while handling or disposing of infectious waste. 732
733
734
Working document QAS/15.622/Rev.1
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CLINICAL SECTION 735 736
9. CLINICAL PHASE 737 738
Note: As in vivo BE trials are considered as clinical trials, specifically a Phase I study, the 739
general requirements and recommendations of GCP apply to all BE trials. Clinical trials 740
must be carried out under conditions which ensure adequate safety of the subjects. The 741
clinical phase of the study can be performed in the premises of a CRO or by contracting 742
suitable premises in a hospital. 743
744
9.1 A CRO should have rooms meeting the requirements listed in the sections below. 745
746
9.2 There should be sufficient space to accommodate the study subjects. 747
748
9.3 Where appropriate, beds should be available for the subjects. The necessity of beds and 749
overnight stay depends on the type of trial and investigational drug and should be specified in the 750
trial protocol. Overnight stays are usually required during the night prior to dosing to ensure 751
adequately controlled conditions and that there was no outside food/medication intake within the 752
number of hours that is specified in the trial protocol. 753
754
9.4 Systems should be in place in the housing facilities and toilets so that subjects can alert 755
CRO staff in case of need. 756
757
9.5 Facilities for changing and storing clothes and for washing and toilet purposes should be 758
clean, well ordered, easily accessible and appropriate for the number of users. Closed toilets should 759
be alarmed and doors should be designed to ensure that they can be opened from the outside should 760
there be a medical emergency. 761
762
9.6 The study site should have the following facilities which should be separate areas where 763
appropriate: 764
‒ rooms (areas) for subjects registration and screening; 765
‒ room (area) for individual subjects to obtain informed consent without compromising 766
privacy; 767
‒ room for subjects housing; 768
‒ room (area) for subjects (recreation area); 769
‒ restricted-access room for pharmaceutical operations (e.g. storage, repacking, dispensing, 770
documentation) (see also section 14); 771
‒ rooms (areas) for administration of the drug(s) under investigation and sample collection; 772
‒ room (area) for sample processing (e.g. plasma separation) and storage (freezer); 773
‒ controlled access storage areas for study materials, medication and documentation including 774
CRFs; 775
‒ rooms (areas) in which to prepare standardized meals and a dining hall; 776
‒ availability of emergency or first-aid equipment and appropriate rescue medication for use 777
in emergencies. 778
‒ adequate facilities for the proper care of subjects who require emergency or other medical 779
care; 780
‒ archiving facilities. 781
782
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9.7 Provisions should be made for the urgent transportation of subjects to a hospital or clinic 783
equipped for the emergency care of subjects, if required by their condition. 784
785
9.8 Access to key documents, such as the randomization list, should be restricted to only certain 786
specific members of personnel such as the pharmacist in charge of the study. Such documents 787
should be password-secured (if electronic) or kept under lock and key (if distributed as a hard-788
copy) and their distribution should be documented. 789
790
9.9 Equipment used to obtain clinical measurements should be appropriately calibrated at pre-791
defined intervals. 792
793
9.10 The adequate function and performance of emergency-use equipment (e.g. defibrillators) 794
should be verified at appropriate intervals. 795
796
10. CLINICAL LABORATORY 797 798
10.1 A suitable qualified clinical laboratory should be used for analysing samples. An accredited 799
laboratory should be used whenever possible. 800
801
10.2 Haematological tests, urine analysis and other tests should be performed during the clinical 802
trial as specified in the study protocol. 803
804
10.3 Sample labelling, receipt storage and chain of custody should ensure full traceability and 805
sample integrity.11
806
807
10.4 The CRO should be supplied with information about analytical methods used in the 808
laboratory, a dated list of laboratory normal ranges and accreditation certificate of the laboratory, if 809
available. These should be available for inspection by regulatory authorities, if required. 810
811
10.5 A current and signed curriculum vitae of the responsible analyst should be available in the 812
laboratory information file. 813
814
10.6 Individual reports should be established by the laboratory for each subject and should be 815
included in the CRFs. Source or raw data for all tests performed should be archived by the 816
laboratory in electronic or paper formats, depending on their source and storage capacity. 817
Electronic formats are preferred. 818
819
10.7 Data integrity requirements apply to all tests related to the study (full reference to be 820
confirmed once the WHO data integrity guidelines are finalized.) For instance, raw data should be 821
adequately protected from modification or deletion. 822
823
11. ETHICS 824 825 11.1 Independent ethics committee 826
Trials must be approved by an independent ethics committee (IEC) (or equivalent) before a study is 827
conducted, according to WHO Operational guidelines for Ethics Committees that review 828
biomedical research6 and to the enforced legislation. This committee must be independent from the 829
sponsor, the investigator and of the CRO. The discussions, recommendations and decisions of the 830
Working document QAS/15.622/Rev.1
page 19
IEC meetings should be documented in detailed minutes of the meeting. The IEC should be given 831
sufficient time for reviewing protocols, informed consent forms (ICFs) and related documentation. 832
833
11.2 Informed consent 834
• Information for study participants should be given in a language and on a level of 835
complexity appropriate and understandable to the subject, both orally and in writing. 836
837
• Informed consent must always be given by the subject and documented in writing before the 838
start of any trial-related activities, in accordance with GCP. If informed consent is also 839
