Page 1

NOTE FOR GUIDANCE ON GOOD CLINICAL PRACTICE

(CPMP/ICH/135/95)

TRANSMISSION TO CPMP

July 1996

FINAL APPROVAL BY CPMP

July 1996

DATE FOR COMING INTO OPERATION

January 1997

POST STEP ERRATA (linguistic minor corrections)

July 2002

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2

GUIDELINE FOR GOOD CLINICAL PRACTICE

ICH Harmonised Tripartite Guideline

INTRODUCTION ....................................................................................................................5

1. GLOSSARY.......................................................................................................................5

1.1

A

DVERSE

D

RUG

R

EACTION

(ADR)...............................................................................5

1.2

A

DVERSE

E

VENT

(AE)..................................................................................................5

1.3

A

MENDMENT

(

TO THE PROTOCOL

) ................................................................................6

1.4

A

PPLICABLE

R

EGULATORY

R

EQUIREMENT

(

S

)...............................................................6

1.5

A

PPROVAL

(

IN RELATION TO

I

NSTITUTIONAL

R

EVIEW

B

OARDS

)...................................6

1.6

A

UDIT

...........................................................................................................................6

1.7

A

UDIT

C

ERTIFICATE

......................................................................................................6

1.8

A

UDIT

R

EPORT

..............................................................................................................6

1.9

A

UDIT

T

RAIL

................................................................................................................6

1.10 B

LINDING

/M

ASKING

.....................................................................................................6

1.11 C

ASE

R

EPORT

F

ORM

(CRF)..........................................................................................6

1.12 C

LINICAL

T

RIAL

/S

TUDY

...............................................................................................7

1.13 C

LINICAL

T

RIAL

/S

TUDY

R

EPORT

..................................................................................7

1.14 C

OMPARATOR

(P

RODUCT

) ............................................................................................7

1.15 C

OMPLIANCE

(

IN RELATION TO TRIALS

)........................................................................7

1.16 C

ONFIDENTIALITY

........................................................................................................7

1.17 C

ONTRACT

....................................................................................................................7

1.18 C

OORDINATING

C

OMMITTEE

.........................................................................................7

1.19 C

OORDINATING

I

NVESTIGATOR

....................................................................................7

1.20 C

ONTRACT

R

ESEARCH

O

RGANIZATION

(CRO).............................................................7

1.21 D

IRECT

A

CCESS

............................................................................................................8

1.22 D

OCUMENTATION

.........................................................................................................8

1.23 E

SSENTIAL

D

OCUMENTS

...............................................................................................8

1.24 G

OOD

C

LINICAL

P

RACTICE

(GCP)................................................................................8

1.25 I

NDEPENDENT

D

ATA

-M

ONITORING

C

OMMITTEE

(IDMC) (D

ATA AND

S

AFETY

M

ONITORING

B

OARD

, M

ONITORING

C

OMMITTEE

, D

ATA

M

ONITORING

C

OMMITTEE

).............8

1.26 I

MPARTIAL

W

ITNESS

.....................................................................................................8

1.27 I

NDEPENDENT

E

THICS

C

OMMITTEE

(IEC).....................................................................8

1.28 I

NFORMED

C

ONSENT

.....................................................................................................9

1.29 I

NSPECTION

...................................................................................................................9

1.30 I

NSTITUTION

(

MEDICAL

)................................................................................................9

1.31 I

NSTITUTIONAL

R

EVIEW

B

OARD

(IRB).........................................................................9

1.32 I

NTERIM

C

LINICAL

T

RIAL

/S

TUDY

R

EPORT

....................................................................9

1.33 I

NVESTIGATIONAL

P

RODUCT

.........................................................................................9

1.34 I

NVESTIGATOR

..............................................................................................................9

1.35 I

NVESTIGATOR

/ I

NSTITUTION

.......................................................................................9

1.36 I

NVESTIGATOR

'

S

B

ROCHURE

.......................................................................................10

1.37 L

EGALLY

A

CCEPTABLE

R

EPRESENTATIVE

..................................................................10

1.38 M

ONITORING

..............................................................................................................10

1.39 M

ONITORING

R

EPORT

.................................................................................................10

1.40 M

ULTICENTRE

T

RIAL

..................................................................................................10

1.41 N

ONCLINICAL

S

TUDY

..................................................................................................10

1.42 O

PINION

(

IN RELATION TO

I

NDEPENDENT

E

THICS

C

OMMITTEE

)..................................10

1.43 O

RIGINAL

M

EDICAL

R

ECORD

.....................................................................................10

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3

1.44 P

ROTOCOL

..................................................................................................................10

1.45 P

ROTOCOL

A

MENDMENT

............................................................................................10

1.46 Q

UALITY

A

SSURANCE

(QA) .......................................................................................11

1.47 Q

UALITY

C

ONTROL

(QC)............................................................................................11

1.48 R

ANDOMIZATION

........................................................................................................11

1.49 R

EGULATORY

A

UTHORITIES

.......................................................................................11

1.50 S

ERIOUS

A

DVERSE

E

VENT

(SAE)

OR

S

ERIOUS

A

DVERSE

D

RUG

R

EACTION

(S

ERIOUS

ADR) 11

1.51 S

OURCE

D

ATA

............................................................................................................11

1.52 S

OURCE

D

OCUMENTS

.................................................................................................11

1.53 S

PONSOR

.....................................................................................................................12

1.54 S

PONSOR

-I

NVESTIGATOR

............................................................................................12

1.55 S

TANDARD

O

PERATING

P

ROCEDURES

(SOP

S

)............................................................12

1.56 S

UBINVESTIGATOR

......................................................................................................12

1.57 S

UBJECT

/T

RIAL

S

UBJECT

............................................................................................12

1.58 S

UBJECT

I

DENTIFICATION

C

ODE

.................................................................................12

1.59 T

RIAL

S

ITE

..................................................................................................................12

1.60 U

NEXPECTED

A

DVERSE

D

RUG

R

EACTION

..................................................................12

1.61 V

ULNERABLE

S

UBJECTS

.............................................................................................13

1.62 W

ELL

-

BEING

(

OF THE TRIAL SUBJECTS

) ......................................................................13

2. THE PRINCIPLES OF ICH GCP.................................................................................13

3.1

R

ESPONSIBILITIES

.......................................................................................................14

3.2

C

OMPOSITION

, F

UNCTIONS AND

O

PERATIONS

............................................................15

3.3

P

ROCEDURES

...............................................................................................................16

3.4

R

ECORDS

....................................................................................................................17

4. INVESTIGATOR............................................................................................................17

