Aswin Nair
Aswin Nair
Aswin Nair
Clinical
trial
experiments
or
are
behavioral
done
in
clinical
research.
research
studies
on human
interventions,
including
as
novel vaccines, drugs, dietary choices, dietary supplements, and medical devices)
and known interventions that warrant further study and comparison. Clinical trials
generate data on safety and efficacy.
An institutional review board (IRB), also known as an independent ethics
committee (IEC), ethical review board(ERB), or research ethics board (REB), is a
type of committee used in research in the United States. They often conduct some
form of risk-benefit analysis in an attempt to determine whether or not research
should be done.[1] The purpose of the IRB is to assure that appropriate steps are
taken to protect the rights and welfare of humans participating as subjects in a
research study.
The first appearance of need of ethics committee (EC) was made in Declaration of
Helsinki in 1964, while in India it appeared in 1980 in the ICMR Policy Statement.
EC also called as the Institutional Review Board or the Ethics Review Board
stands as the bridge between the researcher and the ethical guidelines of the
country. ECs are responsible for carrying out the review of proposed research
before the commencement of the research. The basic responsibility of EC is to
ensure an independent, competent and timely review of all ethical aspects of the
project proposals received in order to safeguard the dignity, rights, safety and wellbeing of all actual or potential research participants.
but it cannot overrule local regulations and laws. There have been several updated
versions with the last accepted at the 59th WMA General Assembly in Seoul,
South Korea in 2008.
Ethics Committee
An EC reviews and subsequently approves or rejects research protocols
submitted by investigators/researchers (investigators). There are different kinds of
ECs. Some review protocols for animal studies, some for human studies in social
sciences such as psychology and education, and others for clinical trials in patients
or healthy volunteers. In this Guide, we address only the principles of ethics review
of protocols involving interventional studies or clinical trials in humans. Many
countries require and legally enforce approval by an EC before clinical trials can
be initiated for testing new drugs or vaccines, medical devices, diagnostics and
medical procedures referred to as test article in this Guide.
As stated in the Declaration of Helsinki: The research protocol must be
submitted for consideration, comment, guidance and approval to a research ethics
committee before the study begins. The ICH GCP states: A trial should be
conducted in compliance with the protocol that has received prior institutional
review board (IRB)/independent ethics committee (IEC) approval/favorable
opinion.
Different names are used for ethics committees reviewing human clinical
trial protocols, such as ethics committee (EC), research ethics committee (REC) or
institutional review board (IRB). For simplicity in this Guide, we use the term
Ethics Committee and the corresponding abbreviation EC. Regardless of the term
chosen for an individual EC, each operates in accordance with applicable laws and
regulations. We also need to clarify that most ECs review study protocols for a
single institution, such as a hospital, with or without academic affiliation, while
some are centralised, and review protocols from more than one institution/clinic.
Central ECs are designed to help reduce administrative burdens on local
ECs and investigators, while maintaining a high level of protection for human
research participants. This arrangement is especially useful when the investigator
works from a single physicians private practice or when multiple sites are
involved in the same geographical or judicial region. However, whether local or
centralised, ECs should all operate at the same standard.
A human research ethics committee EC should not be confused with any
hospital ethics committee (HEC) reviewing ethical or moral questions that may
arise during a patient's standard care. The EC reviews clinical research protocols,
while the HEC acts as the patients advocate, defining the ethical principles of
clinical procedures and management within a hospital.
3. Protect researchers
4. Enable researchers to obtain funding
5. Enable research to be published
According to Mark P. Aulisio and Robert M. Arnol in their article on Role of the
Ethics Committee they quoted Ethics committees arose in response to a clinical
need for a formal mechanism to address some of the value conflicts and
uncertainties that arise in contemporary health-care settings
To
protect
the
rights,
safety
and
well
being
of
patients;
by
Ensure that all participants in research are aware about the pros and cons for their
participation and have given appropriate Informed Consent.