recorded by video this recording should be retained following local legal requirements . 840
841
• The information must make clear that participation is voluntary and that the subject has the 842
right to withdraw from the study on his or her own initiative at any time, without having to 843
give a reason (compensation should be paid prorata temporis). If subjects who withdraw 844
from the study offer their reasons for doing so, those reasons should be included in the 845
study records. 846
847
• The subject must have access to information about insurance and other procedures for 848
compensation or treatment should he or she be injured or disabled by participating in the 849
trial or during screening. 850
851
• The volunteers/subjects should be given opportunity to discuss their concerns with a 852
physician regarding potential side effects or reactions from the use of the investigational 853
products before participation in the trial. They should also be given the opportunity and 854
sufficient time to discuss their concerns with their participation in the trial with individuals 855
outside of the CRO, such as friends and family members, if they wish. 856
857
• If the ICF is available in several languages (e.g. in English and in the local language, or in 858
several vernacular languages), it should be ensured that all versions of the form contain the 859
same information. 860
861
12. MONITORING 862 863
Note: monitoring is an essential activity to ensure the quality of the clinical trial. 864
865
12.1 The monitor should be qualified (see section 8, Personnel). The main responsibility of the 866
monitor for a BE study is to ensure that the study is conducted in accordance with the protocol, 867
GCP, GLP and applicable ethical and regulatory requirements. This includes verification of the use 868
of correct procedures for completion of CRFs and verification of the accuracy of data obtained. 869
870
12.2 The sponsor can delegate the monitoring function to the CRO. In such cases the CRO 871
should be able to arrange for the monitoring of the trial according to regulatory requirements. In 872
such a case attention should be paid to the independence of the monitoring function in order to 873
avoid conflicts of interest and pressure on the monitors. The monitoring reports should always be 874
provided to the sponsor. 875
876
12.3 A risk-based approach to monitoring can be considered. However, a pre- and post-study 877
visit as well as a monitoring visit during the conduct of the trial are usually performed. The monitor 878
should prepare a written report after each site visit and communicate any issues to the CRO and to 879
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the sponsor as promptly as possible, even during conduct of the study if possible, to enable prompt 880
corrective action. Such communications and corrective actions should be documented. 881
882
12.4 When the monitoring is delegated to the CRO, SOPs should be available to describe: 883
‒ the designation of monitors, who should be independent from the personnel performing the 884
trial; 885
‒ monitoring visit procedures; 886
‒ the extent of source data verification, including with regards to accountability of the 887
investigational products and adherence to the protocol. 888
The extent of the monitoring, including the number of visits to be performed, should be agreed 889
upon with the sponsor. 890
891
12.5 Separate SOPs (with checklists for the monitor) for the initiation visit, routine monitoring 892
visits and a closing visit are recommended. 893
894
12.6 Appropriate entry/exit record of each monitoring visit should be maintained. 895
896
13. INVESTIGATORS 897 898
13.1 The principal investigator (PI) should have the overall responsibility for the clinical conduct 899
of the study, including clinical aspects of study design, administration of the products under 900
investigation, contacts with local authorities and the ethics committee and for signing the protocol 901
and the final study report. 902
903
13.2 The investigator(s) should have appropriate qualifications, be suitably trained and 904
have experience in the conduct of BE studies (the legal status of persons authorized to act as 905
investigators differs between countries) and at least one investigator must be legally allowed 906
to practise medicine. 907
908
13.3 The medically-qualified investigator should be responsible for the integrity, health and 909
welfare of the subjects during the trial and the accurate documentation of all trial-related clinical 910
data. 911
912
13.4 The CRO is responsible for selecting investigator(s). In cases where the investigators are 913
not permanent employees of the CRO external investigators should be contracted and adequately 914
trained. 915
916
14. RECEIVING, STORAGE AND HANDLING OF INVESTIGATIONAL DRUG 917
PRODUCTS 918 919
14.1 CROs should document all the information concerning the receipt, storage, handling 920
and accountability of investigational and comparator products at any stage of the trial. CROs 921
must keep records of information about the shipment, delivery, receipt, storage (including 922
storage conditions), dispensing, administration, reconciliation, return and/or destruction of 923
any remaining pharmaceutical products. Detail of the pharmaceutical product used should 924
include dosage form and strength, lot number, expiry date and other coding that identifies the 925
specific characteristics of the product tested. 926
927
Working document QAS/15.622/Rev.1
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14.2 A suitable location within the CRO or a local pharmacy or hospital pharmacy should 928
assume responsibility for storage, delivery, return and record keeping of the investigational 929
products. 930
931
14.3 Pharmaceutical products should be stored under appropriate storage conditions as specified 932
in the official drug information provided by the sponsor. 933
934
14.4 All study medication should be kept in a securely locked area accessible only to authorized 935
persons. 936
937
14.5 Randomization should be performed in accordance with an SOP and records should be 938
maintained, including the randomization list and seed, if applicable. Under normal operations the 939
