sponsors responcibilities
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SPONSORS RESPONSIBILITIES
Dr Farheen Shaikh
Wockhardt Limited
Sponsor
Sponsor is an individual, company, institution, or organization which takes responsibility for the initiation, management, and/or financing of a clinical trial. An investigator is also sponsorif he takes all the responsibilitiesof a clinical trial.
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Sponsor team
Sponsor team contain following:
Project Manager
CRA/Monitor CRO (Contract Research Organization) Data Manager
Biostatician
Medical Writer
Responsibilities of sponsor
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1. Selection of Site and Investigator
Sponsor responsibility is to
select well qualified, trained andexperiencedinvestigator(s) for theconduct of trial. The selected
investigator should be based at theinstitutions/hospitals havingsufficient resources to properlyconduct the trial.
Responsibilities of sponsor
2. Allocation of Duties and ResponsibilitiesPrior to initiating a Study the
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Sponsor should define and allocateall Study related
duties and responsibilities to therespective identified
person(s)/organization(s).
Responsibilities of sponsor
3. Contract Research Organizati
on (CRO)A sponsor may transfer any or all ofthe sponsor's trial-relatedduties and functions to a CRO, butthe ultimate responsibility for thequality and integrity of the trial dataalways resides with the sponsor.
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The CRO should implement qualityassurance and quality control.
Responsibilities of sponsor
Any trial-related duty and function that is transferred to and assumed by a C
RO should be specified in writing. Any trial-related duties and functions not specifically transferred to and assumed bya CRO are retained by thesponsor. All references to a sponsor in this guideline also apply to a CRO to
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the extent that aCRO has assumed the trial related duties and funct
ions of a sponsor.
Responsibilities of sponsor
4. Medical ExpertiseThe sponsor shoulddesignate appropriately qualified
medical personnel who will bereadily available to advise on trialrelated medical questions orproblems.
If necessary, outside consultant's
may be appointed for this purpose.
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Responsibilities of spon
sor
5. Trial DesignThe sponsor should utilize qualified
individuals (e.g. biostatisticians,clinical pharmacologists, andphysicians) as appropriate,throughout all stages of the trial
process, from designing the protocoland CRFs and planning the analysesto analyzing and preparing interimand final clinical trial reports.
Responsibilities of sponsor
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6. FinancingThe financial aspects of the trial
should be documented in anagreement between the sponsorand the investigator/institution.
Responsibilities of sponsor
7. Notification/Submission to Re
gulatory Authority(ies)Before initiating the clinical trial(s),the sponsor (or the sponsor and theinvestigator, if required by theapplicable regulatoryrequirement(s)) should submit anyrequired application(s) to theappropriate authority(ies) (DCGI)
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for review, acceptance, and/orpermission (as required by the
applicable regulatoryrequirement(s)) to begin the trial(s).
Responsibilities of spon
sor
Any notification/submission should be dated and contain sufficient information to identify the protocol.
Responsibilities of spon
sor
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8. Confirmation of review by IRB/IEC
The particulars about themembers of the Investigators/Institutions Ethics Committeeincluding their names, addresses,
qualifications and experience.An undertaking that the Ethics
Committee is organized andoperates according to the GCP andthe applicable laws and regulations.
Responsibilities of sponsor
Documented approval / favorableopinion of the Ethics Committeebefore the initiation of the Study.
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The sponsor should obtain fromthe investigator/institution
documentation and dates of anyIRB/IEC reapprovals/re-evaluations with favorable opinion,and of any withdrawals or
suspensions of approval/favorableopinion.
Responsibilities of spon
sor
9.Trial Management, Data Hand
ling, and Record Keeping
The sponsor should utilizeappropriately qualified individuals tosupervise the overall conduct of the
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trial, to handle the data, to verifythe data, to conduct the statistical
analyses, and to prepare the trialreports.
Responsibilities of spon
sor
The sponsor may consider establishing an independent data-monitoring committee(IDMC) to assess the progress of a clinical trial, including the safety data and thecritical efficacy endpoints at intervals, and to recommend to the sp
onsor whether tocontinue, modify, or stop a trial.
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The IDMC should have writtenoperating procedures and maintai
n written recordsof all its meetings.
Responsibilities of spon
sor
When using electronic trial datahandling and/or remote electronic trial data systems, the sponsor should:
Maintain a security system thatprevents unauthorized access to the data. Maintain a list of the individualswho are authorized to make datachanges
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Responsibilities of sponsor
Maintain adequate backup of the data. Safeguard the blinding, if any (e.g. maintain the blinding duringdata entry andprocessing).
Responsibilities of sponsor
10.Adverse Drug Reaction ReportingThe sponsor is responsible for
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reporting all adverse drug reactions(ADRs) that are both serious and
unexpected to all investigators,IRB/IEC involved in the particulartrial and to the regulatory authority(ies).
The Sponsor should provide ADR/AEreporting forms to theInvestigator(s)/Institution(s).