To promote fair ethical policies and procedures which will maximize the
likelihood of achieving good and patient-oriented outcomes;
To enhance the ethical tenor between health care professionals and organisations
conducting clinical trials.
Responsibilities
Review of proposed research before the commencement of the research
Independent, competent and timely review of all ethical aspects of the
project proposals received.
Safeguard the dignity, rights, safety and well- being of all actual or potential
research participants
Ethical Considerations
Basic Ethical Principles in Human Research
The Belmont Report (1974) summarizes three basic ethical principles relevant to
research involving human subjects.
Beneficence
Maximize possible benefits and minimize possible harms
The investigator should give forethought to the maximization of benefits and the
reduction of risk that might occur from the research
Justice
Fairness in distribution
Justice occurs when some benefit to which a person is entitled is denied without
good reason or when some burden is imposed unduly
Equitable selection of participants
The highest level of risk arises when the product is first tested in humans (firstintohuman trials), followed by trials with dose escalation and multiple dosing.
Most of these trials are conducted in healthy volunteers, not participants with the
target disease. Initial human pharmacology clinical trials, conducted mostly on
healthy volunteers, are followed by exploratory trials where the test article is
administered on target participant groups for the first time. The reactions from
these participants may differ from those in healthy volunteers, so first-into-human
trials are also often regarded as having a higher risk of harm and therefore need
extra oversight
Clinical testing of medicinal products that are ineffective and/or have
unreasonable side-effects is terminated early. This means that late exploratory and
confirmatory clinical trials are performed on a subsample of products confidently
expected to have a reasonably low risk of inducing side-effects in relation to the
treatment effect, since the safety profile is acceptable. The targeted patient
population may also influence the degree of risk of a medicinal product. For
instance, life-threatening diseases such as cancer usually call for stronger and thus
potentially more toxic drugs with a different risk of harm acceptance from, for
instance, anti-flu drugs. Likewise, young children may have a higher risk of sideeffects than adults, due to their ongoing organ growth and the bodys functional
development in early life. Participants in need of multiple drug treatments, such as
psychiatric patients or drug abusers, have a risk of harm from drug-to-drug
interaction, which may be higher than for participants given the test drug who have
no other significant medical conditions. Proper risk assessment of a trial can be
made only with detailed access to the results of previous testing of the product, in
animals and humans, as well as details of the target population and knowledge
about the characteristics of the test article. Such information should be included in
any trial protocol. For trials overseen by a regulatory authority, additional details
are documented in a mandatory investigators brochure. Both the trial protocol and
the investigators brochure for a trial, if present, should be submitted to an EC for
review
the rationale behind the trial design and sample size, treatment blinding, the riskbenefit balance, participant compensation, informed consent, insurance/indemnity,
any conflicts of interest that may influence the collection of data or results, and
essential quality assurance measures.
Vulnerable participants.
Privacy and confidentiality.
Data safety monitoring.
Participant recruitment procedures
Qualification of investigators
Conflict of interest.
Clinical trial insurance and indemnity.
Essential clinical trial documents.
Clinical trial registration
Dissemination of trial results.
Issues of EC Procedures: Local laws and institutional guidelines.
Proportionate EC review.
Expedited/full board review.
Continuing review.
Acceptability of trial.
Trial amendments.
Adverse event reporting.
Anticipated problems.
Suspension or termination of a trial.
Complaints.
Appeals.
Non-compliance
during the past year. His nickname among the locals is in fact Seven to Eleven.
Despite this heavy workload, he has agreed to be the investigator of an herbal
extract oncology trial sponsored by a local herbal medicine company, Golden
Trust. He will recruit the cancer patients through his own clinic. Dr. Wong has
finally completed the EC application and will now send it to the EC of a local
medical teaching institution where he is a temporary lecturer.