randomization list should be accessible only to the person who generates it, a dispensing 940
pharmacist and the statistician and should not be circulated or made available to other staff 941
members via any medium. A system should be in place which allows the PI or delegated staff to 942
access the randomization list in case of emergencies. 943
944
14.6 Labelling should be performed in accordance with the following requirements: 945
‒ the printing step should be done in a manner that reduces potential risks of mislabelling and 946
should be done in accordance with a SOP; 947
‒ each label should include the following information 948
• name of the sponsor, 949
• a statement of “for clinical trial use only”, 950
• trial reference number or study number, 951
• batch number, 952
• subject identification number (to which the product is destined to be given to), 953
• period, 954
• active ingredient and dosage, 955
• the storage conditions, 956
• expiry date (month/year) or retest date, 957
• identification of the product (test or reference). 958
‒ compliance of all labels with the randomization list should be verified once printed, prior to 959
labelling of the containers; 960
‒ labelling should be done on the container, not on the lid, to ensure that the information is 961
not lost once the lid is removed; 962
‒ the system used for labelling and documenting the administration of the product should 963
make it possible to verify that each subject indeed received the product dispensed for him, 964
for instance, by using labels with a tear-off portion. In such a case, labels should be 965
designed in such a way that two identical labels are pasted to the container and that the 966
second label can be easily cut or detached and pasted onto the CRFs at the time of dosing 967
(e.g. two labels printed side by side, with only one that is actually pasted onto the container 968
and the other one which remains attached but unpasted – it should be torn off or cut with 969
scissors at the time of dosing. Using two independent labels – one stuck on the container, 970
one kept loose – should be avoided due to the risk of mix-ups); 971
‒ the empty containers should be labelled separately for the test and the reference 972
investigational products and should remain adequately segregated and placed in a secure 973
area under lock and key, to ensure absence of risk of any potential mix ups, until the 974
dispensing stage; 975
Working document QAS/15.622/Rev.1
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‒ label reconciliation should be performed; 976
‒ appropriate, detailed records should be maintained for each of the above steps. 977
978
14.7 Dispensing/packaging should be performed in accordance with the following requirements: 979
‒ the surface area on to which the product will be handled should be thoroughly cleaned prior 980
to bringing bottles of the product in the area. Any product container (full or empty), lone 981
dosage formulations, labelling materials contaminants/dirt/debris should be removed from 982
the area; 983
‒ a second person should verify that the surface area (otherwise referred to as “line”) is indeed 984
clear and clean prior to bringing and opening containers of the product: 985
‒ test and reference products should be handled using an appropriate instrument, such as a 986
spatula or spoon, as opposed to gloved hands; 987
‒ tablets should be distributed in each container in accordance with the randomization list 988
either for the comparator or for the test product. Both products should never be handled at 989
the same time. This also applies to the labelled containers; 990
‒ records should be made of this step in a manner that is similar to manufacturing batch 991
records, as described in WHO GMP guidelines, i.e. each and every step should be recorded 992
sequentially in detail; 993
‒ the surface area used to handle the product and its surroundings should be cleared and 994
cleaned immediately after and/or prior to initiating the dispensing of the next product (it is 995
important to note that this also applies to different products used in the same study); 996
‒ drug accountability and dispensing records should be maintained at all times. Each activity 997
should be documented at the time it is performed. This includes 998
• records of doses dispensed and returned or destroyed, 999
• records of cleaning and clearance of the area prior to dispensing, 1000
• record of verification of adequate cleaning and clearance of the area, 1001
• record of verification by a second person of each step; 1002
‒ any factors that could affect the integrity of the data relating to investigational medicinal 1003
products and comparators should be recorded, monitored and controlled. 1004
1005
[Please refer for further guidance on labelling and dispensing to the WHO good manufacturing 1006
practices: supplementary guidelines for the manufacture of investigational pharmaceutical 1007
products for clinical trials in humans, WHO Technical Report Series, No. 964, Annex 7, 1996.] 1008
1009
14.8 Dosing should be performed in accordance with the following requirements: 1010
‒ dosing should be performed in accordance with a SOP; 1011
‒ it should be performed under the supervision of the investigator or of qualified staff to 1012
whom this task has been explicitly delegated in writing; 1013
‒ whenever possible, just prior to dosing, a check should be performed of vial contents 1014
matching the information on the label; 1015
‒ the exact time of dosing should be documented; 1016
‒ in order to ensure that the subject has swallowed the product, a mouth check should be 1017
performed by looking under the tongue, under the lips, in the corners of the mouth and 1018
between gums and cheeks, using a tongue depressor or a spatula and a flashlight, in the case 1019
of solid oral dosage forms. For other types of dosage forms verification of adequate 1020
administration should be performed by other suitable means. It should be documented; 1021
‒ if more than one dosage unit is administered this should be clearly documented; 1022
Working document QAS/15.622/Rev.1
page 23
‒ dosing can be documented directly in the case report forms. If retranscribed in the case of 1023
report forms from other documents the original documents should be retained; 1024