4.1

I

NVESTIGATOR

'

S

Q

UALIFICATIONS AND

A

GREEMENTS

...............................................17

4.2

A

DEQUATE

R

ESOURCES

..............................................................................................17

4.3

M

EDICAL

C

ARE OF

T

RIAL

S

UBJECTS

...........................................................................18

4.4

C

OMMUNICATION WITH

IRB/IEC ...............................................................................18

4.5

C

OMPLIANCE WITH

P

ROTOCOL

...................................................................................18

4.6

I

NVESTIGATIONAL

P

RODUCT

(

S

)..................................................................................19

4.7

R

ANDOMIZATION

P

ROCEDURES AND

U

NBLINDING

.....................................................19

4.8

I

NFORMED

C

ONSENT OF

T

RIAL

S

UBJECTS

...................................................................20

4.9

R

ECORDS AND

R

EPORTS

.............................................................................................23

4.10 P

ROGRESS

R

EPORTS

....................................................................................................24

4.11 S

AFETY

R

EPORTING

....................................................................................................24

4.12 P

REMATURE

T

ERMINATION OR

S

USPENSION OF A

T

RIAL

............................................24

4.13 F

INAL

R

EPORT

(

S

)

BY

I

NVESTIGATOR

..........................................................................25

5. SPONSOR........................................................................................................................25

5.1

Q

UALITY

A

SSURANCE AND

Q

UALITY

C

ONTROL

.........................................................25

5.2

C

ONTRACT

R

ESEARCH

O

RGANIZATION

(CRO)...........................................................25

5.3

M

EDICAL

E

XPERTISE

..................................................................................................25

5.4

T

RIAL

D

ESIGN

.............................................................................................................26

5.5

T

RIAL

M

ANAGEMENT

, D

ATA

H

ANDLING

,

AND

R

ECORD

K

EEPING

..............................26

5.6

I

NVESTIGATOR

S

ELECTION

..........................................................................................27

5.7

A

LLOCATION OF

R

ESPONSIBILITIES

.............................................................................28

5.8

C

OMPENSATION TO

S

UBJECTS AND

I

NVESTIGATORS

...................................................28

5.9

F

INANCING

..................................................................................................................28

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4

5.10 N

OTIFICATION

/S

UBMISSION TO

R

EGULATORY

A

UTHORITY

(

IES

).................................28

5.11 C

ONFIRMATION OF

R

EVIEW BY

IRB/IEC....................................................................28

5.12 I

NFORMATION ON

I

NVESTIGATIONAL

P

RODUCT

(

S

)......................................................29

5.13 M

ANUFACTURING

, P

ACKAGING

, L

ABELLING

,

AND

C

ODING

I

NVESTIGATIONAL

P

RODUCT

(

S

)...........................................................................................................................29

5.14 S

UPPLYING AND

H

ANDLING

I

NVESTIGATIONAL

P

RODUCT

(

S

)......................................30

5.15 R

ECORD

A

CCESS

.........................................................................................................30

5.16 S

AFETY

I

NFORMATION

................................................................................................31

5.17 A

DVERSE

D

RUG

R

EACTION

R

EPORTING

......................................................................31

5.18 M

ONITORING

..............................................................................................................31

5.19 A

UDIT

.........................................................................................................................34

5.20 N

ONCOMPLIANCE

........................................................................................................35

5.21 P

REMATURE

T

ERMINATION OR

S

USPENSION OF A

T

RIAL

............................................35

5.22 C

LINICAL

T

RIAL

/S

TUDY

R

EPORTS

..............................................................................35

5.23 M

ULTICENTRE

T

RIALS

................................................................................................35

6. CLINICAL TRIAL PROTOCOL AND PROTOCOL AMENDMENT(S)...............36

6.1

G

ENERAL

I

NFORMATION

.............................................................................................36

6.2

B

ACKGROUND

I

NFORMATION

.....................................................................................36

6.3 T

RIAL

O

BJECTIVES AND

P

URPOSE

...............................................................................37

6.4

T

RIAL

D

ESIGN

.............................................................................................................37

6.5

S

ELECTION AND

W

ITHDRAWAL OF

S

UBJECTS

.............................................................37

6.6

T

REATMENT OF

S

UBJECTS

...........................................................................................38

6.7

A

SSESSMENT OF

E

FFICACY

.........................................................................................38

6.8

A

SSESSMENT OF

S

AFETY

.............................................................................................38

6.9

S

TATISTICS

.................................................................................................................38

6.10 D

IRECT

A

CCESS TO

S

OURCE

D

ATA

/D

OCUMENTS

........................................................39

6.11 Q

UALITY

C

ONTROL AND

Q

UALITY

A

SSURANCE

.........................................................39

6.12 E

THICS

........................................................................................................................39

6.13 D

ATA

H

ANDLING AND

R

ECORD

K

EEPING

...................................................................39

6.14 F

INANCING AND

I

NSURANCE

.......................................................................................39

6.15 P

UBLICATION

P

OLICY

.................................................................................................39

6.16 S

UPPLEMENTS

.............................................................................................................39

7. INVESTIGATORÍS BROCHURE................................................................................39

7.1

I

NTRODUCTION

...........................................................................................................39

7.2

G

ENERAL

C

ONSIDERATIONS

.......................................................................................40

7.3 C

ONTENTS OF THE

I

NVESTIGATORÍS

B

ROCHURE

..............................................................40

7.5

APPENDIX 2:............................................................................................................46

8. ESSENTIAL DOCUMENTS FOR THE CONDUCT OF A CLINICAL TRIAL....47

8.1

I

NTRODUCTION

...........................................................................................................47

8.2

B

EFORE THE

C

LINICAL

P

HASE OF THE

T

RIAL

C

OMMENCES

.........................................48

8.4

A

FTER

C

OMPLETION OR

T

ERMINATION OF THE

T

RIAL

................................................58

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5

GUIDELINE FOR GOOD CLINICAL PRACTICE

ICH Harmonised Tripartite Guideline

INTRODUCTION

Good Clinical Practice (GCP) is an international ethical and scientific quality standard for

designing, conducting, recording and reporting trials that involve the participation of human

subjects. Compliance with this standard provides public assurance that the rights, safety and

well-being of trial subjects are protected, consistent with the principles that have their origin

in the Declaration of Helsinki, and that the clinical trial data are credible.

The objective of this ICH GCP Guideline is to provide a unified standard for the European

Union (EU), Japan and the United States to facilitate the mutual acceptance of clinical data by

the regulatory authorities in these jurisdictions.