The SOPs should be updated periodically based on the changing requirements. The
term of appointment of members could be extended for another term and a defined
percentage of members could be changed on regular basis. It would be preferable
to appoint persons trained in bioethics or persons conversant with ethical
guidelines and laws of the country. Substitute member may be nominated if
meetings have been continuously missed by a member due to illness or other
unforeseen circumstances. For this the criteria for number of missed meetings may
be defined in the SOP.
TRAINING
The EC members should be encouraged to keep abreast of all national and
international developments in ethics through orientation courses on related topics
by its own members or regular training organized by constituted body(ies), so that
they become aware of their role and responsibilities. For drug trial review it is
preferable to train the IEC members in Good Clinical Practice. Any change in the
regulatory requirements should be brought to their attention and they should be
aware of local, social and cultural norms, as this is the most important social
control mechanism
REGULATION
Once the legislation of guidelines occurs which is currently under active
consideration by the Ministry of Health, a Biomedical Research Authority will be
set up under the proposed Bill on Biomedical Research on Human
Participants(Promotion and Regulation) which would require that all IECs register
with this Authority. It will also evaluate and monitor functioning of the IECs, and
develop mechanisms for enforcing accountability and transparency by the
institutions.
REVIEW PROCEDURES
The IEC should review every research proposal on human participants
before the research is initiated. It should ensure that a scientific evaluation has
been completed before ethical review is taken up. The Committee should evaluate
the possible risks to the participants with proper justification, the expected benefits
and adequacy of documentation for ensuring privacy, confidentiality and the justice
issues.
The IECs member-secretary or secretariat shall screen the proposals for their
completeness and depending on the risk involved categorise them into three types,
namely, exemption from review, expedited review and full review (see below for
explanation). Minimal risk would be defined as one which may be anticipated as
harm or discomfort not greater than that encountered in routine daily life activities
of general population or during the performance of routine physical or
psychological examinations or tests. However, in some cases like surgery,
chemotherapy or radiation therapy, great risk would be inherent in the treatment
itself, but this may be within the range of minimal risk for the research participant
undergoing these interventions since it would be undertaken as part of current
everyday life. An investigator cannot decide that her/his protocol falls in the
exempted category without approval from the IEC. All proposals will be
SUBMISSION OF APPLICATION
The researcher should submit an application in a prescribed format along
with the study protocol as prescribed in SOP of IEC concerned. The protocol
should include the following: 1. The title with signature of Principal Investigator (PI) and Co investigators as
attestation for conducting the study.
2. Clear research objectives and rationale for undertaking the investigation in
human participants in the light of existing knowledge
3. Recent curriculum vitae of the Investigators indicating qualification and
experience.
4. Participant recruitment procedures and brochures, if any.
5.Inclusion and exclusion criteria for entry of participants.
6. Precise description of methodology of the proposed research, including sample
size (with justification), type of study design (observational, experimental, pilot,
15. A statement on probable ethical issues and steps taken to tackle the same like
justification for washout of standard drug, or the use of placebo control.
16. All other relevant documents related to the study protocol like investigator's
brochure for trial on drugs / devices / vaccines / herbal remedies and statement of
relevant regulatory clearances.
17. Agreement to comply with national and international Good Clinical Practices
(GCP) protocols for clinical trials.
18. Details of Funding agency/ Sponsors and fund allocation.(Format for JNU
provided)
19. For international collaborative study details about foreign collaborators and
documents for review of Health Ministry's Screening Committee(HMSC) or
appropriate Committees under other agencies/authority like Drug Controller
General of India (DCGI)
20. For exchange of biological material in international collaborative study a MoU/
Material Transfer Agreement between the collaborating partners.
21. A statement on conflict-of-interest (COI), if any.
The IEC should be able to provide complete and adequate review of the
research proposals submitted to them. It should meet periodically at frequent
intervals to review new proposals, evaluate annual progress of ongoing ones,
review serious adverse event (SAE) reports and assess final reports of all research
activities involving human beings through a previously scheduled agenda,
amended wherever appropriate. The following points should be considered while
doing so:
1. The decision must be taken by a broad consensus after the quorum requirements
are fulfilled to recommend / reject / suggest modification for a repeat review or
advice appropriate steps. The Member Secretary should communicate the decision
in writing to the PI.