‒ drug reconciliation, after dosing, should be verified by a second responsible person. 1025
1026
14.9 The investigator should follow the protocol requirements, randomization scheme and where 1027
required, blinding. The investigator should ensure that the investigational product use is 1028
documented in such a way as to ensure appropriate dosage. 1029
1030
14.10 Samples of the product in the original container should be retained for possible 1031
confirmatory testing in the future for a period of at least one year after the expiry date of the newest 1032
product (test or reference) or in compliance with the applicable national requirements or 1033
international recommendations, as appropriate. Sample retention should be defined and described in 1034
an SOP and be specified in the contract between the sponsor and the CRO. Dispensed products that 1035
were not administered should also be retained. 1036
1037
15. CASE REPORT FORMS 1038 1039
15.1 CRFs should be used to record data on each subject during the course of the trial. 1040
1041
15.2 The CRO should have a procedure for designing CRFs if the sponsor requests the CRO to 1042
design them. It is recommended to use a standardized format or template which should be amended 1043
for each study protocol in accordance with the requirements for the particular study. The CRF 1044
should be reviewed against other trial documentation such as the protocol and trial database to 1045
ensure that appropriate information and data is captured and that the CRF is consistent with other 1046
trial documentation. 1047
1048
15.3 The required data to be collected on each volunteer should be specified in the trial protocol. 1049
Any data to be recorded directly on the CRF (i.e. no prior written or electronic record of data), and 1050
to be considered to be source data, should be identified in the protocol. 1051
1052
15.4 CRFs should reflect the actual results obtained during the study and allow easy access to 1053
verification, audit and inspection of the data. 1054
1055
15.5 Appropriate procedures should be established and followed to document the investigator's 1056
certification of the accuracy of CRFs. Any errors or omissions should be clarified with the 1057
investigator, corrected, dated and signed and explained on the CRF. 1058
1059
15.6 Copies of the clinical laboratory reports and all ECGs should be included with the CRFs for 1060
each subject and should be submitted along with the dossier, if applicable, according to 1061
requirements of the regulatory authority to whom the dossier is submitted. 1062
1063
16. VOLUNTEERS, RECRUITMENT METHODS 1064 1065
Note: The selection of subjects should be performed sufficiently in advance to ensure that a 1066
sufficient number of subjects will be available. The last-minute selection of additional 1067
subjects may result in non-compliance with the inclusion and exclusion criteria, 1068
possibly compromising the safety of the subjects and the integrity of the trial data. The 1069
use of a generic screening process to select a pool of subjects which can be enrolled in 1070
any bioequivalence study conducted at the CRO (unless the protocol foresees specific 1071
inclusion or exclusion criteria) can help to achieve this goal. 1072
Working document QAS/15.622/Rev.1
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1073
16.1 Procedures for the recruitment of volunteers should be available and should include a 1074
description of the potential methods that can be used by the CRO for recruitment of volunteers. A 1075
database should be maintained for volunteers to avoid cross-participation and to specify a minimum 1076
time interval between a volunteer’s participation in two studies. Access to the database should be 1077
password controlled in order to secure confidential volunteer/subject information. 1078
1079
16.2 Volunteer and subject identification should be ensured by reliable means. If a biometric 1080
system is used for the identification of volunteers this system should be validated on a periodic 1081
basis as well as after any change made to the validated system that could impact its function. 1082
1083
16.3 Informed consent of potential subjects should be obtained for any screening procedures 1084
required to determine eligibility for the study, in addition to informed consent for participation in 1085
the research portion of the study. 1086
1087
16.4 Subject selection criteria (inclusion and exclusion criteria) and recruitment procedures 1088
should be described in the clinical trial protocol. 1089
1090
16.5 Subject screening results and trial participation should be recorded in a validated 1091
database maintained by the CRO. If a regional or national volunteer database exists then trial 1092
participation should be checked and participation data uploaded to this central repository to 1093
prevent over-volunteering. Access to the database should be password controlled in order to 1094
secure confidential subject information. 1095
1096
16.6 Ideally the CRO's database should record and allow the users to query: 1097
– contact details; 1098
– gender; 1099
– status: eligible, disqualified, not eligible, quarantined, etc., and the reason for this 1100
status if applicable; 1101
– date and place of last study participation, if applicable/if known; 1102
– date of last screening; 1103
– a unique code assigned to the subject which will never change; 1104
– outcome of last trial: Completed, randomised but not dosed, withdrawn for personal 1105
reason, withdrawn for medical reason, etc. 1106
These data should be backed up daily and be available for review at any time. 1107
1108
16.7 Medical records should be generated for each subject and should include information 1109
obtained during each screening visit and each study participation, which could be relevant for 1110
the inclusion and follow-up of the subject into subsequent trials. Access to previous medical 1111
records for individual subjects should be available and a consistency check conducted where 1112
trial-specific medical records are generated. This is important to ensure safety issues can be 1113
assessed before enrolment in a study. 1114
1115
17. FOOD AND FLUIDS 1116 1117
