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PRINCIPLES OF CLINICAL RESEARCH Editor : Dr. Monali Desai |
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Principles of Clinical
Research By: Monali Desai
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General
responsibilities of Investigators
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Common terms used in
Clinical Research By: Monali Desai
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Book Preview - ABC of
Research Methodology and Applied Biostatistics by
Dr.Mahendra Parikh
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Principles of
Clinical Research By: Monali Desai
India is fast becoming one of the biggest hubs for
conducting global clinical trials. In 2007, the country
conducted around 220 clinical trials, making up for less
than 2 percent of the global clinical trials. But, according
to a new research report, a number of factors such as low
cost, large patient pool, easy recruitment, strong
government support and strengthening of its intellectual
property environment will enable India to conduct nearly 5
percent of the global clinical trials by 2012. The industry
will spend 1500 crore plus on clinical trials in India, as
per Goldman Sachs, Centre watch, Goldman Sachs and McKinsey.
What has led to this dramatic shift in the location of
clinical trials? The change was made in response
to vociferous demands from multinational drug
companies and private organizations that conduct clinical
research for a relaxation of the rules for drug trials
— those necessary hurdles whose price tags can
run to 40 percent of the cost of drug
development. It has become increasingly difficult
to test drugs in Western countries, with their strict
regulations, elaborate safety and compensation
requirements, and small populations, all of which
make the recruitment of research subjects slow
and expensive.
India is a particularly attractive site for such trials
because of its genetically diverse population of
more than 1 billion people with patient pollution
suffering from infectious diseases to chronic illnesses.
As most of the healthcare costs in
India are paid 'out of pocket', a large patient population
continues to have unmet medical needs. As a result, they may
readily volunteer to participate in clinical trials to get
free treatment. Virtually all Indian doctors speak
English, and may have acquired postgraduate
qualifications abroad, primarily in Britain or
the United States. Added to these attractions are
cheap labor and low infrastructure costs, which can reduce
expenditures for clinical trials by as much as 60
percent. We, as clinicians, are interested in bringing more
clinical trials to India as, study of pharmacogenomics gives
evidence that drug response and adverse effects are based on
one’s genes.
In January 2005, the government of India enacted a new rule
that allows foreign pharmaceutical companies and other
interested parties to conduct trials of new drugs
in India at the same time that trials of the same
phase are being conducted in other countries.
This new rule supersedes a directive of India's Drugs
and Cosmetics Rules that required a "phase lag"
between India and the rest of the world.
According to the old rule, if a phase 3 study had
been completed elsewhere, only a phase 2 study was
permitted in India. Even under the new rule, phase 1
trials will not normally be permitted in India.
The old rule was designed to protect Indians from
being used as guinea pigs in the testing of
unproved drugs of foreign origin; trials of domestically
discovered drugs were not subject to this provision.
Despite the availability of infrastructure and demand in
India, the area of Clinical Research (CR) is still in its
infancy here. The country has more than half a million
practicing doctors, but fewer than 200 investigators
have been trained in good clinical practice in
regards to CR. Among some 14,000 general hospitals,
no more than 150 have the adequate infrastructure to
conduct trials, and there are fewer than a dozen
pathology laboratories that meet the criteria for
compliance with good laboratory practice. Only
about half of the large hospitals have institutional review
boards, and even these boards have not yet formulated
standard operating procedures — and they, too,
often lack the expertise with which to evaluate
protocols. Information about conflicts of
interest is neither sought nor voluntarily provided by
investigators. Furthermore, the Drugs Controller
General of India (DCGI) — the equivalent of the
U.S. Food and Drug Administration (FDA) — is
understaffed and lacks the expertise to evaluate
protocols.