2. If a member has conflict-of-interest (COI) involving a project then s/he should
submit this in writing to the chairperson before the review meeting, and it should
also be recorded in the minutes.,
3. If one of the members has her/his own proposal for review or has any COI then
s/he should withdraw from the IEC while the project is being discussed
4. A negative decision should always be supported by clearly defined reason
REVIEW PROCESS
The method of review should be stated in the SOP whether the review
should be done by all reviewers or by primary reviewer(s) in which case a brief
summary of the project with informed consent and patient information sheet,
advertisements or brochures, if any, should be circulated to all the other members.
The ethical review should be done in formal meetings and EC should not take
decisions through circulation of proposals. The committee should meet at regular
intervals and should not keep a decision pending for more than 3 - 6 months, which
may be defined in the SOP.
PERIODIC REVIEW
The ongoing research may be reviewed at regular intervals of six months to one
year as may be specified in the SOP of the ethics committee.
CONTINUING REVIEW
The IEC has the responsibility to continue reviewing approved projects for
continuation, new information, adverse event monitoring, follow-up and later after
completion if need be.
INTERIM REVIEW
Each IEC should decide the special circumstances and the mechanism when an
interim review can be resorted to by a sub-committee instead of waiting for the
scheduled time of the meeting like re-examination of a proposal already examined
by the IEC or any other matter which should be brought to the attention of the IEC.
However, decisions taken should be brought to the notice of the main committee.
MONITORING
Once IEC gives a certificate of approval it is the duty of the IEC to monitor the
approved studies, therefore an oversight mechanism should be in place. Actual site
visits can be made especially in the event of reporting of adverse events or
violations of human rights. Additionally, periodic status reports must be asked for
at appropriate intervals based on the safety concerns and this should be specified in
the SOP of the IEC. SAE reports from the site as well as other sites are reviewed
by EC and appropriate action taken when required. In case the IEC desires so,
reports of monitoring done by the sponsor and the recommendations of the DSMB
may also be sought.
RECORD KEEPING
All documentation and communication of an IEC are to be dated, filed and
preserved according to written procedures. Strict confidentiality is to be maintained
during access and retrieval procedures. The following records should be
maintained for the following:
i. The Constitution and composition of the IEC;
ii. Signed and dated copies of the latest the curriculum vitae of all IEC members
with records of training if any;
iii. Standing operating procedures of the IEC;
iv. National and International guidelines;
v. Copies of protocols submitted for review;
vi. All correspondence with IEC members and investigators regarding application,
decision and follow up;
vii. Agenda of all IEC meetings;
viii. Minutes of all IEC meetings with signature of the Chairperson;
ix. Copies of decisions communicated to the applicants;
x. Record of all notification issued for premature termination of a study with a
summary of the reasons;
xi. Final report of the study including microfilms, CDs and Video recordings.
It is recommended that all records must be safely maintained after the
completion/termination of the study for a period of 3 years if it is not possible to
maintain the same for more than that due to resource crunch and lack of
infrastructure.
Documentation
For a thorough and complete review, all research proposals should be
submitted
with the following documents :
1.Name of the applicant with designation.
2.Name of the Institute/ Hospital / Field area where research will be conducted
3. Approval of the Head of the Department / Institution
6. Proposal should be submitted with all relevant enclosures like proformae, case
report forms, questionnaires, follow - up cards, etc.
7. Informed consent process, including patient information sheet and informed
consent form in local language(s).
8. For any drug / device trial, all relevant pre-clinical animal data and clinical
trial data from other centres within the country / countries, if available.
9. Curriculum vitae of all the investigators with relevant publications in last five
years.
10. Any regulatory clearances required.
11. Source of funding and financial requirements for the project
.