17.1 As meals can significantly affect absorption of drugs fasting and meals should be 1118
standardized and adequately controlled and scheduled during the study days. The CRO should be 1119
able to arrange for standardized meals, snacks and drinks to study subjects as described in the 1120
clinical trial protocol. 1121
Working document QAS/15.622/Rev.1
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1122
17.2 Records should be maintained for timing, duration and amount of food and fluids 1123
consumed. Subjects should be asked for food and drink consumption prior to ambulatory samples 1124
being obtained, if the protocol contains specific requirements. 1125
1126
17.3 Standardized meals should be designed by a dietician with appropriate qualification, 1127
training and experience. If such services are contracted out a formal contract with terms of 1128
reference should be available. 1129
1130
18. SAFETY, ADVERSE EVENTS, ADVERSE EVENT REPORTING 1131 1132
18.1 Appropriate study planning includes adequate evaluation of risk to the subjects. The study 1133
should be planned, organized, performed and monitored so that the safety profile will be 1134
acceptable, including to the volunteers. 1135
1136
18.2 First-aid emergency equipment and appropriate rescue medication should be available at the 1137
study site and adequate facilities of the proper care of subjects who require emergency or other 1138
medical care. Any treatment given to a subject should be documented and included in the CRF and 1139
supporting documentation as necessary. 1140
1141
18.3 A medical doctor should be responsible for medical decisions in case of adverse events and 1142
for notifying the relevant health authorities, the sponsor and, when applicable, the Ethics 1143
Committee, without delay in the case of serious adverse events. Appropriate timelines should be 1144
respected as governed by national regulations. 1145
1146
18.4 The CRO should have appropriate adverse event registration and reporting forms, which 1147
should be provided to the investigator; these forms can be part of the CRF. If required the 1148
respective sponsor's forms may be used. 1149
1150
BIOANALYTICAL SECTION 1151
1152
Note: The analysis of drug concentrations may be performed in the same CRO which conducted 1153
the clinical study, or may be contracted to another laboratory or CRO. 1154
1155
19. METHOD DEVELOPMENT 1156
1157 19.1 The bioanalytical laboratory should provide detail on how a bioanalytical method was 1158
developed. The laboratory should keep a copy of any publication used to develop the bioanalytical 1159
method. The modifications and adaptations to the published method made by the laboratory should 1160
be documented. 1161
1162 19.2 Selection of the internal standard should be justifiable by sound scientific principles. In 1163
general, chemical and physical properties of the internal standard should be as close to those of the 1164
analyte as possible. Both stable isotope-labelled and non-isotope labelled internal standards are 1165
acceptable, though the use of stable isotope-labelled internal standard is recommended when MS 1166
methods are used. The selection of a stable isotope labelled internal standard should take into 1167
consideration factors such as the isotope labelling positions in order to limit the risk of exchange 1168
reactions. 1169
1170
Working document QAS/15.622/Rev.1
page 26
19.3 Method development should ensure that methods are created in a manner which will 1171
minimize any potential human error. 1172
1173
20. METHOD VALIDATION 1174 1175
The most up-to-date guidelines from stringent regulatory authorities (SRAs) on the topic 1176
of bioanalytical method validation should be followed. 1177
1178 20.1 Validation requirements for the analytical method should be described in the protocol. 1179
There should be separate SOPs for analytical method validation. 1180
1181
20.2 Data to support the stability of the samples under the stated conditions and period of storage 1182
should be available preferably before the start of the study. 1183
1184
20.3 Method validation should be performed with at least one run that is comparable in length to 1185
those that are expected to be used for analysis of samples. 1186
1187
21. SAMPLE COLLECTION, STORAGE AND HANDLING OF BIOLOGICAL 1188
MATERIAL 1189 1190
21.1 The specification of the samples (serum, plasma or urine), sampling method, volume and 1191
number of samples should be stated in the clinical trial protocol and the information provided to the 1192
volunteer. 1193
1194
21.2 There should be documented procedures for the collection, preparation, transport or 1195
shipping and storage of samples. 1196
1197
21.3 Any specific lighting conditions foreseen by the protocol or other documents should be 1198
complied with. This should be documented. 1199
1200
21.4 Actual sampling times and deviations from the prespecified sampling times should be 1201
recorded. Deviations should be reported in the study report and should be taken into consideration 1202
when calculating the pharmacokinetic parameters. 1203
1204
21.5 Labelling of collected samples should be clear to ensure correct identification and 1205
traceability of each sample. 1206
1207
21.6 The storage conditions of samples depend on the investigational drug. However, all storage 1208
conditions (e.g. freezer temperature) should be specified in the study protocol, controlled, 1209
monitored and recorded throughout the storage period and transportation. Procedures should be in 1210
place to ensure sample integrity in case of system failures. 1211
1212
21.7 Records for the storage and retrieval of samples should be maintained. 1213
1214
21.8 It is recommended to keep duplicate or back-up samples, and store and ship them 1215
separately. 1216
1217
21.9 The duration of storage of bioanalytical samples should be specified in the contract between 1218
the sponsor and the CRO. 1219
1220
Working document QAS/15.622/Rev.1
page 27
21.10 Local requirements for the handling and destruction of remaining biological materials 1221
should be followed. 1222
1223
22. ANALYSIS OF STUDY SAMPLES 1224
1225 The most up-to-date guidelines from SRAs on the topic of bioanalytical method validation should 1226
be applied. Additionally: 1227