The guideline was developed with consideration of the current good clinical practices of the

European Union, Japan, and the United States, as well as those of Australia, Canada, the

Nordic countries and the World Health Organization (WHO).

This guideline should be followed when generating clinical trial data that are intended to be

submitted to regulatory authorities.

The principles established in this guideline may also be applied to other clinical investigations

that may have an impact on the safety and well-being of human subjects.

1. GLOSSARY

1.1 Adverse Drug Reaction (ADR)

In the pre-approval clinical experience with a new medicinal product or its new usages,

particularly as the therapeutic dose(s) may not be established: all noxious and unintended

responses to a medicinal product related to any dose should be considered adverse drug

reactions. The phrase responses to a medicinal product means that a causal relationship

between a medicinal product and an adverse event is at least a reasonable possibility, i.e. the

relationship cannot be ruled out.

Regarding marketed medicinal products: a response to a drug which is noxious and

unintended and which occurs at doses normally used in man for prophylaxis, diagnosis, or

therapy of diseases or for modification of physiological function (see the ICH Guideline for

Clinical Safety Data Management: Definitions and Standards for Expedited Reporting).

1.2 Adverse Event (AE)

Any untoward medical occurrence in a patient or clinical investigation subject administered a

pharmaceutical product and which does not necessarily have a causal relationship with this

treatment. An adverse event (AE) can therefore be any unfavourable and unintended sign

(including an abnormal laboratory finding), symptom, or disease temporally associated with

the use of a medicinal (investigational) product, whether or not related to the medicinal

(investigational) product (see the ICH Guideline for Clinical Safety Data Management:

Definitions and Standards for Expedited Reporting).

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1.3 Amendment (to the protocol)

See Protocol Amendment.

1.4 Applicable Regulatory Requirement(s)

Any law(s) and regulation(s) addressing the conduct of clinical trials of investigational

products.

1.5 Approval (in relation to Institutional Review Boards)

The affirmative decision of the IRB that the clinical trial has been reviewed and may be

conducted at the institution site within the constraints set forth by the IRB, the institution,

Good Clinical Practice (GCP), and the applicable regulatory requirements.

1.6 Audit

A systematic and independent examination of trial related activities and documents to

determine whether the evaluated trial related activities were conducted, and the data were

recorded, analyzed and accurately reported according to the protocol, sponsor's standard

operating procedures (SOPs), Good Clinical Practice (GCP), and the applicable regulatory

requirement(s).

1.7 Audit Certificate

A declaration of confirmation by the auditor that an audit has taken place.

1.8 Audit Report

A written evaluation by the sponsor's auditor of the results of the audit.

1.9 Audit Trail

Documentation that allows reconstruction of the course of events.

1.10

Blinding/Masking

A procedure in which one or more parties to the trial are kept unaware of the treatment

assignment(s). Single-blinding usually refers to the subject(s) being unaware, and double-

blinding usually refers to the subject(s), investigator(s), monitor, and, in some cases, data

analyst(s) being unaware of the treatment assignment(s).

1.11

Case Report Form (CRF)

A printed, optical, or electronic document designed to record all of the protocol required

information to be reported to the sponsor on each trial subject.

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1.12

Clinical Trial/Study

Any investigation in human subjects intended to discover or verify the clinical,

pharmacological and/or other pharmacodynamic effects of an investigational product(s),

and/or to identify any adverse reactions to an investigational product(s), and/or to study

absorption, distribution, metabolism, and excretion of an investigational product(s) with the

object of ascertaining its safety and/or efficacy. The terms clinical trial and clinical study are

synonymous.

1.13

Clinical Trial/Study Report

A written description of a trial/study of any therapeutic, prophylactic, or diagnostic agent

conducted in human subjects, in which the clinical and statistical description, presentations,

and analyses are fully integrated into a single report (see the ICH Guideline for Structure and

Content of Clinical Study Reports).

1.14

Comparator (Product)

An investigational or marketed product (i.e., active control), or placebo, used as a reference in

a clinical trial.

1.15

Compliance (in relation to trials)

Adherence to all the trial-related requirements, Good Clinical Practice (GCP) requirements,

and the applicable regulatory requirements.

1.16

Confidentiality

Prevention of disclosure, to other than authorized individuals, of a sponsor's proprietary

information or of a subject's identity.

1.17

Contract

A written, dated, and signed agreement between two or more involved parties that sets out

any arrangements on delegation and distribution of tasks and obligations and, if appropriate,

on financial matters. The protocol may serve as the basis of a contract.

1.18

Coordinating Committee

A committee that a sponsor may organize to coordinate the conduct of a multicentre trial.

1.19

Coordinating Investigator

An investigator assigned the responsibility for the coordination of investigators at different

centres participating in a multicentre trial.

1.20

Contract Research Organization (CRO)

A person or an organization (commercial, academic, or other) contracted by the sponsor to

perform one or more of a sponsor's trial-related duties and functions.

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1.21

Direct Access

Permission to examine, analyze, verify, and reproduce any records and reports that are

important to evaluation of a clinical trial. Any party (e.g., domestic and foreign regulatory

authorities, sponsor's monitors and auditors) with direct access should take all reasonable

precautions within the constraints of the applicable regulatory requirement(s) to maintain the

confidentiality of subjects' identities and sponsorís proprietary information.

1.22

Documentation

All records, in any form (including, but not limited to, written, electronic, magnetic, and

optical records, and scans, x-rays, and electrocardiograms) that describe or record the

methods, conduct, and/or results of a trial, the factors affecting a trial, and the actions taken.

1.23

Essential Documents

Documents which individually and collectively permit evaluation of the conduct of a study

and the quality of the data produced (see 8. Essential Documents for the Conduct of a Clinical

Trial).

1.24

Good Clinical Practice (GCP)

A standard for the design, conduct, performance, monitoring, auditing, recording, analyses,

and reporting of clinical trials that provides assurance that the data and reported results are

credible and accurate, and that the rights, integrity, and confidentiality of trial subjects are

protected.

1.25

Independent Data-Monitoring Committee (IDMC) (Data and Safety Monitoring

Board, Monitoring Committee, Data Monitoring Committee)

An independent data-monitoring committee that may be established by the sponsor to assess

at intervals the progress of a clinical trial, the safety data, and the critical efficacy endpoints,

and to recommend to the sponsor whether to continue, modify, or stop a trial.

1.26

Impartial Witness

A person, who is independent of the trial, who cannot be unfairly influenced by people

involved with the trial, who attends the informed consent process if the subject or the

subjectís legally acceptable representative cannot read, and who reads the informed consent

form and any other written information supplied to the subject.