12. Other financial issues including those related to insurance
13. An agreement to report only Serious Adverse Events (SAE) to IEC.
14. Statement of conflicts of interest, if any.
15. Agreement to comply with the relevant national and applicable international
guidelines.
16. A statement describing any compensation for study participation (including
expenses and access to medical care) to be given to research participants; a
description of the arrangements for indemnity, if applicable (in study-related
injuries); a description of the arrangements for insurance coverage for
research participants, if applicable; all significant previous decisions(e.g.,
those leading to a negative decision or modified protocol) by other ECs or
regulatory authorities for the proposed study (whether in the same location or
elsewhere) and an indication of the modification(s) to the protocol made on
research involving
clinical rationale behind the protocol. This is why EC members should be provided
with a detailed trial protocol. A protocol that is unsound from either a scientific
and/or clinical viewpoint should not be conducted and thus not be approved by
the EC.
A clinical trial that will not advance knowledge about a certain medical test
article should not be conducted, since the risk-benefit balance for participants will
be unacceptably high. With any trial there comes a certain risk of harm e.g.,
expected adverse events ranging from accidents when traveling to the study site,
to catching an infectious disease in a health care setting or encountering an adverse
event during a routine practice that is an unnecessary, rather than standard,
treatment-related medical procedure. But even if the results are negative
ultimately showing no beneficial effect of the test article the trial still advances
our knowledge. All data collected during a clinical trial must be free of errors. It is
intended for use as an important body of evidence when a new medicinal product
is reviewed by the government drug regulatory authority. Before a product can be
used in medical care ,the regulatory authority reviews the results from all trials of
the product. After approval is granted, the product will be given to a large patient
population. For this reason, the regulatory authority must be sure that all
supporting data included in the new drug application file are trustworthy and
reliable, so the efficacy and safety profile of the product can be accurately
established. This is why quality assurance is an important issue in clinical trials
Issues of EC Procedures
acceptable for expedited review or not, and this is driven by local laws and
institutional guidelines.
Acceptability of Trial
The EC should deem that all clinical trials are subject to scientific review, and thus
avoid putting participants at unnecessary risk of harm. A scientific review judges
the importance of the research question and validity of the methodology; this can
only be assessed by those familiar with the disciplines and methods of the
proposed research. Traditionally, clinical trials undergo scientific review as part of
the EC review process, using appropriate expertise among EC members. Clinical
trials overseen by regulatory authorities will have already been subject to scientific
review prior to the EC review. It is thus good practice to collect information from
the EC application about the types of scientific reviews a particular trial has been
subject to prior to the EC review, for instance, by regulatory authorities or granting
agencies. Any protocol raising many minor concerns or a few major concerns
should either be rejected or subject to revision and subsequently re-assessed.
Results from a trial not based on or adhering to current scientific knowledge,
lacking important pre-clinical information and/or using substandard trial design
will, in most cases, not be conclusive and therefore not be useful. Such trials could
also put participants at risk of harm without any scientific reason, while also
consuming financial and human resources that might be more purposefully
directed to other more important research projects.
ABBREVIATIONS
ADR
AE
Adverse Event
CRA
CRC
CRFs
CRO
DSMC
EC
Ethics Committee
EMEA
ERB
FDA
GCP
GLP
GMP
HRPP
ICH
ICMJE
IDMC
IEC
IND
IRB
NDA
QoL
Quality of Life
REC
SAE
SOPs
WMA
Conclusion
In summary, research is commonplace in short-term training programs in
global health. This is true in medicine, public health, engineering, and many other
disciplines.
2. This case involved several potentially competing aims: Bryces career goals,
the interests of his home advisor, the sponsors funding choice, and the local
priorities. In general, local priorities should take priority when designing a
research project.
3. Lastly, trainees, sending and host institutions, and sponsors should all be
aware that research is subject to IRB and local ethics committee oversight.
When questions arise or changes to the research occur, it is imperative to
contact these oversight bodies for advice and approval.