1228 22.1 The results of the method validation should be available before the initiation of study 1229
sample analysis, with the possible exception of the evaluation of the long-term stability of the 1230
analyte in matrix. However these results should be available before the study report is issued and 1231
should be submitted with the validation report in the application. 1232
1233 22.2 Each analytical run should include calibration curve (CC) standards, QC samples and 1234
subject samples processed simultaneously. The exact sequence of processing should be 1235
documented. All samples collected from a given subject during all trial periods should be analysed 1236
in the same run unless scientifically justified (e.g. due to the limited stability of samples, requiring 1237
the analysis of period one samples before period two is conducted). 1238
1239
22.3 Equipment with an adequate capacity should be used to be able to process all samples in a 1240
run simultaneously, rather than splitting the samples into several extraction batches. However, if 1241
using several extraction batches within a single analytical run cannot be avoided, each batch should 1242
include QC samples. The acceptance criteria for the analytical run should be defined in a SOP first 1243
for the full run, then if the run is acceptable, for each individual extraction batch. 1244
1245
22.4 Every effort should be made during method development to avoid carry-over effects. If 1246
carry-over cannot be avoided, procedures should be implemented to limit its influence, for instance, 1247
by inserting wash samples into runs after samples with a high level of concentration. 1248
1249
22.5 With regards to the use of blank plasma in the preparation of CCs and QCs: 1250
‒ the number of freeze-thaw cycles and the storage duration that a given blank plasma sample 1251
can be submitted to, should be limited as much as possible to ensure absence of degradation 1252
and/or change of its properties. Freezing blank plasma in small volumes should be 1253
considered to help limit the number of freeze-thaw cycles for any given blank plasma 1254
sample; 1255
‒ the anticoagulant that was used for the blank plasma should be documented. It should match 1256
the anticoagulant that was used in study samples, in nature and in proportion. 1257
1258
22.6 With regards to incurred sample reanalysis: 1259
‒ incurred sample reanalysis should be performed in line with the European Medicines 1260
Agency (EMA) Guideline on Bioanalytical Method Validation (2011)5; 1261
‒ large differences between results may indicate analytical issues and should be investigated. 1262
1263
23. DATA PROCESSING AND DOCUMENTATION 1264 1265
23.1 Integration settings should be science-based and fully justifiable. Smoothing should be kept 1266
low enough not to mask possible interferences and changes in peak geometry. 1267
1268
Working document QAS/15.622/Rev.1
page 28
23.2 The different iterations used to obtain a CC should be saved – if a given CC fails, it is not 1269
acceptable to exclude CCs which meet acceptance criteria or similarly, to include CC standards 1270
which do not meet criteria, just to make the calibration or the QC standards pass. The source data 1271
should contain the original, first evaluation of runs (containing all calibration samples). If several 1272
calibration samples are excluded sequentially the CC obtained at each step should be retained to 1273
document that the criteria to exclude the next sample were met. If electronic raw data are used it is 1274
acceptable to only save the final calibration if it is possible to revert to the initial calibration during 1275
an inspection. The process and criteria for acceptance and exclusion of CC standards should be 1276
described in an SOP. 1277
1278
23.3 If the first or last calibration sample is rejected the calibration range should be truncated, i.e. 1279
the second calibration sample becomes the lower limit of quantification (LLOQ) in that run (or the 1280
one before last calibration sample becomes the upper limit of quantification (ULOQ). Samples with 1281
a concentration below the revised LLOQ (or above the revised ULOQ) should be reanalysed. 1282
Alternatively, the whole run may be repeated but this is not the preferred option. 1283
1284
23.4 Internal standard variation should be trended and used as part of the verifications of result 1285
validity. Significant changes in internal standard response could signal an analytical problem which 1286
could require an investigation and/or sample reanalysis. Significant differences between the internal 1287
standard results of CC standards or QC standards vs samples could also signal problems affecting 1288
the reliability of the results. 1289
1290
23.5 Full audit trails should be activated at all times and on all analytical instruments in a given 1291
facility, both prior, during and after the method validation and the study of interest. 1292
1293
23.6 All original analytical raw data (e.g. calculations, chromatograms and their associated audit 1294
trails, etc.) should be documented in a manner that will ensure traceability with respect to the 1295
sample number, equipment used, date and time of analysis and the name(s) of the technician(s). If 1296
several audit trail files are generated all should be retained (e.g. results table audit trail, project 1297
audit trail, instrument audit trail). 1298
1299
23.7 Each data point should be traceable to a specific sample, including sample number, time of 1300
collection of the sample, time of centrifugation, if applicable, time when the sample was placed in 1301
the freezer, time of sample analysis, etc., to be able to determine whether any aberrant results might 1302
have been due to sample mishandling. 1303
1304
24. GOOD LABORATORY PRACTICES 1305
1306 24.1 Although most GLP guidelines
3 apply formally only to non-clinical safety studies, general 1307
principles of GLP should also be followed during the bioanalytical part of bioequivalence studies. 1308
1309
24.2 Analysis should be performed in a laboratory with established QA systems. 1310
1311
24.3 Key sample storage systems or other areas requiring environmental controls should be 1312
adequately qualified, calibrated and maintained. There should be an alarm system or an adequate 1313