In 2001, self-styled researchers working in their
own clinics formulated "vaginal pellets" of
erythromycin and tried them as contraceptive agents
in more than 790 poor, illiterate, rural women in West
Bengal. In 2003, letrozole, an anticancer drug,
was tested in more than 430 young women at a
dozen private clinics to find out whether it
promoted ovulation. All these trials took place without
regulatory approval. Adverse coverage
in the media, that trials in India are illegal and
unethical trials, could mean a loss of opportunity for
India to make a mark on the CR industry.
This calls for the development of its capacities and
capabilities in terms of infrastructure, regulatory
structure, and formulation of specialized pool of research
investigators. The aim by Indian Council of Medical Research
is to generate such professionals who can represent India in
good light, which attracts further international
collaborations. Also, this will help to organize this sector
in a well-defined mould, whose interests will have to be
catered at both local and international level. This will go
a long way in launching and boosting India as a major player
in this area of research and ensure that it does not lag
behind for want of trained manpower.
Currently, per clinicaltrials.org a central registry for all
clinical trials, there are 2208 clinical trials in
Gynecology and 128 trials in Obstetrics, with 7 being done
in India. There are over 31 pregnancy registries with
minimal inputs from obstetricians from India. While we
as Investigators in developing countries could benefit from
rigorous training in the design, conduct, and ethical
oversight of trials, which would allow us to engage more
fully in multinational clinical research at a leadership
level, pressures at work and time constraints may limit us
from attending professional courses.
In following few months I wish to share some topics which
could help some reader’s take active part in this
interesting field. The topics I have in mind are starting
with some common terminologies used in clinical research,
responsibilities of an Investigator, training of staff, FDA
rules pertaining to an investigator, registering a trial,
ethical review committees and any other topic requested by
reader’s.
References:
A K Nair (2009) Retrieved on 23 Feb
2009 from
http://www.expresspharmaonline.com/20090215/management02.shtml
Samiran Nundy, M.Chir, Chandra M. Gulhati (2005).A New
Colonialism? — Conducting Clinical Trials in India. New
England Journal of Medicine.
Volume 352, Number 16:1633-1636
Seth W. Glickman et al.( 2009)
Ethical and Scientific Implications of the Globalization of
Clinical Research.
New
England Journal of Medicine. Volume 360, Number 8 :816-823
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General responsibilities of Investigators:
An Investigator is responsible for ensuring that an
investigation is conducted according to the signed
investigator statement, the investigational plan, and
applicable regulations; for protecting the rights, safety,
and welfare of subjects under the investigator’s care; and
for the control of drugs under investigation. An
investigator shall, in accordance with the Code of Federal
Regulations and ICH/GCP Guidelines, obtain the informed
consent of each human subject to whom the drug is
administered, except as provided in CFR50.23.
The Investigator shall:
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Maintain IRB approval to conduct
the clinical trial and report to the IRB as required.
The IRB must assume continued responsibility for the
study and review the research on at least an annual
basis.
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Maintain a file of all
communications with the IRB on issues related to the
clinical trial.
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Complete, sign, and return to
Kendle a Form FDA 1572 including a current CV for the
Principal Investigator, Sub-Investigator(s), and any
study personnel involved, if listed.
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Conduct the study in strict
adherence to the protocol.
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Supervise the use of the study drug
as outlined in the protocol. The study drug may be
provided by medical doctors or study staff working under
the supervision of an Investigator who is a medical
doctor.
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Store the study drug in a secure
and locked area with limited access. The storage and
custody of the study drug are responsibilities of the
Investigator.
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Maintain adequate records of the
receipt and disposition of all study drug (including
dates, quantities and use by the study subjects).
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Inform each subject of the risks
and benefits of participating in the study and obtain a
properly signed, dated and witnessed (if applicable)
informed consent form for each subject before he or she
begins any study–related procedures.
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Document all adverse events on the
CRF; document all Serious Adverse Events (SAEs) on the
SAE Form and immediately notify Kendle via phone and
fax.
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Report all SAEs to the IRB.
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Maintain a master log of all
subjects screened for the study and establish a system
to alert clinic staff of scheduled follow-up visits;
provide clinic staff with a system for contacting study
subjects who do not return for scheduled follow-up.