1.27

Independent Ethics Committee (IEC)

An independent body (a review board or a committee, institutional, regional, national, or

supranational), constituted of medical professionals and non-medical members, whose

responsibility it is to ensure the protection of the rights, safety and well-being of human

subjects involved in a trial and to provide public assurance of that protection, by, among other

things, reviewing and approving / providing favourable opinion on, the trial protocol, the

suitability of the investigator(s), facilities, and the methods and material to be used in

obtaining and documenting informed consent of the trial subjects.

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The legal status, composition, function, operations and regulatory requirements pertaining to

Independent Ethics Committees may differ among countries, but should allow the

Independent Ethics Committee to act in agreement with GCP as described in this guideline.

1.28

Informed Consent

A process by which a subject voluntarily confirms his or her willingness to participate in a

particular trial, after having been informed of all aspects of the trial that are relevant to the

subject's decision to participate. Informed consent is documented by means of a written,

signed and dated informed consent form.

1.29

Inspection

The act by a regulatory authority(ies) of conducting an official review of documents,

facilities, records, and any other resources that are deemed by the authority(ies) to be related

to the clinical trial and that may be located at the site of the trial, at the sponsor's and/or

contract research organizationís (CROís) facilities, or at other establishments deemed

appropriate by the regulatory authority(ies).

1.30

Institution (medical)

Any public or private entity or agency or medical or dental facility where clinical trials are

conducted.

1.31

Institutional Review Board (IRB)

An independent body constituted of medical, scientific, and non-scientific members, whose

responsibility is to ensure the protection of the rights, safety and well-being of human subjects

involved in a trial by, among other things, reviewing, approving, and providing continuing

review of trial protocol and amendments and of the methods and material to be used in

obtaining and documenting informed consent of the trial subjects.

1.32

Interim Clinical Trial/Study Report

A report of intermediate results and their evaluation based on analyses performed during the

course of a trial.

1.33

Investigational Product

A pharmaceutical form of an active ingredient or placebo being tested or used as a reference

in a clinical trial, including a product with a marketing authorization when used or assembled

(formulated or packaged) in a way different from the approved form, or when used for an

unapproved indication, or when used to gain further information about an approved use.

1.34

Investigator

A person responsible for the conduct of the clinical trial at a trial site. If a trial is conducted by

a team of individuals at a trial site, the investigator is the responsible leader of the team and

may be called the principal investigator. See also Subinvestigator.

1.35

Investigator / Institution

An expression meaning "the investigator and/or institution, where required by the applicable

regulatory requirements".

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1.36

Investigator's Brochure

A compilation of the clinical and nonclinical data on the investigational product(s) which is

relevant to the study of the investigational product(s) in human subjects (see 7. Investigatorís

Brochure).

1.37

Legally Acceptable Representative

An individual or juridical or other body authorized under applicable law to consent, on behalf

of a prospective subject, to the subject's participation in the clinical trial.

1.38

Monitoring

The act of overseeing the progress of a clinical trial, and of ensuring that it is conducted,

recorded, and reported in accordance with the protocol, Standard Operating Procedures

(SOPs), Good Clinical Practice (GCP), and the applicable regulatory requirement(s).

1.39

Monitoring Report

A written report from the monitor to the sponsor after each site visit and/or other trial-related

communication according to the sponsorís SOPs.

1.40

Multicentre Trial

A clinical trial conducted according to a single protocol but at more than one site, and

therefore, carried out by more than one investigator.

1.41

Nonclinical Study

Biomedical studies not performed on human subjects.

1.42

Opinion (in relation to Independent Ethics Committee)

The judgement and/or the advice provided by an Independent Ethics Committee (IEC).

1.43

Original Medical Record

See Source Documents.

1.44

Protocol

A document that describes the objective(s), design, methodology, statistical considerations,

and organization of a trial. The protocol usually also gives the background and rationale for

the trial, but these could be provided in other protocol referenced documents. Throughout the

ICH GCP Guideline the term protocol refers to protocol and protocol amendments.

1.45

Protocol Amendment

A written description of a change(s) to or formal clarification of a protocol.

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1.46

Quality Assurance (QA)

All those planned and systematic actions that are established to ensure that the trial is

performed and the data are generated, documented (recorded), and reported in compliance

with Good Clinical Practice (GCP) and the applicable regulatory requirement(s).

1.47

Quality Control (QC)

The operational techniques and activities undertaken within the quality assurance system to

verify that the requirements for quality of the trial-related activities have been fulfilled.

1.48

Randomization

The process of assigning trial subjects to treatment or control groups using an element of

chance to determine the assignments in order to reduce bias.

1.49

Regulatory Authorities

Bodies having the power to regulate. In the ICH GCP guideline the expression Regulatory

Authorities includes the authorities that review submitted clinical data and those that conduct

inspections (see 1.29). These bodies are sometimes referred to as competent authorities.

1.50

Serious Adverse Event (SAE) or Serious Adverse Drug Reaction (Serious ADR)

Any untoward medical occurrence that at any dose:

•

results in death,

•

is life-threatening,

•

requires inpatient hospitalization or prolongation of existing hospitalization,

•

results in persistent or significant disability/incapacity,

or

•

is a congenital anomaly/birth defect

(see the ICH Guideline for Clinical Safety Data Management: Definitions and Standards for

Expedited Reporting).

1.51

Source Data

All information in original records and certified copies of original records of clinical findings,

observations, or other activities in a clinical trial necessary for the reconstruction and

evaluation of the trial. Source data are contained in source documents (original records or

certified copies).

1.52

Source Documents

Original documents, data, and records (e.g., hospital records, clinical and office charts,

laboratory notes, memoranda, subjects' diaries or evaluation checklists, pharmacy dispensing

records, recorded data from automated instruments, copies or transcriptions certified after

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verification as being accurate copies, microfiches, photographic negatives, microfilm or

magnetic media, x-rays, subject files, and records kept at the pharmacy, at the laboratories and

at medico-technical departments involved in the clinical trial).

1.53

Sponsor

An individual, company, institution, or organization which takes responsibility for the

initiation, management, and/or financing of a clinical trial.

1.54

Sponsor-Investigator

An individual who both initiates and conducts, alone or with others, a clinical trial, and under

whose immediate direction the investigational product is administered to, dispensed to, or

used by a subject. The term does not include any person other than an individual (e.g., it does

not include a corporation or an agency). The obligations of a sponsor-investigator include

both those of a sponsor and those of an investigator.