monitoring system to control the temperature of the critical stage areas and key sample storage 1314
systems, such as freezers. If there is an automatic alarm system it has to be tested regularly for its 1315
functionality. The daily monitoring and all the alarm checks should be documented. There should 1316
be a system in place to ensure that timely and appropriate action is taken following an alarm. 1317
1318
Working document QAS/15.622/Rev.1
page 29
24.4 For purposes of qualification and requalification the temperature mapping of the freezers 1319
and refrigerators should be run for between 24 and 72 hours, or more if justified. Remapping 1320
should be done after any significant modifications to the storage units. 1321
1322
24.5 Appropriate repairs and/or sample transfer to other equivalent storage units should be 1323
considered whenever an analysis of temperature monitoring records show unexplained variability 1324
outside normal operating limits. 1325
1326
24.6 Balances, other measuring devices and equipment/instruments used during the conduct of a 1327
trial should be periodically calibrated and verified before use. They should be fit for their intended 1328
purpose. 1329
1330
24.7. There should be SOPs for the operation, use, calibration, checks and preventive 1331
maintenance of equipment. Records should be maintained. Equipment used during the course of the 1332
trial should be identified to be able to verify that they have been appropriately qualified and 1333
calibrated. 1334
1335
24.8 Chemicals, reference substances, reagents, solvents and solutions should be labelled to 1336
indicate identity, purity concentration (if appropriate), expiry date and specific storage instructions. 1337
Information concerning source, preparation date and stability should be available. 1338
1339
PHARMACOKINETIC, STATISTICAL CALCULATIONS AND 1340
REPORTING SECTION 1341
1342
25. PHARMACOKINETIC AND STATISTICAL CALCULATIONS 1343 1344
25.1 The statistical model underlying any primary BE analysis should be stated in the 1345
protocol and/or a statistical analysis plan. It should be made clear which factors are fixed and 1346
which are random. It should be stated if the model is a mixed effects model, a normal linear 1347
model, etc. If the methods of statistical analysis are amended following protocol approval 1348
then this should be documented in a protocol amendment and should also be reported in the 1349
clinical study report including the reason for change. 1350
1351
25.2 Calculations should be made by qualified persons (see Section 8: Personnel). 1352
1353
25.3 The means of performing pharmacokinetic and statistical calculations (both software and 1354
scripts) should be specified in the study protocol and/or a pharmacokinetic analysis plan and a 1355
statistical analysis plan. Data analysis should conform to these requirements. This should include 1356
the manner in which AUCinf is derived (i.e. how the points used for extrapolation are selected). 1357
1358
25.4 Calculations should be made using validated software and scripts. Software and scripts 1359
should be validated or qualified using an SOP, ideally with datasets of varying complexity and with 1360
the alpha level(s) actually in use. Self-designed software should be demonstrated as suitable for 1361
intended use. For guidance on the use of computerized systems (5) (see Section 4: Computer 1362
Systems). 1363
1364
25.5 Data values input should be double-checked by a second qualified person as per an SOP. 1365
1366
Working document QAS/15.622/Rev.1
page 30
25.6 A database of trial records should be maintained and it should preferably be locked as soon 1367
as possible after completion of the study. Once it is locked the study can be unblinded and 1368
statistical analysis performed. The dates of locking and statistical analysis should be documented, 1369
mentioned in the study report and the process should be defined in a suitable procedure. 1370
1371
26. STUDY REPORT 1372 1373
26.1 The clinical study report should reflect the complete study procedures and results in an 1374
accurate manner. 1375
1376
26.2 The clinical study report should be well written and presented. All deviations from the 1377
protocol in the performance of the study should be reported. 1378
1379
26.3 There should be no discrepancies between the results stated in the report and the actual 1380
original (raw) data. 1381
1382
26.4 The report should comply with regulatory requirements as applicable and be presented in a 1383
standard format. 1384
1385
26.5 The study report should include a report on the bioanalytical part of the trial, including a 1386
description of the bioanalytical method used and the validation report of this method. 1387
1388
26.6 The procedure for approval of the clinical study report by the investigator and sponsor and 1389
for approval of the bioanalytical report by the study director should be specified. 1390
1391
26.7 The report should be approved (signed and dated) by the responsible persons. 1392
1393
26.8 All monitoring and audit reports should be available before release of the final study report. 1394
1395
REFERENCES 1396 1397
1. Multisource (generic) pharmaceutical products: guidelines on registration requirements to 1398
establish interchangeability. In: Expert Committee on Specifications for Pharmaceutical 1399
Preparations. Forty-ninth report. World Health Organization, Geneva. WHO Technical 1400
Report Series, No. 992, Annex 7, 2015, pp. 347–390. 1401
1402
2. Guidelines for good clinical practice for trials on pharmaceutical products. WHO Technical 1403
Report Series, No. 850, 1995 (pp. 97–137). 1404
1405
3. WHO Handbook on Good Laboratory Practice/OECD Series on Principles of Good 1406
Laboratory Practice and Compliance Monitoring, Number 1: OECD Principles on Good 1407
Laboratory Practice (as revised in 1997). Organization for Economic Co-operation and 1408
Development. ENV/MC/CHEM(98)17. 26.Jan, 1998. 1409
1410
4. The Good Automated Manufacturing Practice (GAMP) Guide - A risk-based approach to 1411
compliant GxP computerized systems (GAMP5). ISPE - International Society for 1412
Pharmaceutical Engineering, December 2009. 1413
1414
5. Guidelines on Bioanalytical Method Validation EMEA/CHMP/EWP/192217/2009 Rev.1 1415