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Document and maintain accurate CRFs
for all subjects. As required, sign forms ascertaining
the accuracy of data recorded. Storage and custody of
all study related records are the responsibility of the
Investigator.
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Retain the copies of the CRFs, the
original informed consent forms and all study-related
documentation of the study site for at least 2 years
after the last approval of a marketing application in an
ICH region and until there are no pending or
contemplated marketing applications in an ICH region or
at least 2 years have elapsed since the formal
discontinuation of clinical development of the
investigational product. It is the responsibility of the
sponsor to inform the investigator/institution as to
when these documents no longer need to be retained.
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Make available all study subjects’
records to staff and representatives from monitoring or
regulatory office.
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Be thoroughly familiar with the
properties of the investigational agent as described in
the Clinical Investigator Brochure.
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Ensure that sufficient time is
allotted to conduct and complete the study; ensure
adequate staff and facilities are available for the
duration of the study; and ensure that other studies do
not divert essential subjects or facilities from the
study at hand.
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Provide information to all staff
members involved with the study or with other elements
of the subject’s management.
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Ensure that the confidentiality of
all information about the subjects and the information
supplied by Kendle is respected by all persons.
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Common terms used in Clinical Research:
Rules and principles for Clinical trials were first
introduced in
Avicenna's
The
Canon of Medicine in 1025 AD, which still form
the basis of modern clinical trials:
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"The drug must be free from any extraneous accidental
quality."
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"It must be used on a simple, not a composite, disease."
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"The drug must be tested with two contrary types of
diseases, because sometimes a drug cures one disease by
its essential qualities and another by its accidental
ones."
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"The quality of the drug must correspond to the strength
of the disease. For example, there are some drugs whose
heat is less than the coldness of certain diseases, so
that they would have no effect on them."
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"The time of action must be observed, so that essence
and accident are not confused."
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"The effect of the drug must be seen to occur constantly
or in many cases, for if this did not happen, it was an
accidental effect."
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"The experimentation must be done with the human body,
for testing a drug on a lion or a horse might not prove
anything about its effect on man."
Coordination between Europe, Japan and the United States led
to a joint regulatory-industry initiative on international
harmonization named after 1990 as the
International Conference on Harmonization of Technical
Requirements for Registration of Pharmaceuticals for Human
Use (ICH)
ICH
HARMONISED TRIPARTITE GUIDELINE. The guidelines
are continuously being updated and are have open excess to
all at
http://www.ich.org/cache/compo/276-254-1.html
Following are some common terms used in clinical trials.
ADVERSE REACTION: (Adverse Event.) An
unwanted effect caused by the administration of drugs. Onset
may be sudden or develop over time.
CLINICAL: Pertaining to or founded on
observation and treatment of participants, as distinguished
from theoretical or basic science.
CLINICAL INVESTIGATOR/ Principal
Investigator: A medical researcher in charge of carrying
out a clinical trial's protocol. Sub Investigator: A medical
researcher assisting the PI.
CLINICAL TRIAL: A clinical trial is a
research study to answer specific questions about vaccines
or new therapies or new ways of using known treatments.
Clinical trials (also called medical research and research
studies) are used to determine whether new drugs or
treatments are both safe and effective. Carefully conducted
clinical trials are the fastest and safest way to find
treatments that work in people. Trials are in four phases:
Phase I –IV.
COMMUNITY-BASED CLINICAL TRIAL (CBCT): A
clinical trial conducted primarily through primary-care
physicians rather than academic research facilities.
COMPASSIONATE USE: A method of
providing experimental therapeutics prior to final FDA
approval for use in humans. This procedure is used with very
sick individuals who have no other treatment options. Often,
case-by-case approval must be obtained from the FDA for
"compassionate use" of a drug or therapy.