1.55

Standard Operating Procedures (SOPs)

Detailed, written instructions to achieve uniformity of the performance of a specific function.

1.56

Subinvestigator

Any individual member of the clinical trial team designated and supervised by the

investigator at a trial site to perform critical trial-related procedures and/or to make important

trial-related decisions (e.g., associates, residents, research fellows). See also Investigator.

1.57

Subject/Trial Subject

An individual who participates in a clinical trial, either as a recipient of the investigational

product(s) or as a control.

1.58

Subject Identification Code

A unique identifier assigned by the investigator to each trial subject to protect the subject's

identity and used in lieu of the subject's name when the investigator reports adverse events

and/or other trial related data.

1.59

Trial Site

The location(s) where trial-related activities are actually conducted.

1.60

Unexpected Adverse Drug Reaction

An adverse reaction, the nature or severity of which is not consistent with the applicable

product information (e.g., Investigator's Brochure for an unapproved investigational product

or package insert/summary of product characteristics for an approved product) (see the ICH

Guideline for Clinical Safety Data Management: Definitions and Standards for Expedited

Reporting).

1.61

Vulnerable Subjects

Individuals whose willingness to volunteer in a clinical trial may be unduly influenced by the

expectation, whether justified or not, of benefits associated with participation, or of a

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retaliatory response from senior members of a hierarchy in case of refusal to participate.

Examples are members of a group with a hierarchical structure, such as medical, pharmacy,

dental, and nursing students, subordinate hospital and laboratory personnel, employees of the

pharmaceutical industry, members of the armed forces, and persons kept in detention. Other

vulnerable subjects include patients with incurable diseases, persons in nursing homes,

unemployed or impoverished persons, patients in emergency situations, ethnic minority

groups, homeless persons, nomads, refugees, minors, and those incapable of giving consent.

1.62

Well-being (of the trial subjects)

The physical and mental integrity of the subjects participating in a clinical trial.

2. THE PRINCIPLES OF ICH GCP

2.1

Clinical trials should be conducted in accordance with the ethical principles that have

their origin in the Declaration of Helsinki, and that are consistent with GCP and the

applicable regulatory requirement(s).

2.2

Before a trial is initiated, foreseeable risks and inconveniences should be weighed

against the anticipated benefit for the individual trial subject and society. A trial should

be initiated and continued only if the anticipated benefits justify the risks.

2.3

The rights, safety, and well-being of the trial subjects are the most important

considerations and should prevail over interests of science and society.

2.4

The available nonclinical and clinical information on an investigational product should

be adequate to support the proposed clinical trial.

2.5

Clinical trials should be scientifically sound, and described in a clear, detailed

protocol.

2.6

A trial should be conducted in compliance with the protocol that has received prior

institutional review

board (IRB)/independent ethics

committee

(IEC)

approval/favourable opinion.

2.7

The medical care given to, and medical decisions made on behalf of, subjects should

always be the responsibility of a qualified physician or, when appropriate, of a

qualified dentist.

2.8

Each individual involved in conducting a trial should be qualified by education,

training, and experience to perform his or her respective task(s).

2.9

Freely given informed consent should be obtained from every subject prior to clinical

trial participation.

2.10 All clinical trial information should be recorded, handled, and stored in a way that

allows its accurate reporting, interpretation and verification.

2.11 The confidentiality of records that could identify subjects should be protected,

respecting the privacy and confidentiality rules in accordance with the applicable

regulatory requirement(s).

2.12 Investigational products should be manufactured, handled, and stored in accordance

with applicable good manufacturing practice (GMP). They should be used in

accordance with the approved protocol.

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2.13 Systems with procedures that assure the quality of every aspect of the trial should be

implemented.

3. INSTITUTIONAL REVIEW BOARD/INDEPENDENT ETHICS

COMMITTEE

(IRB/IEC)

3.1 Responsibilities

3.1.1 An IRB/IEC should safeguard the rights, safety, and well-being of all trial subjects.

Special attention should be paid to trials that may include vulnerable subjects.

3.1.2 The IRB/IEC should obtain the following documents:

trial protocol(s)/amendment(s), written informed consent form(s) and consent form updates

that the investigator proposes for use in the trial, subject recruitment procedures (e.g.

advertisements), written information to be provided to subjects, Investigator's Brochure (IB),

available safety information, information about payments and compensation available to

subjects, the investigatorís current curriculum vitae and/or other documentation evidencing

qualifications, and any other documents that the IRB/IEC may need to fulfil its

responsibilities.

The IRB/IEC should review a proposed clinical trial within a reasonable time and document

its views in writing, clearly identifying the trial, the documents reviewed and the dates for the

following:

•

approval/favourable opinion;

•

modifications required prior to its approval/favourable opinion;

•

disapproval / negative opinion; and

•

termination/suspension of any prior approval/favourable opinion.

3.1.3 The IRB/IEC should consider the qualifications of the investigator for the proposed

trial, as documented by a current curriculum vitae and/or by any other relevant

documentation the IRB/IEC requests.

3.1.4 The IRB/IEC should conduct continuing review of each ongoing trial at intervals

appropriate to the degree of risk to human subjects, but at least once per year.

3.1.5 The IRB/IEC may request more information than is outlined in paragraph 4.8.10 be

given to subjects when, in the judgement of the IRB/IEC, the additional information

would add meaningfully to the protection of the rights, safety and/or well-being of the

subjects.

3.1.6 When a non-therapeutic trial is to be carried out with the consent of the subjectís

legally acceptable representative (see 4.8.12, 4.8.14), the IRB/IEC should determine

that the proposed protocol and/or other document(s) adequately addresses relevant

ethical concerns and meets applicable regulatory requirements for such trials.

3.1.7 Where the protocol indicates that prior consent of the trial subject or the subjectís

legally acceptable representative is not possible (see 4.8.15), the IRB/IEC should

determine that the proposed protocol and/or other document(s) adequately addresses

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relevant ethical concerns and meets applicable regulatory requirements for such trials

(i.e. in emergency situations).

3.1.8 The IRB/IEC should review both the amount and method of payment to subjects to

assure that neither presents problems of coercion or undue influence on the trial

subjects. Payments to a subject should be prorated and not wholly contingent on

completion of the trial by the subject.

3.1.9 The IRB/IEC should ensure that information regarding payment to subjects, including

the methods, amounts, and schedule of payment to trial subjects, is set forth in the

written informed consent form and any other written information to be provided to

subjects. The way payment will be prorated should be specified.