Corr.* Committee for Medicinal Products for Human Use (CHMP), 1 February 2012. 1416
Working document QAS/15.622/Rev.1
page 31
1417
6. WHO Operational guidelines for Ethics Committees that review biomedical research (7). 1418
WHO, TDR/PRD/ETHICS/2000.1. http://www.who.int/tdr/publications/ 1419
documents/ethics.pdf?ua=1). 1420
1421
7. WHO Good data management practices guidelines (full reference to be confirmed once 1422
finalized.) 1423
1424
8. Good Practices for Computerised Systems in Regulated “GXP” Environments, PIC/S 1425
Guidance, Pharmaceutical Inspection Convention Pharmaceutical Inspection Co-operation 1426
Scheme, PI 011-3, 25 September 2007. 1427
1428
9. US FDA Code of Federal Regulations Part 11. 1429
1430
10. EU guidelines to Good Manufacturing Practice and Medicinal Products for Human and 1431
Veterinary Use Annex 11, Computerised systems. 1432
1433
1434
Working document QAS/15.622/Rev.1
page 32
APPENDIX 1 (REVISED) 1435 EXAMPLES OF THE LIST OF STANDARD OPERATING PROCEDURES AT A CONTRACT 1436
RESEARCH ORGANIZATION 1437 1438
The following are examples of the list of standard operating procedures (SOPs) that should be 1439
used at contract research organizations (CROs). This list is not exhaustive as other procedures 1440
may be necessary depending on the functional and compliance requirements at each facility. 1441
All of the documents at the CRO related to a bioequivalence (BE)/clinical trial should be 1442
controlled (version date, approved, etc.) documents. This control is easier if the documents 1443
are in the SOP format or are appended to SOPs. 1444
SOPs should be in place at least for all the critical and major operations in the BE/clinical 1445
trial. 1446
Number and name of SOP 1447
1. Conduct of BE study. 1448
2. Archiving and retrieval of documents related to a BE study. 1449
3. Quality assurance of a BE study; audits of clinical and bioanalytical part of the study 1450
and the study report. 1451
4. Study files. 1452
5. Preparation and review of the protocol for the study. 1453
6. Amendment to the protocol for the study. 1454
7. Protocol deviations/violation recording and reporting. 1455
8. Sponsor/CRO quality assurance agreement in conducting the BE study. 1456
9. Study approval process by ethical committee . 1457
10. Bioavailability (BA)/BE report. 1458
11. Study report. 1459
12. Written informed consent. 1460
13. Obtaining written informed consent for screening from study volunteers. 1461
14. Allotment of identification numbers to volunteers at various stages in BE study. 1462
15. Investigator’s brochure. 1463
16. Case-report form (CRF). 1464
17. Preparation of CRF, review and completion. 1465
18. Data collection and CRF completion. 1466
19. Adverse/serious adverse event monitoring, recording and reporting. 1467
20. Organization chart of the study. 1468
21. Training of the personnel. 1469
22. Responsibilities of the members of the research team. 1470
23. Monitoring of the study by the sponsor. 1471
24. Conduct of pre-study meeting. 1472
25. Study start-up. 1473
26. Subject management. 1474
27. SOP on mobilization of individuals for registration into volunteer bank. 1475
28. Eligibility criteria for registration and registration of individuals into volunteer bank. 1476
29. Handling of subject withdrawal. 1477
30. Allotment of identification numbers to volunteers at various stages in the biostudy. 1478
31. Screening of enrolled volunteers for the study. 1479
32. Collection of urine samples of subjects for detection of drugs of abuse and 1480
transportation of samples to pathology laboratory. 1481
33. Custodian duties. 1482
Working document QAS/15.622/Rev.1
page 33
34. Payments to research subjects for BA/BE studies. 1483
35. Procedures for entry into and exit from clinical unit 1484
36. Handling of subject check-in and check-out. 1485
37. Housekeeping at clinical unit. 1486
38. Planning, preparation, evaluation and service of standardized meals for bio-studies. 1487
39. Distribution of meals to study subjects. 1488
40. Operation and maintenance of nurse calling system. 1489
41. Administration of oral solid dosage form of the drug to human subjects during BA/BE 1490
study. 1491
42. Cannulation of study subjects. 1492
43. Collection of blood samples from study subjects. 1493
44. Identification of biological samples. 1494
45. Recording of vital signs of subjects. 1495
46. Operation and verification of fire alarm system. 1496
47. Oxygen administration to subject from medical oxygen cylinder. 1497
48. Emergency care of subjects during BA/BE study. 1498
49. Availability of ambulance during BA/BE study. 1499
50. Centrifugation and separation of blood samples. 1500
51. Storage of plasma/serum samples. 1501
52. Segregation of bio-samples. 1502
53. Transfer of plasma/serum samples to bioanalytical laboratory. 1503
54. Procedures for washing glassware. 1504
55. Recording temperature and relative humidity of rooms. 1505
56. Instruction on operation and maintenance procedures for all the equipment in the 1506
clinical unit. 1507
57. Numbering the equipment and log books for use in the clinical unit. 1508
58. Control of access to pharmacy. 1509
59. Pharmacy area requirements. 1510
60. Authorization related to drug storage, dispensing and retrieval from storage for BE study. 1511
61. Study drug receipt, return and accountability documentation. 1512
62. Study drug receipt and return procedures. 1513
63. Storage of drugs in the pharmacy. 1514
64. Line clearance before and after dispensing. 1515
65. Documentation of line clearance and dispensing; packaging records and release of 1516
dispensed drugs. 1517
66. Retention of samples of study drugs. 1518
67. Disposal of archived study drugs. 1519
68. Disposal of biological materials. 1520
69. Procedures for bioanalytical laboratory (SOPs for the different equipment, analytical 1521
methods, reagent preparation). 1522
70. Out-of-specification in the laboratory. 1523
71. Acceptance criteria for analytical runs: acceptance of calibration curves, acceptance of 1524
the runs based on quality control samples results. 1525
72. Chromatographic acceptance criteria, chromatogram integration. 1526
73. Sample re-assay. 1527
74. Pharmacokinetic data from bioanalytical data. 1528
75. Statistics in a BE study. 1529
i
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