COMPLEMENTARY AND ALTERNATIVE THERAPY:
Broad range of healing philosophies, approaches, and
therapies that Western (conventional) medicine does not
commonly use to promote well-being or treat health
conditions. Examples include acupuncture, herbs, etc.
CRA: A clinical research associate ensures
compliance with the
clinical trial protocol, checks clinical site
activities, makes on-site visits, reviews
Case
Report Forms (CRFs)
and communicates with clinical research investigators. A
clinical research associate is usually required to possess
an
academic degree in Life Sciences and needs to
have a good knowledge of
Good
clinical practice and local regulations.
CASE REPORT FORM: A Case Report Form (or CRF) is a paper or
electronic questionnaire specifically used in clinical trial
research. The Case Report Form is the tool used by the
sponsor of the
clinical trial
to collect data from each participating site. All data on
each patient participating in a clinical trial are held
and/or documented in the CRF, including
adverse events
CRO: A Contract Research Organization (CRO) is a service
organization that provides support to the
pharmaceutical/biotech industry in the drug and medical
device research & development process.
DATA SAFETY AND MONITORING BOARD (DSMB): An independent
committee, composed of community representatives and
clinical research experts, that reviews data while a
clinical trial is in progress to ensure that participants
are not exposed to undue risk. A DSMB may recommend that a
trial be stopped if there are safety concerns or if the
trial objectives have been achieved.
DOSE-RANGING STUDY: A clinical trial in
which two or more doses of an agent (such as a drug) are
tested against each other to determine which dose works best
and is least harmful.
DOUBLE-BLIND STUDY: A clinical trial
design in which neither the participating individuals nor
the study staff knows which participants are receiving the
experimental drug and which are receiving a placebo (or
another therapy). Double-blind trials are thought to produce
objective results, since the expectations of the doctor and
the participant about the experimental drug do not affect
the outcome; also called double-masked study.
DRUG-DRUG INTERACTION: A modification of the effect of a
drug when administered with another drug. The effect may be
an increase or a decrease in the action of either substance,
or it may be an adverse effect that is not normally
associated with either drug.
EFFICACY: (Of a drug or treatment).
The maximum ability of a drug or treatment to produce a
result regardless of dosage. A drug passes efficacy trials
if it is effective at the dose tested and against the
illness for which it is prescribed. In the procedure
mandated by the FDA, Phase II clinical trials gauge
efficacy, and Phase III trials confirm it .
ENDPOINT: Overall outcome that the
protocol is designed to evaluate. Common endpoints are
severe toxicity, disease progression, or death.
ENROLLING: The act of signing up
participants into a study. Generally this process involves
evaluating a participant with respect to the eligibility
criteria of the study and going through the
informed consent process.
EXPERIMENTAL DRUG: A drug that is
not FDA licensed for use in humans, or as a treatment for a
particular condition
FROM 1572: Form submitted by Principal
Investigator which contains contact details, CV, financial
disclosure, conflict of interest and agreement to conduct
the study with ICH GCP guidelines
INCLUSION/EXCLUSION CRITERIA: The medical or social
standards determining whether a person may or may not be
allowed to enter a clinical trial. These criteria are based
on such factors as age, gender, the type and stage of a
disease, previous treatment history, and other medical
conditions. It is important to note that inclusion and
exclusion criteria are not used to reject people personally,
but rather to identify appropriate participants and keep
them safe.
INSTITUTIONAL REVIEW BOARD (IRB):
1. A committee of physicians, statisticians, researchers,
community advocates, and others that ensures that a clinical
trial is ethical and that the rights of study participants
are protected. All clinical trials in the U.S. must be
approved by an IRB before they begin. 2. Every institution
that conducts or supports biomedical or behavioral research
involving human participants must, by federal regulation,
have an IRB that initially approves and periodically reviews
the research in order to protect the rights of human
participants.
INTENT TO TREAT: Analysis of clinical
trial results that includes all data from participants in
the groups to which they were randomized even if they never
received the treatment.