3.2 Composition, Functions and Operations

3.2.1 The IRB/IEC should consist of a reasonable number of members, who collectively

have the qualifications and experience to review and evaluate the science, medical

aspects, and ethics of the proposed trial. It is recommended that the IRB/IEC should

include:

a) At least five members.

b) At least one member whose primary area of interest is in a nonscientific area.

c) At least one member who is independent of the institution/trial site.

Only those IRB/IEC members who are independent of the investigator and the sponsor

of the trial should vote/provide opinion on a trial-related matter.

A list of IRB/IEC members and their qualifications should be maintained.

3.2.2 The IRB/IEC should perform its functions according to written operating procedures,

should maintain written records of its activities and minutes of its meetings, and

should comply with GCP and with the applicable regulatory requirement(s).

3.2.3 An IRB/IEC should make its decisions at announced meetings at which at least a

quorum, as stipulated in its written operating procedures, is present.

3.2.4 Only members who participate in the IRB/IEC review and discussion should

vote/provide their opinion and/or advise.

3.2.5 The investigator may provide information on any aspect of the trial, but should not

participate in the deliberations of the IRB/IEC or in the vote/opinion of the IRB/IEC.

3.2.6 An IRB/IEC may invite nonmembers with expertise in special areas for assistance.

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3.3 Procedures

The IRB/IEC should establish, document in writing, and follow its procedures, which should

include:

3.3.1 Determining its composition (names and qualifications of the members) and the

authority under which it is established.

3.3.2 Scheduling, notifying its members of, and conducting its meetings.

3.3.3 Conducting initial and continuing review of trials.

3.3.4 Determining the frequency of continuing review, as appropriate.

3.3.5 Providing, according to the applicable regulatory requirements, expedited review and

approval/favourable opinion of minor change(s) in ongoing trials that have the

approval/favourable opinion of the IRB/IEC.

3.3.6 Specifying that no subject should be admitted to a trial before the IRB/IEC issues its

written approval/favourable opinion of the trial.

3.3.7 Specifying that no deviations from, or changes of, the protocol should be initiated

without prior written IRB/IEC approval/favourable opinion of an appropriate

amendment, except when necessary to eliminate immediate hazards to the subjects or

when the change(s) involves only logistical or administrative aspects of the trial (e.g.,

change of monitor(s), telephone number(s)) (see 4.5.2).

3.3.8 Specifying that the investigator should promptly report to the IRB/IEC:

a) Deviations from, or changes of, the protocol to eliminate immediate hazards to the

trial subjects (see 3.3.7, 4.5.2, 4.5.4).

b) Changes increasing the risk to subjects and/or affecting significantly the conduct

of the trial (see 4.10.2).

c) All adverse drug reactions (ADRs) that are both serious and unexpected.

d) New information that may affect adversely the safety of the subjects or the

conduct of the trial.

3.3.9 Ensuring that the IRB/IEC promptly notify in writing the investigator/institution

concerning:

a) Its trial-related decisions/opinions.

b) The reasons for its decisions/opinions.

c) Procedures for appeal of its decisions/opinions.

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3.4 Records

The IRB/IEC should retain all relevant records (e.g., written procedures, membership lists,

lists of occupations/affiliations of members, submitted documents, minutes of meetings, and

correspondence) for a period of at least 3 years after completion of the trial and make them

available upon request from the regulatory authority(ies).

The IRB/IEC may be asked by investigators, sponsors or regulatory authorities to provide its

written procedures and membership lists.

4. INVESTIGATOR

4.1 Investigator's Qualifications and Agreements

4.1.1 The investigator(s) should be qualified by education, training, and experience to

assume responsibility for the proper conduct of the trial, should meet all the

qualifications specified by the applicable regulatory requirement(s), and should

provide evidence of such qualifications through up-to-date curriculum vitae and/or

other relevant documentation requested by the sponsor, the IRB/IEC, and/or the

regulatory authority(ies).

4.1.2 The investigator should be thoroughly familiar with the appropriate use of the

investigational product(s), as described in the protocol, in the current Investigator's

Brochure, in the product information and in other information sources provided by the

sponsor.

4.1.3 The investigator should be aware of, and should comply with, GCP and the applicable

regulatory requirements.

4.1.4 The investigator/institution should permit monitoring and auditing by the sponsor, and

inspection by the appropriate regulatory authority(ies).

4.1.5 The investigator should maintain a list of appropriately qualified persons to whom the

investigator has delegated significant trial-related duties.

4.2 Adequate Resources

4.2.1 The investigator should be able to demonstrate (e.g., based on retrospective data) a

potential for recruiting the required number of suitable subjects within the agreed

recruitment period.

4.2.2 The investigator should have sufficient time to properly conduct and complete the trial

within the agreed trial period.

4.2.3 The investigator should have available an adequate number of qualified staff and

adequate facilities for the foreseen duration of the trial to conduct the trial properly and

safely.

4.2.4 The investigator should ensure that all persons assisting with the trial are adequately

informed about the protocol, the investigational product(s), and their trial-related

duties and functions.

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4.3 Medical Care of Trial Subjects

4.3.1 A qualified physician (or dentist, when appropriate), who is an investigator or a sub-

investigator for the trial, should be responsible for all trial-related medical (or dental)

decisions.

4.3.2 During and following a subject's participation in a trial, the investigator/institution

should ensure that adequate medical care is provided to a subject for any adverse

events, including clinically significant laboratory values, related to the trial. The

investigator/institution should inform a subject when medical care is needed for

intercurrent illness(es) of which the investigator becomes aware.

4.3.3 It is recommended that the investigator inform the subject's primary physician about

the subject's participation in the trial if the subject has a primary physician and if the

subject agrees to the primary physician being informed.

4.3.4 Although a subject is not obliged to give his/her reason(s) for withdrawing prematurely

from a trial, the investigator should make a reasonable effort to ascertain the reason(s),

while fully respecting the subject's rights.

4.4 Communication with IRB/IEC

4.4.1 Before initiating a trial, the investigator/institution should have written and dated

approval/favourable opinion from the IRB/IEC for the trial protocol, written informed

consent form, consent form updates, subject recruitment procedures (e.g.,

advertisements), and any other written information to be provided to subjects.

4.4.2 As part of the investigator's/institutionís written application to the IRB/IEC, the

investigator/institution should provide the IRB/IEC with a current copy of the

Investigator's Brochure. If the Investigator's Brochure is updated during the trial, the

investigator/institution should supply a copy of the updated Investigatorís Brochure to

the IRB/IEC.

4.4.3 During the trial the investigator/institution should provide to the IRB/IEC all

documents subject to review.