Responsibilities of spon
sor
11. Information on Investigational Product(s)When planning trials, the sponsorshould ensure that sufficient safetyand efficacy data from nonclinical
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studies and/or clinical trials areavailable to support human
exposure by the route, at thedosages, for the duration, and inthe trial population to be studied.
Responsibilities of spon
sor
11. Information on Investigatio
nal Product(s)The sponsor should update the
Investigator's Brochure assignificant new information becomes
available.
Responsibilities of sponsor
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12. Manufacturing, Packaging,
Labeling, and Coding Investigational Product(s)The sponsor should ensure that theinvestigational product(s) (including
active comparator(s) and placebo, ifapplicable) is characterized asappropriate to the stage ofdevelopment of the product(s),
is manufactured in accordancewith any applicable GMP, and
Responsibilities of sponsor
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is coded and labeled in a manner that protects the blinding, if ap
plicable. In addition, the labeling shouldcomply with applicable regulatoryrequirement(s).
The sponsor should determine, for the investigational product(s),
acceptable storage temperatures, storage conditions (e.g. protecti
on from light), storage times,
Responsibilities of spon
sor
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The investigational product(s) should be packaged to prevent con
tamination andunacceptable deterioration during transport and storage.
Responsibilities of spon
sor
In blinded trials, the coding system for the investigational product(s) should include a mechanism that permits rapid identification oftheproduct(s) in case of a medicalemergency, but does not permit
undetectablebreaks of the blinding.
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Responsibilities of spon
sor
13. Supply storage and handling of investigational product
The Sponsor is responsible for supplying the Investigational Products, includingComparator(s) and Placebo if applicable.
Responsibilities of sponsor
The sponsor should not supplyan investigator/institution with theinvestigational product(s) until th
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e sponsor obtains all required documentation (e.g. approval/favoura
ble opinion from IRB/IEC and regulatory authority(ies).
Sponsor should also maintain records of the quantities of Investig
ational Productwith proper batchnumbers.
Responsibilities of sponsor
Ensure timely delivery of investigational product(s) to the investigator(s). Sponsor may take steps to ensure that the investigational product
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(s) are stable overthe period of use.
Responsibilities of sponsor
14. Safety InformationThe sponsor is responsible for theongoing safety evaluation of theinvestigational product(s).
The sponsor should promptly notifyall concerned investigator(s)/institution(s) and the regulatoryauthority(ies) of findings that couldaffect adversely the safety of
subjects, impact the conduct of thetrial, or alter the IRB/IEC's
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approval/favourable opinion tocontinue the trial.
Responsibilities of sponsor
15. Monitoringa) Monitoring of clinical trial is theresponsibility of sponsor. Thesponsor should determine the
appropriate extent and nature ofmonitoring.b) The sponsor is responsible forthe appointment of monitors/CRAwho will monitor the conduct of the
trial is in compliance with the GCP,and with the applicable regulatoryrequirement(s).
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Responsibilities of spon
sor
16. AuditIt's the responsibility of the sponsor
to perform an audit at all trial sitefor the purpose of carrying out theaudit, the sponsor may appointindividuals qualified by training and
experience to conduct audits.
Responsibilities of sponsor
The Auditors should be independent of the parties involved in thestudy and their qualifications sho
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vailable to the Regulatory Authorities
Responsibilities of sponsor
17. In Case of NoncomplianceNoncompliance with the protocol,SOPs, GCP, and/or applicableregulatory requirement(s) by an
investigator/institution, or bymember(s) of the sponsor's staffshould lead to prompt action by thesponsor to secure compliance.
Responsibilities of sponsor
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18. Premature termination or suspension of studyIn case the sponsor chooses or isrequired to terminate prematurelyor suspend the study, then thesponsor should notify the
investigator(s), institution(s), theethics committee and the regulatoryauthorities accordingly thenotification should document thereason(s) for the termination orsuspension by the sponsor or by theinvestigator /institution.
Responsibilities of spon
sor
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19. Multi-centre studiesFor multi-centre studies, the
sponsor should ensure that allinvestigators/institutions involved inthe trial in strict adherence with theprotocol and applicable GCP
guidelines.Since multicentre studies areconducted simultaneously byseveral investigators at differentinstitutions following the same
protocol, the sponsor should makespecial administrative arrangementsfor their conduct.
Responsibilities of sponsor
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The CRFs are designed to capture the required data at all multice
ntre trial sites. For those investigators who are collecting additionaldata, supplemental CRFs should also be provided that are designed t
o capture the additional data.
Responsibilities of sponsor
20. Clinical trial/Study reportsWhether the trial is completed orprematurely terminated, thesponsor should ensure that theclinical trial reports are preparedand provided to the regulatory
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agency(ies) as required by theapplicable regulatory
requirement(s).
Responsibilities of sponsor
The sponsor should also ensurethat the clinical trial reports in marketing applications meet the standards of the ICH Guideline & Schedule Y (appendix II) for Structure and Content of Clinical Study Reports.