INVESTIGATIONAL NEW DRUG: A
new drug, antibiotic drug, or biological drug that is used
in a clinical investigation. It also includes a biological
product used in vitro for diagnostic purposes.
NEW DRUG APPLICATION (NDA): An application
submitted by the manufacturer of a drug to the FDA - after
clinical trials have been completed - for a license to
market the drug for a specified indication.
OFF-LABEL USE: A drug prescribed for
conditions other than those approved by the FDA.
ORPHAN DRUGS: An FDA category that
refers to medications used to treat diseases and conditions
that occur rarely. There is little financial incentive for
the pharmaceutical industry to develop medications for these
diseases or conditions. Orphan drug status, however, gives a
manufacturer specific financial incentives to develop and
provide such medications.
PEER REVIEW: Review of a clinical trial
by experts chosen by the study sponsor. These experts review
the trials for scientific merit, participant safety, and
ethical considerations.
PHARMACOKINETICS: The
processes (in a living organism) of absorption,
distribution, metabolism, and excretion of a drug or
vaccine.
PHASE I TRIALS: Initial studies to
determine the metabolism and pharmacologic actions of drugs
in humans, the side effects associated with increasing
doses, and to gain early evidence of effectiveness; may
include healthy participants and/or patients.
PHASE II TRIALS: Controlled clinical
studies conducted to evaluate the effectiveness of the drug
for a particular indication or indications in patients with
the disease or condition under study and to determine the
common short-term side effects and risks.
PHASE III TRIALS: Expanded controlled
and uncontrolled trials after preliminary evidence
suggesting effectiveness of the drug has been obtained, and
are intended to gather additional information to evaluate
the overall benefit-risk relationship of the drug and
provide and adequate basis for physician labeling.
PHASE IV TRIALS: Post-marketing
studies to delineate additional information including the
drug's risks, benefits, and optimal use.
PRECLINICAL: Refers to the testing
of experimental drugs in the test tube or in animals - the
testing that occurs before trials in humans may be carried
out.
PROTOCOL: A study plan on which all
clinical trials are based. The plan is carefully designed to
safeguard the health of the participants as well as answer
specific research questions. A protocol describes what types
of people may participate in the trial; the schedule of
tests, procedures, medications, and dosages; and the length
of the study. While in a clinical trial, participants
following a protocol are seen regularly by the research
staff to monitor their health and to determine the safety
and effectiveness of their treatment.
QUERY: Any clarification sought from
the clinical monitor, data associates or sponsor
RECRUITING: The period, during which a trial is attempting
to identify and enroll participants for the study.
Recruitment activities can include advertising and other
ways of solicting interest from possible participants.
RISK-BENEFIT RATIO: The risk to
individual participants versus the potential benefits. The
risk/benefit ratio may differ depending on the condition
being treated. .
STUDY CORDINATOR: They are employed by
Principal investigators.
Study coordinators work directly with study volunteers,
providing them safety and protection while collecting and
managing the study data. They promote, advertise, and
conduct telephone and face-to-face screenings to recruit
volunteers. During the study process, they assess volunteer
condition and coordinate ongoing clinical/laboratory testing
and physical exams.
STUDY ENDPOINT: A primary or secondary
outcome used to judge the effectiveness of a treatment.
STUDY TYPE: The primary
investigative techniques used in an observational protocol;
types are Purpose, Duration, Selection, and Timing.
TOXICITY: An adverse effect produced
by a drug that is detrimental to the participant's health.
The level of toxicity associated with a drug will vary
depending on the condition which the drug is used to treat.
TREATMENT IND: IND stands for
Investigational New Drug application, which is part of the
process to get approval from the FDA for marketing a new
prescription drug in the U.S. It makes promising new drugs
available to desperately ill participants as early in the
drug development process as possible. Treatment INDs are
made available to participants before general marketing
begins, typically during Phase III studies. To be considered
for a treatment IND a participant cannot be eligible to be
in the definitive clinical trial.
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