4.5 Compliance with Protocol

4.5.1 The investigator/institution should conduct the trial in compliance with the protocol

agreed to by the sponsor and, if required, by the regulatory authority(ies) and which

was given approval/favourable opinion by the IRB/IEC. The investigator/institution

and the sponsor should sign the protocol, or an alternative contract, to confirm

agreement.

4.5.2 The investigator should not implement any deviation from, or changes of the protocol

without agreement by the sponsor and prior review and documented

approval/favourable opinion from the IRB/IEC of an amendment, except where

necessary to eliminate an immediate hazard(s) to trial subjects, or when the change(s)

involves only logistical or administrative aspects of the trial (e.g., change in

monitor(s), change of telephone number(s)).

4.5.3 The investigator, or person designated by the investigator, should document and

explain any deviation from the approved protocol.

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4.5.4 The investigator may implement a deviation from, or a change of, the protocol to

eliminate an immediate hazard(s) to trial subjects without prior IRB/IEC

approval/favourable opinion. As soon as possible, the implemented deviation or

change, the reasons for it, and, if appropriate, the proposed protocol amendment(s)

should be submitted:

a) to the IRB/IEC for review and approval/favourable opinion,

b) to the sponsor for agreement and, if required,

c) to the regulatory authority(ies).

4.6 Investigational Product(s)

4.6.1 Responsibility for investigational product(s) accountability at the trial site(s) rests with

the investigator/institution.

4.6.2 Where allowed/required, the investigator/institution may/should assign some or all of

the investigator's/institutionís duties for investigational product(s) accountability at the

trial site(s) to an appropriate pharmacist or another appropriate individual who is under

the supervision of the investigator/institution..

4.6.3 The investigator/institution and/or a pharmacist or other appropriate individual, who is

designated by the investigator/institution, should maintain records of the product's

delivery to the trial site, the inventory at the site, the use by each subject, and the return

to the sponsor or alternative disposition of unused product(s). These records should

include dates, quantities, batch/serial numbers, expiration dates (if applicable), and the

unique code numbers assigned to the investigational product(s) and trial subjects.

Investigators should maintain records that document adequately that the subjects were

provided the doses specified by the protocol and reconcile all investigational

product(s) received from the sponsor.

4.6.4 The investigational product(s) should be stored as specified by the sponsor (see 5.13.2

and 5.14.3) and in accordance with applicable regulatory requirement(s).

4.6.5 The investigator should ensure that the investigational product(s) are used only in

accordance with the approved protocol.

4.6.6 The investigator, or a person designated by the investigator/institution, should explain

the correct use of the investigational product(s) to each subject and should check, at

intervals appropriate for the trial, that each subject is following the instructions

properly.

4.7 Randomization Procedures and Unblinding

The investigator should follow the trial's randomization procedures, if any, and should ensure

that the code is broken only in accordance with the protocol. If the trial is blinded, the

investigator should promptly document and explain to the sponsor any premature unblinding

(e.g., accidental unblinding, unblinding due to a serious adverse event) of the investigational

product(s).

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4.8 Informed Consent of Trial Subjects

4.8.1 In obtaining and documenting informed consent, the investigator should comply with

the applicable regulatory requirement(s), and should adhere to GCP and to the ethical

principles that have their origin in the Declaration of Helsinki. Prior to the beginning

of the trial, the investigator should have the IRB/IEC's written approval/favourable

opinion of the written informed consent form and any other written information to be

provided to subjects.

4.8.2 The written informed consent form and any other written information to be provided to

subjects should be revised whenever important new information becomes available

that may be relevant to the subjectís consent. Any revised written informed consent

form, and written information should receive the IRB/IEC's approval/favourable

opinion in advance of use. The subject or the subjectís legally acceptable

representative should be informed in a timely manner if new information becomes

available that may be relevant to the subjectís willingness to continue participation in

the trial. The communication of this information should be documented.

4.8.3 Neither the investigator, nor the trial staff, should coerce or unduly influence a subject

to participate or to continue to participate in a trial.

4.8.4 None of the oral and written information concerning the trial, including the written

informed consent form, should contain any language that causes the subject or the

subject's legally acceptable representative to waive or to appear to waive any legal

rights, or that releases or appears to release the investigator, the institution, the

sponsor, or their agents from liability for negligence.

4.8.5 The investigator, or a person designated by the investigator, should fully inform the

subject or, if the subject is unable to provide informed consent, the subject's legally

acceptable representative, of all pertinent aspects of the trial including the written

information and the approval/ favourable opinion by the IRB/IEC.

4.8.6 The language used in the oral and written information about the trial, including the

written informed consent form, should be as non-technical as practical and should be

understandable to the subject or the subject's legally acceptable representative and the

impartial witness, where applicable.

4.8.7 Before informed consent may be obtained, the investigator, or a person designated by

the investigator, should provide the subject or the subject's legally acceptable

representative ample time and opportunity to inquire about details of the trial and to

decide whether or not to participate in the trial. All questions about the trial should be

answered to the satisfaction of the subject or the subject's legally acceptable

representative.

4.8.8 Prior to a subjectís participation in the trial, the written informed consent form should

be signed and personally dated by the subject or by the subject's legally acceptable

representative, and by the person who conducted the informed consent discussion.

4.8.9 If a subject is unable to read or if a legally acceptable representative is unable to read,

an impartial witness should be present during the entire informed consent discussion.

After the written informed consent form and any other written information to be

provided to subjects, is read and explained to the subject or the subjectís legally

acceptable representative, and after the subject or the subjectís legally acceptable

representative has orally consented to the subjectís participation in the trial and, if

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capable of doing so, has signed and personally dated the informed consent form, the

witness should sign and personally date the consent form. By signing the consent form,

the witness attests that the information in the consent form and any other written

information was accurately explained to, and apparently understood by, the subject or

the subject's legally acceptable representative, and that informed consent was freely

given by the subject or the subjectís legally acceptable representative.

4.8.10 Both the informed consent discussion and the written informed consent form and any

other written information to be provided to subjects should include explanations of the

following:

a) That the trial involves research.

b) The purpose of the trial.

c) The trial treatment(s) and the probability for random assignment to each

treatment.

d) The trial procedures to be followed, including all invasive procedures.

e) The subject's responsibilities.

f) Those aspects of the trial that are experimental.

g) The reasonably foreseeable risks or inconveniences to the subject and, when

applicable, to an embryo, fetus, or nursing infant.

h) The reasonably expected benefits. When there is no intended clinical benefit to

the subject, the subject should be made aware of this.

i) The alternative procedure(s) or course(s) of treatment that may be available to the

subject, and their important potential benefits and risks.

j) The compensation and/or treatment available to the subject in the event of trial-

related injury.

k) The anticipated prorated payment, if any, to the subject for participating in the

trial.

l) The anticipated expenses, if any, to the subject for participating in the trial.

m) That the subject's participation in the trial is voluntary and that the subject may

refuse to participate or withdraw from the trial, at any time, without penalty or

loss of benefits to which the subject is otherwise entitled.

n) That the monitor(s), the auditor(s), the IRB/IEC, and the regulatory authority(ies)

will be granted direct access to the subject's original medical records for

verification of clinical trial procedures and/or data, without violating the

confidentiality of the subject, to the extent permitted by the applicable laws and

regulations and that, by signing a written informed consent form, the subject or

the subject's legally acceptable representative is authorizing such access.

o) That records identifying the subject will be kept confidential and, to the extent

permitted by the applicable laws and/or regulations, will not be made publicly

available. If the results of the trial are published, the subjectís identity will remain

confidential.

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p) That the subject or the subject's legally acceptable representative will be informed

in a timely manner if information becomes available that may be relevant to the

subject's willingness to continue participation in the trial.

q) The person(s) to contact for further information regarding the trial and the rights

of trial subjects, and whom to contact in the event of trial-related injury.

r) The foreseeable circumstances and/or reasons under which the subject's

participation in the trial may be terminated.

s) The expected duration of the subject's participation in the trial.

t) The approximate number of subjects involved in the trial.

4.8.11 Prior to participation in the trial, the subject or the subject's legally acceptable

representative should receive a copy of the signed and dated written informed consent

form and any other written information provided to the subjects. During a subjectís

participation in the trial, the subject or the subjectís legally acceptable representative

should receive a copy of the signed and dated consent form updates and a copy of any

amendments to the written information provided to subjects.

4.8.12 When a clinical trial (therapeutic or non-therapeutic) includes subjects who can only

be enrolled in the trial with the consent of the subjectís legally acceptable

representative (e.g., minors, or patients with severe dementia), the subject should be

informed about the trial to the extent compatible with the subjectís understanding and,

if capable, the subject should sign and personally date the written informed consent.

4.8.13 Except as described in 4.8.14, a non-therapeutic trial (i.e. a trial in which there is no

anticipated direct clinical benefit to the subject), should be conducted in subjects who

personally give consent and who sign and date the written informed consent form.

4.8.14 Non-therapeutic trials may be conducted in subjects with consent of a legally

acceptable representative provided the following conditions are fulfilled:

a) The objectives of the trial can not be met by means of a trial in subjects who can

give informed consent personally.

b) The foreseeable risks to the subjects are low.

c) The negative impact on the subjectís well-being is minimized and low.

d) The trial is not prohibited by law.

e) The approval/favourable opinion of the IRB/IEC is expressly sought on the

inclusion of such subjects, and the written approval/ favourable opinion covers

this aspect.

Such trials, unless an exception is justified, should be conducted in patients having a

disease or condition for which the investigational product is intended. Subjects in these

trials should be particularly closely monitored and should be withdrawn if they appear

to be unduly distressed.

4.8.15 In emergency situations, when prior consent of the subject is not possible, the consent

of the subject's legally acceptable representative, if present, should be requested. When

prior consent of the subject is not possible, and the subjectís legally acceptable

representative is not available, enrolment of the subject should require measures

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described in the protocol and/or elsewhere, with documented approval/favourable

opinion by the IRB/IEC, to protect the rights, safety and well-being of the subject and

to ensure compliance with applicable regulatory requirements. The subject or the

subject's legally acceptable representative should be informed about the trial as soon as

possible and consent to continue and other consent as appropriate (see 4.8.10) should

be requested.

4.9 Records and Reports

4.9.1 The investigator should ensure the accuracy, completeness, legibility, and timeliness of

the data reported to the sponsor in the CRFs and in all required reports.

4.9.2 Data reported on the CRF, that are derived from source documents, should be

consistent with the source documents or the discrepancies should be explained.

4.9.3 Any change or correction to a CRF should be dated, initialed, and explained (if

necessary) and should not obscure the original entry (i.e. an audit trail should be

maintained); this applies to both written and electronic changes or corrections (see

5.18.4 (n)). Sponsors should provide guidance to investigators and/or the investigators'

designated representatives on making such corrections. Sponsors should have written

procedures to assure that changes or corrections in CRFs made by sponsor's designated

representatives are documented, are necessary, and are endorsed by the investigator.

The investigator should retain records of the changes and corrections.

4.9.4 The investigator/institution should maintain the trial documents as specified in

Essential Documents for the Conduct of a Clinical Trial (see 8.) and as required by the

applicable regulatory requirement(s). The investigator/institution should take measures

to prevent accidental or premature destruction of these documents.

4.9.5 Essential documents should be retained until 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. These

documents should be retained for a longer period however if required by the applicable

regulatory requirements or by an agreement with the sponsor. It is the responsibility of

the sponsor to inform the investigator/institution as to when these documents no longer

need to be retained (see 5.5.12).

4.9.6 The financial aspects of the trial should be documented in an agreement between the

sponsor and the investigator/institution.

4.9.7 Upon request of the monitor, auditor, IRB/IEC, or regulatory authority, the

investigator/institution should make available for direct access all requested trial-

related records.

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4.10

Progress Reports

4.10.1 The investigator should submit written summaries of the trial status to the IRB/IEC

annually, or more frequently, if requested by the IRB/IEC.

4.10.2 The investigator should promptly provide written reports to the sponsor, the IRB/IEC

(see 3.3.8) and, where applicable, the institution on any changes significantly affecting

the conduct of the trial, and/or increasing the risk to subjects.

4.11

Safety Reporting

4.11.1 All serious adverse events (SAEs) should be reported immediately to the sponsor

except for those SAEs that the protocol or other document (e.g., Investigator's

Brochure) identifies as not needing immediate reporting. The immediate reports should

be followed promptly by detailed, written reports. The immediate and follow-up

reports should identify subjects by unique code numbers assigned to the trial subjects

rather than by the subjects' names, personal identification numbers, and/or addresses.

The investigator should also comply with the applicable regulatory requirement(s)

related to the reporting of unexpected serious adverse drug reactions to the regulatory

authority(ies) and the IRB/IEC.

4.11.2 Adverse events and/or laboratory abnormalities identified in the protocol as critical to

safety evaluations should be reported to the sponsor according to the reporting

requirements and within the time periods specified by the sponsor in the protocol.